M-KOPA’s total workforce in Kenya and Uganda is currently around 1731 fulltime employees in addition to 9000 direct sales representatives (DSRs) who are commissioned sales agents of the company. The Company has a total of 10 staff in senior management (four female and six male staff). The customer care activities are partially outsourced. There are call centre staff operating under an outsourced company providing 425 indirect employees in Kenya and Uganda. There are also around 200 indirect employees involved in providing security, mobility, warehouse and collection services.
Human Resources Policies and Procedures
While each contractor company has its own HR policies, M-KOPA has a Human Resources (HR) policy in the employee handbook that provides detail on recruitment and appointment procedures in accordance with local regulatory requirements of the markets it operates in for its direct employees. The policy articulates working conditions (working hours, probationary period, performance appraisal and disciplinary actions), non-discrimination and equal opportunity, recruitment, promotion, overtime, staff development/training, whistleblowing and employment termination. M-KOPA’s employee handbook includes the code of conduct and working conditions to newly hired staff, which is shared with each employee as part of the induction program. As part of the contractual language for its contractors and suppliers, M-KOPA will include a requirement on alignment of HR policies and procedures with PS 2 requirements (ESAP item 1).
Working Conditions and Terms of Employment
All M-KOPA employees have formal written contracts provided upon recruitment and the terms of service are explained during staff orientation. The contracts describe details such as job title, working conditions, terms of employment and benefits. All indirect employees have access to training and follow-on managerial support of the outsourcing company. Similar to direct employees at M-KOPA, indirect employees also have contracts which includes their rights and responsibilities, the recruitment terms, compensation, benefits, leave, overtime and termination conditions.
Grievance Mechanism
The Company has developed an employee grievance mechanism together with a whistle blowing which applies to all direct and indirect employees and other third-party stakeholders including suppliers. Grievances may be submitted to the line manager or other manager pursuant to the grievance policy or reported anonymously through the M-KOPA whistle blower system. This grievance mechanism will be enhanced by M-KOPA to explicitly mention an anonymous channel for raising grievances, a separate route for addressing Gender-Based Violence (GBV) related grievances and the establishment of a grievances register as well as appointment of competent staff to handle the grievances to provide a timely response. (ESAP item 3).
Non-discrimination and Equal Opportunity
As per the HR policy, M-KOPA is an equal opportunity employer, and the company does not discriminate on the basis of sex, ethnic background or religious and social affiliation. The company will conduct a gender smart safety audit and conduct training on this for employees and managers separately on outcomes as needed (ESAP item 4). The Company has developed a policy on sexual harassment that is a stand-alone document from the employee handbook. To ensure that this policy and related grievance procedure are put into practice, the client will enhance the staff training to put more emphasis on gender-based violence at the workplace under ESAP item 4.
Protecting the Workforce
The minimum age for employment is defined to be 16 years in the local labour law of Kenya and 14 in Uganda. The Company's employment screening requirements for potential employees include verification of birth certificates and national identity cards, which are only issued to persons 16 and over, and the company minimum age for employment is 18. The company will include reference to non-use of forced labour in their recruitment and appointment SOP (ESAP item 5).
Occupational Health and Safety
M-KOPA has an OHS committee that inspects the Kenya and Uganda premises to identify unsafe conditions. The company conducts yearly OHS risk assessments in line with local legislation requirements. These risk assessments are undertaken by the EHS/compliance team and remediation actions directly addressed with support from M-KOPA country management. Based on the OHS risk assessments, various health and safety SOPs and key performance indicators KPIs are in place. These include permit to work procedure for hazardous activities, and a specific lock out tag out procedure for electrical work. M-KOPA educates and encourages the DSRs to ride motorbikes with helmet. Satellite trackers are used to monitor the exact speed the car, used for transportation of the goods, and their location, any signs of dangerous driving (sharp turns and sudden breaking, for example), and fuel consumption during work trips.
In 2021, three lost time incidents were reported. Per the existing ESMS, any incidents including road safety, are expected to be reported and are recorded in the incident reporting system. The company will develop an OHS monitoring program aligned with IFC PSs and WBG EHS Guidelines, with clear frequency, method and reporting lines. It will include an incident recording system to describe the incidents, the root cause(s) and corrective action plan that will be communicated to the relevant department for action (ESAP item 2).
M-KOPA works closely with an external consultant to conduct annual audits to ensure continuous improvement of the OHS management program.
COVID Impact and Measures
In response to COVID 19 pandemic, M-KOPA has developed a COVID 19 protocol to protect its staff and visitors. The measures entail elevated hygiene and disinfection at the workplace, a mechanism to enable contact tracing, frequent cleaning of the premises, and work from home whenever possible. Between 2020 and 2021, M-KOPA’s I-vaccinate initiative in Kenya targeted staff and their dependents and a total of 3000 people were vaccinated, including around 80% of M-KOPA’s Kenya-based staff. In Uganda, a similar initiative was also taken. Workers engaged by Third Parties
The company relies on contractors for its deliver process. Shipping of the products is outsourced to internationally recognized logistics companies.
Third party contractors also include private security providers, licensed waste management contractors and contractors providing mobility services such as vehicles for delivery of products. M-KOPA will formalize the requirement for its contractors and suppliers to follow and use the E&S policy of M-KOPA while working within M-KOPA’s premises or providing services such as product delivery. In alignment with PS 1 and 2 requirements, the contractors will be required to follow the national regulations and applicable PS requirements related to occupational safety, and fire safety in addition to the company’s E&S policy and procedures in general (ESAP item 6).
Supply Chain
M-KOPA reviews its suppliers’ environmental and social sustainability policies, including its commitments that relate to child labor and forced labor as well as OHS provisions and checks whether its suppliers have an E&S policy, anti-sexual harassment policy and grievance mechanism for its employees. M-KOPA will update its existing supplier onboarding system, to include codes of conduct addressing child labor and forced labor issues, use of hazardous substances in electronic and electric equipment and use of conflict minerals and materials (ESAP item 1).
The ESMS will formalize the screening and review process of its third-party suppliers, especially on issues of harmful child labor, forced labor, significant OHS risks. Under the ESMS, the company will (i) map and screen their existing suppliers for PS 2 risks, ii) take remedial actions if child labor or forced labor are discovered within their supply chain, iii) develop a Supplier Code of Conduct, including a checklist for risk screening its third-party supplier and selection consistent with IFC PS2 related supply chain requirements; (iv) provide its suppliers with training on checklist and supplier code; (v) monitor the Supplier Code of Conduct on annual basis as part of the ESMS (ESAP item 1).
