Workforce. The Salto Plant workforce comprises approximately 350 direct workers (91% male and 9% female). The Company has a program to train and retain people with disabilities that exceeds the mandatory quota of 5% from Ministry of Labor in Brazil. The Salto Plant has approximately 400 third party contracted workers (88% male and 12% female) providing the following services: internal truck transport, emergency responders, canteen, cleaning, maintenance, security and blasting. During the construction period of the Project, on average, there will be 308 construction workers on site. In the plant operation phase after the retrofit, there will be approximately 10 additional direct workers positions and approximately 65 for third-party contractors.
Human Resources (HR) Policy and Procedures. Through its human resources (HR) policies and practices, which are clearly articulated and readily available to its employees, the Company adheres to all Brazilian legal labor requirements regarding working conditions. Policies include workers’ rights and obligations, remuneration, working hours, disciplinary actions, career development, internal and external communications, including workers’ grievances, training, and education, etc. Review of the HR policies and procedures demonstrated alignment with the IFC PS2 requirements.
Working Conditions and Terms of Employment. The work contract in Brazil covers aspects, such as working period, rest period, overtime, annual, sick and maternity leave which are defined by law and under collective bargaining agreements (CBAs) with worker’s unions. VC reported paying all employer social security taxes and legally mandated benefits, as required. The standard working period is 44 hours per week (including 4 hours on Saturday) and the daily working period cannot exceed 10 hours (2 hours overtime included). The Company has a renumeration policy and pays the regional middle target in accordance with the function. Annually a survey is completed to check whether the compensation is competitive. The VC workforce does not include migrant workers as employees and contractors are hired locally.
Worker’s Organization. Labor rights in Brazil are enshrined in the constitution and the consolidated labor laws (known as Consolidação das Leis do Trabalho, or CLT, in Portuguese), and labor relations are highly regulated under the country's laws and labor practices, including the requirement for most categories of workers to belong to a union. In VC’s case, the workforce can belong to different unios depending on the nature of the job. Annually, VC negotiates CBAs with these unions to define the annual salaries and other works conditions. There are union representatives working in the cement plant and quarries, and they organize internal workers’ committees to participate in the collective bargaining process.
Non-discrimination & equal opportunity. Forced and child labor, harassment and discrimination are treated as crimes under Brazilian law. Forced and child labor are included the VC Code of Conduct, which addresses its commitment to the United Nations Universal Declaration of Human Rights and the UN Global Compact and has among its principles to eliminate all forms of forced or compulsory labor and eradicate all forms of child labor from VC’s production chain. These practices are prohibited in all Company and supplier operations.
Equal opportunity is an important part of the Company's “Our VC Way” cultural program developed in 2021. The program has diversity as one of its pillars, with the aim to actively promote diversity and inclusion (D&I) in the VC network and sphere of influence. This is supported, among others, with a leadership development program for women, D&I trainings for all leaders in VC, mentorship for black women, training program for women drivers and a development program for people with a disability. Both the hiring process and the approach to promotion follow well established policies and procedures and are based on merit and competencies; no evidence of discrimination was found during appraisal. Worker/Contractor Grievance Mechanism. VC established grievance mechanism for workers and related conflict resolution which can be reported via the independent Ethics Line, which is also available for employees and third-party contractors. The Company reported that the last internal grievance received on sexual misconducts at Salto Plant was in 2019.
Protecting the workforce. The Company follows Brazil's legislation regarding minimum age required for employment (18 years old.) The Company checks the worker's age at time of application, recruitment, and contracting. The Company does engage trainees of 16-17 years of age under the Brazilian government's Jovem Aprendiz training program, but it follows all requirements of the program, including limited work hours to allow for participants' schooling and prohibitions against exposing trainees to any forms of hazardous labor.
Workers engaged by third parties. The following services are provided by third-party contractors: internal truck transport, emergency responders, canteen, cleaning, maintenance, security, and blasting ate the quarry sites. As described in other sections, the third-party contractors’ firms are screened for labor, social, OHS and environmental compliance, providing sufficient EHS training to its workers, which is monitored by VC. There will be no EPC contractor for the Project, the engineering will be managed by the VC Project team. Contractors have not yet been selected for the Project will be hired locally when it’s possible. They will be selected through technical and commercial competition also following the Contractor Handbook. VC will maintain the EHS management plans during the Project construction phase in accordance with the national legal requirements and internal contractor EHS standard operating procedures, which align with the World Bank Group (WBG) EHS General Guidelines. As set forth in ESAP#2, the Company will develop a Traffic Management Plan for the construction phase and inform its neighbours and nearby communities presenting the Project and the Traffic Management Plan. During these meetings VC will also inform these stakeholders on the grievance mechanism and communication channels in case they have any concerns.
Supply Chain. Forced and child labor is not tolerated by the Company and is checked for during the screening and appraisal processes of suppliers and third-party contractors following the Supplier Appraisal and Approval Procedures. The national public child and forced labor list is consulted and periodically checked. If the supplier is listed for forced and/or child labor, VC will not approve or disengage itself from this supplier.
Occupational Health and Safety. As described in the PS1 section, the Company annually completes OHS risk assessments and develops a Risk Prevention Plan (PPRA). The Company has OHS programs as per the Brazilian Legislation (Portaria 3214/78), defined by the Regulatory Norms (NR) of the Ministry of Labor NR 07 and NR 09. NR compliance is annually reviewed, and the Salto Plant is currently in compliance. For routine tasks, such as work at heights, hot work, excavations, demolitions, drilling, lifting of loads, working with chemicals and electricity, before starting, a preliminary risk analysis (APR) is performed. For non-routine work in confined environments, a risk assessment, monitoring and control of the existing risk is performed and assigned employees receive compulsorily. A Permit-to-Work system is in place to cover the high risks tasks performed at Salto Plant and also applies to contractors. The Company complies with NR 06, which prescribes provision of Individual Personal Protection Equipment (PPE) only approved by the Ministry of Labor.
The industrial processes are mostly automated, which results in a limited number of workers being inside the operational area thereby reducing the exposure of workers to inherent risks typically found cement production. The Company’s 2022 workers loss time injury frequency rate (LTIFR) is 1.22 accidents per million hours worked compared to 1.31 in 2021, which is considered good and below international reference values (i.e. 1.8 for cement manufacturing). Average severity rates (lost days/injury were respectively, 29 (2022), and 67 (2021). In 2021, there were three incidents involving vehicles. No fatalities occurred in recent years. The Company has introduced several programs (e.g SafeStart, drivers’ safety and Behavioural Observations) to increase safety awareness among employees, as well an effective OHS training program that has resulted in these low LTIFRs.
The Company conducts mandatory pre-hiring, periodic and termination health assessments when contracts are terminated of all employees that include basic clinical assessment and additional tests depending on an individual’s job function and exposure to identified risks. VC monitors worker’s exposure to hazards in the workplace under its mandatory workplace risk prevention program (PPRA) and has conducted a formal hazard/risk assessment of its operations.
Gender and Gender Based Violence (GBV). In completing the IFC’s Gender Based Violence project assessment tool, no high risks were identified based on the Company’s processes in place, i.e. Code of Conduct and internal grievance mechanism. The Company keeps track of grievances related to sexual harassment, no cases have been reported for the Salto Plant for both direct and contracted workers.
