The company has about 1787 directly hired employees (as on August 2021) including CHL Corporate staff (which includes the projects under construction), and operating Hotels, commercial and retail assets across India. The gender split of staff is roughly 86% male and 14% female. In addition, the off-roll employees (contract workers) account for around 339 across all the operating assets. The contracted workforce is hired for multiple services including housekeeping, security, engineering, horticulture, pest control, CCTV management, secure/ valet parking, loss prevention, cooks/chefs, kitchen stewarding, maintenance, civil work, drivers, helpers, etc. Apart from these some of the hotels also have to rely upon on demand contract workers whenever the hotels have big events organized; these events are not happening since onset of COVID-19. The contract workers working at Chalet premises are either sourced through manpower supply agencies (usually for specialized skill sets) or through service contracts. The construction workforce numbers are variable as the construction work (at 3 sites) and the construction work has been impacted due to COVID-19.
While overall meeting minimum standards, CHL Hotels has a higher obligation to monitor the implementation of policies and actions to minimize gender-related risks in its operations. In particular, Marriot would benefit from increased staff training and other actions; while CHL can strengthen a survivor-centred approach in its sexual harassment policies. As part of the ESAP 7, CHL will develop a strategy to drive gender equality & the empowerment of women in order to close the gap between male vs female employees and in position of importance within the organization, ensuring specifically that achieving gender parity is a goal of the organization. The strategy will include increased monitoring and provide specialized trainings in regards to hiring practices at all CHL facilities, ensuring there are no discriminatory practices in regards to recruitment, hirings and promoting women. It will also include an explicit policy prohibiting pregnancy health test related to screening and selection of potential women employees.
The current assessment is based on detailed review of HR related documentary evidence and detailed consultation with the CHL, Marriott, and Accor HR Managers. As part of the ESAP 3, CHL will undertake a third party labor assessment through specialized consultant (as per IFC PS 2 and applicable local regulations) including a detailed review of labor and working conditions with a focus on labor rights including freedom of association, collective bargaining, the recent retrenchment, prevention of sexual harassment, avoidance of discrimination, grievance mechanism, wages/overtime payments, social security benefits, open court cases, labor liabilities etc. across different hotels and retail/commercial assets of the company. The third party labour assessment will cover CHL corporate, sample operating assets operated by Marriott, and Accor. CHL will implement corrective action to address gaps, if any, from the third party labour assessment through a time bound action plan.
HR Policies and Procedures, Working Conditions and Terms of Employment:
Chalet has an HR policy applicable for all the Corporate staff, Project team (construction) which operates directly under K Raheja Group, retail (Inorbit) and commercial (Mindspace). Retail and commercial are mostly managed by CHL through management contract with Mindspace and Inorbit teams, which operates directly under K Raheja Group. The retail assets and commercial assets wherever, directly managed by CHL or Inorbit or Mindspace have Chalet HR policies applicable to them, which is same as the HR Manual for the K Raheja Group. In case of retail assets, the employees are on the payroll of Inorbit.
In case of hotel assets owned by CHL and operated by Marriott & Accor, while the staff are on the pay roll of CHL, the hiring as well as the terms and condition of employment are governed by Marriott/ Accor HR policies. Almost all the employees excluding some of the security staffs and housekeeping staffs are on-roll staff or direct employee of the CHL. All the staff of CHL hired directly or through operators receive joining letter clearly articulating the terms and conditions of employment. All direct employees after joining are expected to complete the probation period and are provided with written appointment letters which explain their employment terms and conditions. The HR policies include employee benefits, payment, separation, etc. As part of the ESAP 4, the company will update the corporate HR policy/guideline including documented policies and procedures on (a) Retrenchment policy and procedures for employees working within CHL properties; (b) Freedom of association & collective bargaining (including policy that ensures respect for the right of unions, which were formed by workers and whose representatives were elected by the workers, to negotiate with management through collective bargaining); (c) Overtime; (d) Employer provided accommodation (with sufficient description of who is entitled and all conditions that apply); (e) Grievance mechanism for all employees including contract workers which regularly documents all issues (grievances or concerns) workers have and how these are being resolved etc. in line with IFC’s Performance Standard 2 including other corrective actions, if any identified through third party labor audit (as set forth in ESAP 3). While the company does not hire anybody below the age of 18 years; however, the company will formalize this as part of the HR Manual update (ESAP 4).
Freedom of Association:
The company does not discourage formation of union or prohibits workers from joining any union. Indian national laws allow formation and registration of trade unions. CHL does not restrict freedom of association or formation of unions. Currently there are unions at three hotels; while collective bargaining agreement (CBA)/ wage agreement is already in place at two hotels, the company is engaging with the recently recognized union at third operational asset in Mumbai for terms of wage agreement. The CBA/wage agreement is agreed between CHL (as owner of the respective assets) and the union. The recognized union is the sole bargaining agent for the workers at both these hotels. These unions are registered as per the Maharashtra recognition of trade union & prevention of unfair trade practices Act which provides that though multiple unions can exist, there can be only one recognized union at a given time in any establishment. The workers category employees (irrespective of their membership) are eligible for representation by the recognized union at both the hotels (including the third hotel where the CBA is yet to be signed). While the operating assets engage in discussion on finalizing the wage agreement, CHL maintains an oversight in terms of regular updates from the operating assets. These agreements apart from the provisions made under law, have extra provisions for the workers based on the merit and longevity in the organization including other benefits such as compensatory off, conveyance allowance.
