Ege Endustri has documented HR policies and procedures that are generally consistent with the national labor regulations and IFC PS 2 requirements, and disclosed on the company’s website: https://egeendustri.com.tr/wp-content/uploads/2020/04/%C4%B0NSAN-KAYNAKLARI-POL%C4%B0T%C4%B0KASI.pdf
The company has a total of 598 direct employees. Contractor workforce is very limited (22 employees) and assigned to support services such as catering and cleaning. The construction activities for the new plant will take some 18 months and the associated workforce will reach 150-200 employees at the peak. Contractors are required to comply with the company’s HR policy requirements and to require the same from their sub-contractors. Worker accommodation is not anticipated since construction labor is available in the city (Izmir), nonetheless workers’ accommodations requirements will be covered within the EHS requirements from contractor.
Workers at the existing plants are members of Metal-Is Union and covered by the Collective Bargaining Agreement (CBA); the current CBA covers the period 1 September 2021 – 31 August 2023. Pay increase, additional private health insurance, and social allowances are provided by the company as per the CBA. The factories work three shifts with additional compensation provided to employees for the night shift, weekends, and public holidays. Overtime work is organized with the prior consent of the employee, monitored, and compensated in line with national regulations.
All employees including contractors are required to enroll in the mandatory social insurance scheme which prevents the occurrence of any child labor or forced labor. Additional controls are in place at the gate of the FTZ to avoid any underage labor.
The company’s HR policy prohibits any discrimination based on race, religion, gender or ethnicity and commits to act for protection of employees from any form of abuse. The HR policy includes commitment for equal opportunities in hiring and career planning. Currently there is a limited female workforce (4%), though recently the Company has become one of five pilot companies under the program `Equalize opportunities, diversify talents` led by the Automobile Suppliers Association and EBRD. This includes policies and actions to support gender mainstreaming (https://www.taysad.org.tr/tr/haber/firsati-esitle-yetenegi-cesitle).
Worker grievances are received and addressed through direct application to HR, the union or OHS committees. As per ESAP item 2, the company will develop a formal grievance mechanism procedure with anonymous submission channels and appoint a contact person with suitable qualifications to assess sensitive grievances (including harassment, gender-based violence, discrimination etc.). A grievance mechanism meeting PS2 requirements will also be available at the construction site as per the EHS requirements of the construction contract.
The closing down of the existing plants and establishment of the new plant is not expected to result in any retrenchment. It’s expected that any potential redundancies that may result from this merger and technology upgrades will be absorbed by the additional production line to be established at the new plant. As per ESAP item 3, the company will however prepare a transfer/job protection plan to review the workforce needs for the new plant prior to the move and assess alternatives to retrenchment. If retrenchment is unavoidable, the company will develop and implement a retrenchment plan meeting PS2 requirements.
The company works with a variety of suppliers and has in place a supplier rating system that integrates EHS criteria from their existing management systems i.e., ISO 14001 and ISO 45001, and bi-annual audits. The company avoids suppliers from conflict affected regions.
Occupational Health and Safety
Both existing plants operate in accordance with ISO 45001 which includes ongoing risk assessments, accident root cause analysis, corrective and preventive action plans, reporting, and management review. The company has formulated an OHS policy and has developed respective procedures, instructions, and forms based on risk assessments in line with Turkish OHS Law (No: 6331). As a high-risk activity, metal product manufacturing includes welding, working at heights, lifting and hoisting equipment, noise, hazardous chemicals as well as the mechanical moving of massive items. These risks are covered in the company’s current risk assessments. The number of lost time accidents, lost days, and the number of near-miss accidents reported are among KPI parameters and are closely monitored. Ege Endustri aims to minimize any equipment-related incidents by selecting appropriate technology. The forklifts are equipped with speed control mechanisms and all dangerous units are guarded and fenced to avoid any contact, proper PPE (Personnel Protective Equipment) use is enforced, use of explosion proof equipment where necessary, and the existence of life safety ropes at heights were observed on site. Lifting and hoisting equipment with locks are controlled more frequently than local legislation requirements. The Lock Out Tag Out (LOTO) procedure is effectively implemented.
In the last 7 years, there have been no fatal accidents. Lost time injury frequency rates (number of incidents per million work hours, LTIFR) are 41.75, 38. 98, and 50. 50 for the last three years respectively, which is significantly higher than compared to good international industrial practice for the metal industry (9). There is no contractor accident reported. The main reasons for injuries are strikes, traps, falling objects, and cuts. The company will ensure job hazard and behavioral safety analyses are being undertaken for high risk working areas and that risk assessments are updated and preventive actions implemented in a timely manner as per ESAP item 4. Furthermore, to identify areas where improvement is needed to protect workers from injuries and clearly understand the root causes of accidents such that adequate mitigation measures are implemented, the company will commission a comprehensive third-party OHS audit for both plants against IFC requirements and national legislation as per ESAP item 5. Based on the findings the company will also ensure similar mitigation measures are applied at the new plant.
Workplace noise exposure, thermal comfort, heat, chemicals, vibration, dust, and light intensity are measured periodically in line with local legislation. As expected in metal product processing due to a large amount of mechanical equipment and activities, the noise exposure levels are higher than the limits at some locations. Therefore, all employees and visitors are provided with hearing protection devices. Fumes containing metals, metal oxides, organic and inorganic compounds, particulates, dust and VOC’s create inhalation hazards. These parameters are measured periodically against local legislation and international standards (OSHA, NIOSH, ACGIH) by an independent and accredited laboratory, and the latest measurement was conducted on February 4, 2022. All parameters are reported in line with local and OHSA limits, though there are a few parameters slightly higher than the limits of NIOSH and ACGIH, however where such occurs PPE use is strictly followed by the employees. Going forward, the use of air emissions extraction systems, acoustic insulating materials, isolation of noise sources, and other engineering controls will be assessed against that applied in good international industry practice within the sector and the required controls implemented at the new facility to be constructed as per ESAP item 6.
The company has formulated and implemented COVID-19 risk management and precautions protocol in line with local legislation including health checks, temperature checks, regular cleaning and disinfection, etc.
