Working Conditions and Management of Worker Relationship PPC is hiring a third-party engineering, procurement, and construction (EPC) contractor to build the cement plant, and the company itself plans to hire a direct workforce of approximately 275 employees for the operational phase of the project. Additional third-party contractors are likely to be used during operations for transport and logistics, security, and possibly catering, housekeeping, and similar functions. At the peak of the construction period, the project will require a temporary work force of between 1,000 and 1,200 skilled workers with the qualifications and experience to perform the various phases of project construction. Close to all of the skilled construction workforce will be sourced internationally while some unskilled functions will be carried out by local day laborers under the supervision of the EPC contractor. A temporary workers? camp will be built for housing the international workforce hired by the EPC. Unskilled day laborers will be drawn from the nearby villages in a way to maximize the opportunities for income to be earned by members of the local communities. PPC will require that the EPC contractor abide by its corporate policies and practices, based on South African standards, for working conditions and occupational health and safety (OHS). PPC is including in an amendment to the EPC contract requirements that the contractor also abide by the requirements of IFC?s Performance Standard 2 as well as the IFC and European Bank for Reconstruction and Development Bank?s Guidance Note on ?Workers? Accommodation: Processes and Standards.? PPC will apply a similar approach, system, and procedures for oversight, monitoring, and documentation of contractor performance as it uses in South Africa. In addition, the ESAP requires that PPC conduct a third-party labor and OHS audit of the EPC contractor?s practices ca. 6 months after the start of civil works to ensure that the EPC contractor?s labor practices are in conformity with the IFC?s Performance Standard 2 and identify any gaps that PPC would need to address. During the operational phase, PPC will apply its corporate guidelines, procedures, and monitoring systems at the country level in the DRC. Where PPC?s own corporate practices exceed DRC legal requirements, they will be maintained. These include a comprehensive approach to recruiting, training, developing, and managing its workforce at all levels, including workers? rights to form organizations for purposes of collective bargaining. It is PPC?s principle to respect worker rights, and it maintains constructive relations with unions at its sites. Through its Kambuku human resources management system, PPC promotes open and candid dialogue with its workforce at all levels. In addition, it has in place worker grievance mechanisms for its South African and other African operations, including an anonymous grievance reporting channel managed by an independent, external party. Furthermore, the IFC reviewed standard employment contracts for operator-level workers at PPC?s South African operations. In addition to clear working conditions and terms of employment, it included provisions on occupational health and safety, the company?s code of ethics, and access to grievance procedures. A separate corporate policy defines PPC?s approach to respecting the rights for workers to organize, form unions, and engage in collective bargaining with management. The standard South African contracts will serve as the basis for PPC?s worker contracts in the DRC, adjusted appropriately for any relevant DRC legal requirements. Provisions of the DRC constitution and/or the 2002 labor code guarantee freedom of peaceful assembly, freedom of association, and the right to form and join trade unions without prior authorization or excessive requirements, as well as to carry out strikes once a union and employer have adhered to lengthy mandatory arbitration and appeal procedures. The law also stipulates different lengths for standard work weeks for different jobs. It requires rest periods and premium pay for overtime, but it does not prohibit compulsory overtime. PPC labor standards, policies, and procedures for the DRC will be based on the company?s corporate practices while ensuring compliance with DRC law. PPC has stated its intention to engage with unions that are registered with the Ministry of Labor and Social Welfare under the DRC labor code, and it intends to recruit its permanent workforce on basis of non-discrimination and equal opportunity, including for women. Under an action item in the ESAP, PPC is required to conduct a third-party audit of labor practices, including those related to OHS, for its principal providers of contracted/subcontracted services within one year of the start of full operations to ensure conformity with the IFC?s Performance Standard 2 and to identify any gaps that PPC would need to address. PPC is committed to the ongoing contribution of its operations to local economic development, education, and workforce development, and it plans to maximize the hiring of local labor for the operations phase over time. In keeping with its strong commitment to maximizing the participation of its national workforce in operations elsewhere in Africa, PPC?s intention is to have no more than 15% of its workforce to be international personnel by the third year after the start of full operations, and it will endeavor to maximize the training, recruitment, and employment of qualified workers and personnel from communities as close to the operation as possible. As it has done in South Africa and elsewhere in Africa, PPC plans to invest heavily in local workforce development through its in-house adult basic education and training (ABET) program, its Technical Skills Academy, Operations Academy, Mining Academy, and similar training programs. PPC will report on the achievement of international workforce reduction in its annual reports to IFC. Protecting the Workforce As a matter of company policy, PPC does not employ persons under the age of 18, and it has policies, systems, and procedures in place to guard against employing under-aged workers or forced labor in South Africa and its operations elsewhere. Similar policies, systems, and procedures will be developed and implemented for its DRC operation. Occupational Health and Safety PPC has extensive policies, systems, and procedures in place in South Africa and its operations elsewhere to ensure that its workers enjoy a safe and healthy work environment, taking into account inherent risks in the cement sector. These policies, systems, and procedures apply for its own workforce as well as those of its contractors and subcontractors, which are required as part of any contract with PPC and operational oversight by the company to safeguard, monitor, and report on breaches in occupational health and safety (OHS) measures to PPC, particularly for hazardous work. For both in-house and contracted work that is hazardous, PPC has measures in place to ensure that such activities are risk-rated, carried out by properly trained personnel using appropriate equipment, documented, and supervised appropriately. PPC?s OHS practices are based on South African legislation on OHS and the Mine Health and Safety Act, and its South African operations are certified against ISO 9001 and 14001. In 2011-12 PPC recorded no fatalities at its operations, and its Lost Day Accident per Million Man Hour (LDA/MMH) frequency decreased from 1.7 in 2011 to 1.15 in 2012. PPC saw one fatality and an LDA/MMH of 1.4 in 2013. Workers Engaged by Third Parties PPC has an extensive system in place for its South African and other African operations with regard to the OHS performance of contractors and subcontractors. As noted above, PPC is requiring its principal third-party contractor in the DRC ? a foreign EPC contractor hired for the construction phase ? to apply both PPC?s corporate measures and Performance Standard 2 requirements with regard to that contractor?s labor and OHS practices. With respect to contractors and subcontractors in both the construction and operations phases, PPC will ensure that any third-party contractor has its own worker grievance mechanism in place for contracted and subcontracted workers, or that PPC will extend its own grievance mechanism to serve workers engaged by the third party. As noted above, PPC will both audit the EPC contractor?s performance on labor standards ca. 6 months after the start of civil works (action item in the ESAP), and PPC will commission a similar audit in the first year of full operations to ensure all other DRC contractors and subcontractors, particularly for transport, logistics, and guard services, are applying PPC?s corporate policy and procedures in light of IFC Performance Standard 2 during the operational phase. Supply Chain PPC?s primary suppliers are not considered to be at high risk of engaging child or forced labor. With regard to occupational safety and health measures for PPC?s contractors and subcontractors engaged in potentially hazardous activities, PPC has stringent policies, contractual requirements, systems, and procedures in place in South Africa and elsewhere to ensure that those third-party companies adhere to PPC?s OHS requirements with the same level of rigor as PPC does.