Al Douh currently employs 217 direct workers, of which 215 are male and 2 females, whose duties include the management and administration of the plant, raw materials and finished products handling, security and other miscellaneous activities such as driving, water management, landscaping etc.
The O&M contractor employs 120 direct workers, of which three are female, performing all activities required to operate the existing production line and to perform any maintenance activities that may be required.
Workers employed by both Al Douh and O&M contractor are provided with written contracts defining their labor and working conditions.
It is estimated that up to 300 workers will be required for the construction of the plant extension. The workers will be employed by the selected EPC contractor.
Human Resources Policies, Procedures and Terms of Employment:
The Company has a Human Resources (“HR”) Department, responsible for workers directly employed by Al Douh, while the O&M Contractor is responsible for the management of its own workers.
The Company does not have a documented HR policy and associated procedures in place. The O&M contractor has defined and implemented their own policies and procedures defining their HR management approach and procedures.
The Company will develop a HR policy (ESAP item 2.1), ensuring alignment of labor and working conditions with the Iraq Labor Law (2015) and IFC PS2, and covering areas including, but not limited to, recruitment, probation, wages, non-discrimination, leave, freedom of association, benefits etc. The O&M contractor’s existing corporate policy is aligned with the requirements of Iraqi legislation and defines the management / worker relationship.
Working Conditions and Management of Worker Relationships:
The terms of employment of all Company workers are subject to Iraqi labor laws, which regulate salaries, overtime, benefits, leave and working conditions. The Company provides transportation for the workers from/to their homes. No canteen is provided and, according to Iraqi legislation, the Company gives the workers monetary compensation in lieu of meals.
The O&M contractor’s labor and working conditions are also largely aligned with local labor law, including working hours, remuneration, leave etc. The O&M Contractor’s employees have a worker organization and are represented by elected worker representatives. Under the terms of the contract the O&M Contractor’s workers are accommodated at a workers’ camp that is located within the boundary of the cement plant. Workers’ accommodation is largely aligned with the requirements of the IFC/EBRD guidance note, Workers’ Accommodation: Processes and Standards.
To ensure alignment with both Iraqi legislation and IFC PS2, the Company will conduct a labor audit of their current labor and working conditions, as well as those of the O&M Contractor. Where gaps are identified, these will be addressed through a time bound action plan, as detailed in ESAP item 2.2. The Company’s HR Policy and procedures, as detailed in ESAP item 2.1, will incorporate the findings and recommendations of the audit and action plan. The renewal of the O&M contract, due in December 2023, will also incorporate findings and recommendations of the audit.
Both the Company and the O&M Contractor rely on public service providers in case of medical emergencies. Therefore, no medical personnel or medical facilities are present at the plant. The Company has however agreed to retain a qualified nurse or medic for each working shift and to set up a basic clinic to administer first aid, to perform a preliminary assessment of injuries in case of serious incident and to stabilize the victim, if necessary, prior to arrival of the public medical services. This is outlined in ESAP item 2.3.
Non-Discrimination, Equal Opportunity, and Protecting the Workforce:
The Company currently employs mostly male workers, while the O&M contract has three female employees. Al Douh has not yet formalized a policy to ensure equal opportunities at the workplace, and to prevent the occurrence of any form of forced/child labor. Such policies and the associated control procedures will be included in the ESMS as outlined in ESAP item 1.3.
Grievance Management:
Al Douh do not currently have a formalized process to allow for the submission of grievances from direct and contracted workers. Thus, the Company, as a component of their ESMS as described under ESAP 1.3, will develop and implement a worker grievance mechanism whereby workplace concerns and grievances can be raised. The Company will inform workers in a written form of the mechanism at the time of recruitment and make it readily accessible. The mechanism will ensure an appropriate level of Company management is involved in addressing grievances and that these are addressed promptly, using an understandable and transparent process that provides timely feedback to those concerned, without retribution. The mechanism will also allow for anonymous grievances to be raised and addressed. While the O&M Contractor have implemented their own grievance management mechanism, including an online reporting platform, Al Douh will extend their grievance management process to contract employees as necessary.
Occupational Health and Safety (OHS):
The Company has yet to develop a formal OHS management system and currently has no staff dedicated to management and monitoring of OHS issues within the Company workforce or within the contractors’ organizations. Specifically, there is room for improvement of workers’ protection at the quarry sites and practices related to electrical safety, machinery guarding, hazardous materials’ handling and storage, bulk transportation, and mechanical excavation.
In view of the forthcoming construction activities, which will take place while the existing plant will be operating, Company will request the selected EPC contractor to perform an OHS audit and a review of OHS risks and hazards associated with the construction activities (ESAP item 2.4). Based on the findings and recommendations of the audit, the Contractor will develop and implement, as a component of their CESMPs, an OHS policy and an OHS Management Plan, including a medical surveillance program for all construction workers, direct and contracted, working on the Project construction activities.
The Company will undertake OHS audit and process safety review focused on plant operations and develop an OHS management plan. The OHS audit will extend to operation of the quarries that are allocated to the Company for extraction of its raw materials. Based on the findings and recommendations of the audit, the Company will develop and implement, as a component of their ESMS, an OHS policy and an OHS Management Plan aligned with the requirements of the PS, WBG EHS Guidelines and GIIP for the sectors (Cement and Construction Materials Extraction). The OHS Policy and Management Plan, will be extended to the O&M workers and to quarry workers, as applicable. These enhancement measures are captured and outlined in ESAP item 2.5.
As part of the OHS Management Plan the Company will provide safety training to all its direct and contracted workers, including contractors working at the quarries. The safety training program and will be developed as part of the ESMS as outlined in ESAP item 1.3.
