Working Conditions and Management of Worker Relationship:

CSAIL?s business activities are currently supported by managers and engineers from CWEI. CSAIL has offices in Karachi and Islamabad currently each staffed by 5-6 CWEI employees designated to manage project related activities on a day-to-day basis. The Karachi office is responsible for managing activities undertaken for the preparation and development of wind/solar projects, including overseeing EPC construction contractors for the construction of its first wind project and preparation work for the two additional projects in the pipeline. The Islamabad office is responsible for hydro project development, currently at exploration and surveying stage. CSAIL will be relying on seconded CWEI staff members to staff its Pakistan offices for the foreseeable future. The number of CWEI staff in CSAIL offices is expected to increase to keep pace with their development program. CWEI and CSAIL will continue to rely on EPC contractors for construction and therefore will retain a relatively small number of staff in Pakistan. CSAIL?s human resources management and practice follow CWEI?s policy and practices, which are applied internationally, including in Pakistan. Moving forward, CSAIL will ensure its labor policy and practices are in compliance with IFC?s PS2 Labor and Working Condition (ESAP Action No. 4).

CWEI currently employs 120 China-based staff working globally. Its Human Resources policy, procedures and terms of employment for both CWEI?s employees and EPC contractors follow national labor laws include regulations of working hours, overtime payments, national holidays, annual leave, maternity leave, medical leave, pension, and other benefits and compensation policies. Individual employment contracts are signed at the time of employment and may be either open-end or fixed-term, depending on the nature of the assignment and the skill level of the employee. Individual ID cards are used for age screening both for CWEI own employees and non-employee workers. Certain CWEI staff are hired though reputable labor agents who are known to comply strictly with Chinese laws and regulations. 

CWEI employees working on overseas projects are all covered under a standard rotation program of six months in project country and two weeks paid leave. To meet its growing business needs and heavy reliance on EPC contractors, CWEI/CSAIL will develop a supplemental policy and procedures with respect to staff rotation in compliance with international good practices. 

Workers unions in Pakistan are recognized by national labor law. Pakistan workers have viable options if they decide to form or join a workers union. CSAIL does not restrict employees? freedom of association. Grievance channels are built into CSAIL?s existing management practices, which are replicated from CWEI; issues can be escalated to higher levels within the organization as and when needed.  As a part of CSAIL?s corporate level ESMS, a worker/contractor grievance mechanism will be established at corporate and project levels to allow free flow of grievances from contracted workers and staff to the relevant line managers for a mutually acceptable resolution. CSAIL?s contractors will be held responsible for the fair and appropriate handling of employee grievances and this will be subject to monitoring by CSAIL.

TGF is the only CSAIL project currently under construction in Pakistan with a total of 660 staff on site, inclusive of CWEI and its EPC contractor and subcontractors. The workforce are 75% (500 staff) Pakistanis and 25% (160) Chinese, the latter mainly civil engineers. Meanwhile, a Pakistan senior advisor to the CEO and eleven Pakistani core technical staff have been hired as TGF employees for the construction and operation phases. A two-month technical training was attended by all eleven engineers; the training program including technical training courses in academies and visits to large wind projects in China. 

The most advanced hydro project is Karot, the EPC contract for which is due to be tendered in October 2014 and construction to be commenced in February 2015. The construction contractors? workforce is expected to be predominantly male with a total number of contracted workers ranging from approximately 2,000 to 3,000 at any one time, including indirect workers hired through contractors to perform construction tasks.

CSAIL will work closely with their EPC contractors to promote local access to project employment in both the construction and operational phases of the project.  Top priority in hiring will be given to those members of local communities affected by the project development. Early indications suggest that the necessary technical skills required for the project construction program may be scarce in the communities closest to the project site.  However, it is expected that the majority of its construction workforce will be made up of Pakistan nationals with a target of 30% of these individuals to be sourced from the local area.  During operations the workforce will be made up of greater than 70% Pakistan nationals. CSAIL will work with local NGOs to develop training needs and vocational training programs for the local community that will assist the EPC contractor in achieving the community employment targets. 

Contractor Workers and Workers Accommodation Camps:
  
CSAIL?s current arrangement holds the EPC contractor independently responsible for ensuring their labor practices are in line with national requirements. As a large number of construction workers working for multiple contractors and sub-contractors are expected, a centralized evaluation system therefore will be in place at CSAIL to monitor that labor laws are being followed by all project contractors and sub-contractors.

The most advanced TGF project has developed a workers accommodation camp site with concrete structured offices and workers accommodations that are very well managed, with sufficient space for individuals and adequate access to water and sanitation. A mosque was built for workers. TGF has also rented out rooms to contractors and subcontractors at reasonable rates. However, the number of worker accommodations the project will be able to provide will not meet the demand from construction teams. As a part of CWEI?s overall process to ensuring CSAIL is in compliance with IFC?s Performance Standard 2, CSAIL will establish an overarching accommodation standard in line with international standards and create a project level monitoring mechanism to ensure that all workers requiring accommodation are housed in camps that meet these standards. Workers camps will be monitored regularly and any deficiencies raised to CWEI/CSAIL management.

Protecting the Workforce (Child Labor, Forced Labor):

The minimum age for construction work under international standards and Pakistan and China labor laws is 18 years. Individual ID card are used for age screening both for CWEI/CSAIL employees and non-employee workers, CSAIL does not use child or forced labor. Contractors are required to strictly follow the national labor law and hire only employees older than 18 year of age for construction works. Moving forward, CSAIL will extend the minimum age requirement to all workers working for CSAIL?s projects including its main service providers.

Occupational Health and Safety:

CTGC strives to achieve objectives of ?Four Zero?, namely, ?zero quality accidents?, ?zero safety accidents?, ?zero environmental accidents? and ?zero unplanned outage of the unit?.  CTGC?s Quality & Safety Department is in charge of operating the safety management system, and provides trainings on safety management and conducts regular health and safety audits at CTGC?s and its subsidiaries? construction and operation sites.  CSAIL?s first project site under construction (Three Gorges First Wind Farm Project, or ?TGF?) was audited in 2013, and its health and safety performance was evaluated as satisfactory against CTGC?s management standards.  CSAIL will incorporate internationally recognized health and safety guidelines from IFC Performance Standards and IFC/WBG Environmental, Health and Safety Guidelines for their management standards in Pakistan.  As of December 2013, TGF had achieved a zero lost-time injuries record.  TGF has both a safety management system and a security management system in place.  Safety inspections are conducted on a daily basis, and relevant OHS trainings are provided to workers.  At the construction site, there are two safety engineers (TGF and CSAIL).  CSAIL will establish a detailed Occupational Health and Safety procedures manual that outlines all requirements to ensure compliance with its own standard practices, IFC Performance Standard 2 and IFC/World Bank Group Environmental, Health and Safety Guidelines (ESAP Action No. 4). This manual will be made available in Chinese, Urdu and English to all contractors, subcontractors and individual workers.