Grievance Mechanism:
The company has a whistle blower policy at corporate level as part corporate HR policies. However, at the operating asset level the employees have access to grievance redressal mechanisms of Marriott and Accor (the GRM is operational with different names such as Marriott’s Guarantee of Fair Treatment, Accor’s Integrity Line, Whistle Blower policy, etc.). As per the procedure, all employees are expected to first direct their grievances either to their supervisor, a person assigned to each department or HR department. The employees also have access to the process of routing their concerns directly through the established portal or reporting anonymously through Global helpline of these reputed Brands. Effectively, all hotels maintain own grievance mechanisms based on each brand policy and procedures. Summary of total number of grievances, the content of the grievances, resolution etc. are reported on a quarterly basis to CHL. Though the system of redressing grievances already exists in different form, these will be updated to meet the IFC PS2 requirements. As set forth in ESAP 4, the CHL will update the HR manual to provide a framework for GRM to be followed at all the operating assets (even if known by different names) including provision for anonymous grievances. CHL will ensure that the grievance systems at all CHL locations are available to direct employees as well as contract workers. Chalet will ensure that the updated GRM is disclosed, and provisions communicated to both the employees and contract workforce. The company will ensure that the GRM regularly documents all workers issues (grievances or concerns) and the resolution in a time bound manner.
Accommodation:
Across the CHL group, around 140 employees (only female staffs) are provided accommodation facilities in the nearby housing society apartments on sharing basis for outstation non- management and junior management level associates primarily to attract and retain talent, in case they find it challenging to get accommodation. Most of the hotel units have started temporary practice of providing accommodation in the hotel due to COVID-19 lockdowns (which restricted movement of employees and difficult for them to reach their workplace). Marriott has local standard operating Procedure (SOP) for providing such accommodation facilities including checklist for monitoring of such accommodation facilities. The CHL will develop guideline/ SOP related to employer provided accommodation (such as room and board) facility as part of HR manual update as set forth in ESAP 4. The written policy/SOP for employer provided accommodation will have sufficient description of who is entitled and all conditions that apply. The Policy /SOP will also include statement as part of the COVID policy the temporary accommodation arrangements at the hotel is a voluntary program in response to the current situation of lockdowns. The workers have the freedom to choose whether to avail of this option or not without any concern of losing their job.
Retrenchment:
CHL has been impacted by COVID-19 leading to positions becoming redundant at operating Assets (especially hotels) resulting in around 80 employees being laid off by the company. The company had to let go off staff at redundant positions including salary reduction of up to 10-25% during COVID-19, which also resulted in additional employees leaving the company. Marriott & Accor as operators provided adequate support through informal means, including providing opportunity for joining back at a later stage in the same asset or a different asset. As set forth in ESAP 4, Chalet will include retrenchment policy in line with IFC’s PS2 as part of the HR manual update and will make it applicable across all the operating assets of Chalet.
Occupational, Health and Safety (OHS):
CHL assets (as per the Brand’s procedure) conduct enterprise risk assessment, hazard identification and risk assessment on occupational health and safety identifying specific safety risks in their operations. The procedures cover fire safety, emergency response for various types of emergencies, safety during construction/renovation etc. The operational report for the project also includes H&S related information.
Regular training programs and all induction trainings are conducted on various safety related topics. Employees and third-party workers undergo health check-up at pre-employment stage. Food handlers go through a health check up every 6 months. OHS statistics (fatalities, incidents records) are monitored at least monthly by Loss & Prevention management department at the asset level and no major injuries informed so far in the past years. While the construction site OHS details are reported to the CHL corporate Project team, the OHS statistics for operation need further streamlining. Statistical performance on occupational health and safety is currently not included in either internal or external reporting. OHS KPIs are important for the effectiveness of OHS management system. As part of the ESAP 1, the company will consider relevant lagging and leading indicators for effective OHS performance management.
The CHL as well as the operators have implemented several COVID-19 response measures for their its operations including: social distancing, ensuring employee and visitors health, cleaning and disinfecting which is in line with governmental requirements as well as the Brand’s procedure.
Construction Safety and Management:
The project (construction) team is common across the K Raheja Group including Chalet. The Project team has EHS manual for the construction stage. Usually, the Engineering and procurement are handled directly by the Head Office; however, CHL typically hires a construction contractor when developing new assets in greenfield site or renovating existing buildings. The contractors are usually L&T or other bigger firms and they usually have their own EHS manual which is reviewed by the Projects team and ensured that the EHS manual is implemented. CHL oversees the projects through the Project team and corporate Project management and technical support departments monitor and report on safety performance and legal compliance including COVID-19 response measures.
From the Project team, one safety officer is either present at the site or manages from corporate depending upon the scale of the construction activity. CHL also requires the construction contractor to have its own safety officer on-site. Safety guidelines for the projects have been documented and cover key areas of EHS at construction sites. During any construction or refurbishment activity at operation assets, the EHS practices of operator companies are followed. The payments and benefits to the workers are managed by the construction contractor and reviewed by the company’s corporate HR and Procurement Management departments.
Workers engaged by third parties:
Apart from the construction workers, third-party contract workers are employed at the hotels for multiple services. The small number of contract workers is due to temporary closure of hotels due to the pandemic and in some cases contracts of these workers are temporarily discontinued, but the company expects to reemploy these workers, when hotels are reopened.
The assets review compliance of the contractors with respect to labor laws for their workers internally through monthly compliance audits. Corrective actions in line with PS 2 requirements, if any identified through third-party labor audit, will be included in an updated ESAP. As part of the ESAP 8, CHL will develop a contractor management system including (but not limited to): identify all compliance requirements under the national labor and employment laws and PS2 covering its employees and sub contractors’ workers including on terms of employment, minimum age, non-discrimination and equal opportunity, freedom of association, worker accommodation and occupational health and safety; grievance mechanism; etc. and implement procedures to demonstrate compliance with the national laws, PS 2 and CHL’s labor standards.
