Human Resources Policies and Procedures:
Daybreak revised the corporate Employee Handbook (July 2020) that set out the main policies and procedures that guide human resources management to include (i) general employment policies and procedures such as equal opportunity and anti-harassment policies, sexual harassment, violence in the workplace, conflict of interest, grievance procedures, casual workers policy (ii) leave entitlements such as annual, sick, maternity and paternity leave; (iii) disciplinary procedures and lists misconduct as sexual harassment, violence at workplace, theft, fraud or pilferage, causing an accident through negligence and (iv) code of conduct to minimize potential disturbance to local communities and local natural resources. The policies in the Employee Handbook apply to all direct staff, consultants, contractors and are consistent with the requirements of Performance Standard 2 (PS 2). The Company will strengthen its recruitment and retention of women talent strategy and actions, including exploring employment and career opportunity barriers for women (ESAP #4). This will be in addition to the current Female Solar Engineering Trainee program specifically for young female engineers designed by the Company to drive diversity.
Working Conditions and Terms of Employment:
Daybreak has a workforce of about 87 direct employees, of which 22 are female and four expatriates. For equipment installation, operation & maintenance, excavation & construction projects and security provision, Daybreak engages services of contractors. The contracted and subcontracted workers, in various categories range between 20 - 100 at a given period depending on work streams.
All employees have written individual contracts specifying terms of employment, hours of work, salary amounts, timelines, rights and responsibilities in line with national laws The staff are entitled to holiday leaves and sick pay; workplaces are generally adequate in space, fitted with safety features and have sex-segregated facilities. There are no migrant workers in the company. None of the employees belongs to any workers’ organization, and no collective bargaining agreements have been entered into between Daybreak and any workers’ organization. Though management has indicated that there are no restrictions for workers to join trade unions/organizations at will, this is not documented in the Handbook. The company will explicitly state in the Handbook that there are no restrictions on freedom of association and for workers to join trade unions/organizations (ESAP #5).
Non-discrimination and Equal Opportunity:
Daybreak commits to be an equal opportunity employer and has designed policies in the Staff Handbook that prohibit any form of discrimination and harassment, including on grounds of gender, sexual orientation, marital or civil partner status, pregnancy or maternity, gender reassignment, race, color, nationality, ethnic or national origin, religion or belief, disability or age. The Handbook has further set out conditions construed as harassment, and these include sexual harassment, and appropriately defines how such cases are addressed in case they occur, as part of a disciplinary and capability procedure. Serious cases of deliberate discrimination may amount to gross misconduct resulting in dismissal.
COVID 19 Pandemic:
Due to the COVID-19 pandemic, Daybreak has developed COVID-19 Standard Operating Procedures (SOP) which provides for additional health and safety measures across the business. These measures include regular staff sensitization on the disease, staff screening at workplaces, additional workplace sanitization and prevention of unsafe work at this period. In the early days of the COVID-19 pandemic (April 2020), 11 employees mainly graduate hires and drivers were placed on unpaid leave with full benefits. All the eleven employees have resumed their duties by July 2020.
Grievance Mechanism (GM):
Daybreak developed a workers’ grievance procedure in 2019 that fits the Company’s operations. This procedure is part of the Employee Handbook, issued to every employee. The procedure covers a wide range of complaints, is clear, provides for documented grievance reporting, alternative handling methods, regular meeting and feedback to claimants and appeal options. A Whistleblowing Policy has also been developed to provide for anonymous grievances to be raised. This mechanism is commensurate with the nature of Daybreak’s operations, enables traceability and is consistent with minimum PS 2 requirements. However, the company will review HR policy and Grievance Mechanism as per PS2 requirements. The review will include updates on anti-sexual harassment and sensitive reporting, training and implementation including how Daybreak tracks, logs, analyses and responds to grievances received and resolved (ESAP #6).
Protecting the Workforce:
The employee recruitment process aligns to respective country legal provisions, which are designed to prevent child labor or forced labor. The Company has minimum use of contractors and monitors the use of child or forced labor in its operations by requesting for identification documents during recruitment. However, the Company will document its commitment and implement supervision mechanism against risks of child or forced labor and will impose consequences for breaches. It will require a declaration on this by contracted parties (ESAP # 7).
Occupational Health and Safety (OHS):
Daybreak has developed OHS policies and procedures that focus on reducing and managing the impact of identified OHS risk aspects as outlined in the OHS Management System Manual (Oct 2019). The manual operationalises the OHS policy and include planning, organisation, implementation, monitoring and audit & review. Daybreak conducts series of specific OHS training to staff, in addition to the mandatory induction training. In early 2020, the trainings were on first aid, practical firefighting and hazard identification and risk management.
The Company has an incident register. The register maintains first aid cases, medical treatment case, restricted work case, lost time incident and fatality. No serious accidents or fatalities have been reported. Safety statistics for the past three years indicate one medical treatment case from a contractor.
Due to the COVID-19 pandemic, Daybreak implements additional health and safety measures across the business. These measures include regular staff sensitization on the disease, staff screening at workplaces, additional workplace sanitization and prevention of unsafe work at this period.
Workers engaged by third parties:
Daybreak engages contractors in some aspect of their operations. Such activities include civil works, PVC panel installation and security provision. The Company signs formal contract documents with these third contractors and has a policy on causal workers engagement. In the planned expansion, the use of contractors is likely to increase. As indicated above, the Company will document its commitment and supervision mechanism to ensure that every contractor retains formal contracts, that comply with local employment laws, with their workers, and meets Company’s policies and this Performance Standard.
Supply Chain:
The Company purchases its modules directly and on an ongoing basis from four module suppliers and runs competitive tenders at least twice annually based on its pipeline of projects. Due to this ongoing panel sourcing IFC Performance Standard 2 supply chain requirements will apply to this project. To address these requirements, Daybreak will seek representations from its suppliers on the labor standards in the module supply chain. Daystar will engage with its module suppliers to explore various mitigation measures including: (i) representation in the module purchase contract that there are no unacceptable labor practices in the module supplier’s operations and that it is in compliance with IFC Performance Standards 2 and other international standards such as the ten principles of the United Nations Global Compact, applicable International Labor Organization conventions; (ii) representation from the module supplier(s) that their sub-suppliers do not engage in unacceptable labor practices and comply with similar international performance standards as the module suppliers; (iii) for Daybreak to have monitoring rights over the module supplier(s) and their sub-suppliers to verify compliance with the representation clauses; (iv) termination of the purchase contract if either the module supplier or its sub-suppliers are found to be in breach of the labor representations; and (v) removal of the module supplier, by Daybreak, from all its future solar module tenders, if there is a breach of the labor representations. (ESAP # 8).
