The labor force for the Dawa water project during the construction phase is expected to be around 130 workers with only around 10 direct workers. The operations and management (“O&M”) contractor will operate and maintain the water treatment plant for one year before handing the project over to SWC. The Company will retain the direct workers throughout the construction and operation phases of the project. The project will not construct workers accommodation as majority of the workers will be sourced from the local population. The water project engineering, procurement and construction contractor will source accommodation for its core project management team from the existing local housing market. However, the project will provide four houses to accommodate core operation phase workers at the water treatment plant.
The labor force for the solar power installation phase has been estimated as approximately 60 workers with only around 10 direct workers. An O&M contractor will operate and maintain the solar power generation with the company retaining its direct workers throughout the construction and operation phases of the project.
EPCL have existing substations within TEMA FZ and Dawa IZ. Therefore, no significant works will be done to connect the SWC and HSC project components to power. The EPCL workers’ numbers will be determined based on contract scope with SWC and HSC.
HR Policies, Procedures and Terms of Employment
SWC, EPCL and HSC implement the LMI Group HR policies and procedures which require compliance with local labor laws and a commitment to equal opportunity. The group HR Policy and procedures includes policies and procedures for recruitment, compensation and benefits, salary and wage payment, increments and adjustments, general and sexual harassment and requisite reporting procedures, leave (annual, sick, maternity, paternity), staff code of conduct, disciplinary actions, performance management, learning and development, succession planning, terminations (dismissal, retirement, redundancy, resignation and death). Workers are provided with contracts that outline their engagement terms as well as stipulated working hours, confidentiality policies, statutory deductions, and notification addresses. The group employee policy handbook also outlines the group’s commitments and was developed as a guidance to new staff on the HR policies and procedures. The communication policy outlines the mechanisms and platforms for use and the group HR department and line managers facilitate continuous staff sensitization, provision of updates from management and collection of staff feedback and concerns. SWC, EPCL and HSC will update the HR policies and procedures by adding policy statements and relevant procedures on freedom of association and collective bargaining; operation and maintenance of company owned workers housing; prohibition of child and forced labor for its direct and third-party workers; and integrate mechanisms for implementation of these provisions in the HR policy and procedures manual. The three companies will also review and update the manual and employee handbook to cover retrenchment policies and procedures including provision of explicit statements on the engagement of workers and unions in the development of retrenchment/redundancy plans in accordance with local laws and PS 2 requirements. The three companies will ensure that the updates workers grievance redress mechanisms are accessible to their workers, allow for prompt resolution of workers concerns, provide for receipt and resolution of grievances on multiple platforms including anonymous grievances and specific mechanisms for managing complaints related to sexual harassment (ESAP #5). All updates will be communicated to workers through available internal communication platforms and sensitization sessions will be organized to communicate any material changes to existing contractual terms.
Grievance Management
The LMI Group harassment policies outline the channels for reporting of general harassment as well as sexual harassment and harassment against persons with disability. However, there are no documented grievance redress mechanisms, templates, or a description of the kind of records to be kept for reporting, recording and resolutions of grievances. SWC, EPCL and HSC will each document a workers grievance redress mechanism, make these accessible to their workers and allow for prompt resolution of workers concerns. The mechanism will also provide for receipt and resolution of grievances on multiple platforms including anonymous grievances and specific mechanisms for managing complaints related to sexual harassment; as required in ESAP #5 above.
Occupational Health and Safety (OHS)
LMI Group HR policies and procedures outline the health and safety commitments on staff awareness, housekeeping and cleanliness, fire safety, first aid, accident insurance, workmen’s compensation as well as management and worker’s responsibilities on health and safety in the workplace. The policy covers employees, customers and visitors to the organization’s premises. The group’s company vehicle policy aims at ensuring safe vehicle use while targeting zero fatalities from use of company vehicles. It requires that authorized drivers have a valid license, appropriate qualifications and that they comply with the group alcohol prohibition policies, incident and accident reporting mechanisms and record keeping per availed templates, maintenance policies and procedures as well as local road traffic laws and regulations. The policy indicates the background checks that management are required to undertake before authorizing drivers as well as disciplinary measures for breach of policy. The E&S risk management procedure to be developed SWC, EPCL and HSC as part of the ESMS under ESAP#1 will also include references to those OHS risk management measures. The procedure will have provisions for worker training and workplace safety, risk assessment, establishment of risk register, incident reporting and investigation and management/monitoring of contractors OHS risks.
COVID 19 Management: None of SWC, EPCL and HSC experienced any retrenchment due to pandemic. COVID-19 procedures were established to manage the disease in the workplace including provision of sanitizers and handwash stations. The SWC, EPCL and HSC emergency preparedness and response plans will be updated to cover COVID-19 measures including applicable crisis management measures, as a part of ESAP#4.
Workers Engaged by Third Parties and Supply Chain
SWC will engage an engineering, procurement and construction contractor for the design and construction phase and maintain the same contractor to operate the project for one year. HSC and EPCL will also engage contractor for their respective installation and transmission line extension works. SWC, EPCL and HSC will each develop and implement a contractor E&S management procedure, that will include labor requirements including monitoring and periodic audit of contractors’ labor practices (as necessary); and integrate these and related reporting requirements into contract agreements (per ESAP#1). To monitor contractors’ comply compliance with the HR policies and procedures including OHS, labor management and workers’ grievance mechanisms, HSC will undertake a labor practices due diligence screening of shortlisted engineering, procurement and construction contractors and their primary suppliers for the solar modules, which will include screening for potential for unfair labor practices in the supply chain as required in ESAP #3.
