The different categories of workers that are engaged in the company’s operations include a) permanent employees, b) workers (including up to 8000-10,000 seasonal workers engaged for bamboo harvesting and daily wage workers in Ballarpur, India) and c) contract employees (mostly managed through various contractors/sub- contractors). The total number of staff and direct workers including contract workers directly employed by BILT are 13,577 (including contract workers that are engaged in different activities across permanent and contract employees). 

The company has a documented (in English and relevant excerpts in local languages) Human Resource Manual, which lays down policies and procedures for its employee (covering amongst other aspects employment condition and working hours; leave; recruitment, compensation; rewards and recognition, benefits and employee welfare, performance management, separation, protection and safeguards aspects relating to gratuity, pension, insurance, travel allowance). Apart from this, the company has an Employee Code of Conduct which outlines standards of personal and professional conduct for all employees and also covers non-discrimination. At each plant level, procedures are in place to support the implementation of corporate policies. These procedures among other aspects include procedures related to grievance handling/management, sexual harassment and training. While staffs are covered under the HR Policies and Code of Conduct, workers (not including seasonal and casual/daily workers) are governed by a “Worker’s Agreement” agreed as part of the collective bargaining process. Each of BILT’s plants in India has workers unions that lead the collective bargaining process. In addition to the unions, each of the company’s plants has one or more of feedback procedure or open door policy as a grievance mechanism. The contract workers are managed through contractors/sub-contractors and the company either directly handles or closely monitors legal compliance (muster- roll, attendance, wage, overtime, wage slips, identity card and leaves). Casual/daily/seasonal workers directly employed by the company are employed/engaged on a daily wage/unit rate basis on mutually agreed terms and an appropriate payment frequency (monthly). 

The Human Resource (HR) policies and procedures are communicated to the employee/workers at the time of appointment (through written and agreed employment contracts), during induction training and are also available on the company’s intranet. Relevant provisions or references to HR policies and terms of employment are included in the appointment letters or employment contract. Minimum wages, working hours and other key information for differing worker categories are displayed at the factory gate and at other relevant locations within the factory premises. The company has procedures (like verification of age through identity cards) in place to prevent child labor in its operations and sets 18 years as the minimum employable age (also a statutory requirement).

BILT has a corporate HR team supported by HR implementation teams at each unit/plant covering functions like training, organization development, payroll management, recruitment, industrial relations, compliance and contractor management. While BILT has in place procedures to comply with labor law requirements, the company needs: to upgrade working and living conditions for 8000-10,000 migrant seasonal employees/workers that the company engages at its Ballarpur plant every year for bamboo harvesting; and also upgrade management of contractors to meet PS2 provisions. Thus the company will, to meet PS 2 requirements undertake the following (refer ESAP); a) develop and implement a formal contractor oversight procedure to ensure ongoing legal compliance, b) define and implement worker accommodation requirements that align with IFC’s requirements; c) improve the grievance management system (to include a formal grievance committee, collection of anonymous complaints, time bound closure of concerns/complaints, feedback to aggrieved workers/employees, documentation, analysis and reporting to senior management) including procedures enabling contract workers access to the grievance mechanism; and d) managing risks and concerns associated with supply chain (especially with respect to child and forced labour and occupational health and safety (OHS). Further, if the bamboo harvesting lease for BILT’s Ballarpur plant is renewed post September 2014, for migrant seasonal workers, who are employed by BILT in bamboo harvesting for 3-5 months, the company will: a) implement measures to improve the OHS conditions and prevent/protect against occupation risks/hazards (like snake bites/animal attack, injury), b) provide appropriate living conditions with appropriate accommodation space,  use of appropriate construction material, including access to basic amenities and facilities like electricity, fan/light, sanitation, drinking water, cooking arrangements, medical facilities, separate facilities for women, pest and garbage management; c) ensure payment of equal and minimum wages to men and women employed in the harvesting activity and d) provide protection and safeguard benefits including insurance benefits to these workers. 

The company manages occupational health and safety through its OHSAS 18001 certified management system that includes: OHS Policy; OHS objectives; roles and responsibility allocation; safety committee composition and procedures; safety induction, training, tool box talk procedures; accident investigation, reporting and corrective action procedures; work permit system and safe work procedures for various activities that exposes workers and employees to hazardous conditions; periodic internal and third party audit, and management review. BILT provides personal protective equipment (PPE) to all employees and requires contractors’ to provide PPE to their workers. The OHS system includes periodic medical examination program for workers. While use of basic PPE at BILT’s plants is adequate, the company will continue to focus on further improving use of activity specific PPEs, particularly under dangerous working conditions. The company has an active safety training program in place. BILT ensures that doctors or para-medical staff are available or that there is access to emergency medical facilities and ambulance is available at plants together with facilities for administering first aid. The company will further upgrade its safety management through ensuring consistency in application of the OHS system across different plant sites. In particular, the company will undertake a comprehensive third party safety audit of its Sewa plant (refer ESAP action item) and implement corrective actions based on the audit findings. The company will, strengthen accident and incident prevention though use of lead and lag indicators; and use of safety risk mitigation hierarchy in risk evaluation and accident prevention.

SFI employs 2,542 direct workers as of April 2014 including 996 in the pulp & paper mill; 937 in plantation operations; 279 in the integrated timber complex (ITC) and 330 in the support services unit. 739 workers are foreign migrant workers from Indonesia (345) and Nepal (394). 1803 of the total workforce (2542) have permanent employment contract with SFI and the remaining are mostly foreign workers engaged on a 2-3 year contract basis. 337 workers across all grades are women. Of these, 79 are foreign workers from Indonesia engaged in ITC operations.  SFI has implemented screening procedures to prevent child labor in its direct operations and the same need to be replicated for contract workmen.

1218 contract workers, spread across 27 small to medium contractors/contracting companies are engaged in the operations across pulp and paper, plantation, logistics, waste disposal, material loading, harvesting, plantation, jetty operations, wood yard and about half of these workers are also foreign workers from Indonesia.

SFI’s Human Resource policies and procedures are defined in a manual which covers general terms and conditions of service (amongst other aspects it covers employment terms, allowances and claims, benefits, working hours; leave, employee conduct and disciplinary regulations). In addition, there are also defined policies and procedures (like those for grievance management, security and an induction kit for foreign workers). The grievance mechanism, needs to be upgraded to include a) removing restrictions on the scope of grievances that can be raised, b) including provisions to file grievances anonymously or confidentially or to a grievance committee; c) provisions for confidentiality protection and non-retribution and d) documentation of grievance redress process, analysis of grievances received and redressed and reporting to senior management on grievances received. SFI will ensure that the grievance redress process is available to all categories of workers, including foreign workers.  

The HR operations at SFI is headed by a general manager and supported by personnel in- charge of recruitment/staffing, compensation/benefits, Industrial and employee relations and talent development. While SFI has documented policies/provisions to ensure compliance to statutory requirements, for full compliance it is committed to: pay the pending arrears for revised minimum wages from January 2013 (for workers who have to be paid retrospectively to comply with the revised minimum wage directive of the government); and check overtime eligibility and payment status at to ensure this meets statutory requirements.  In hiring foreign workers, though SFI uses government approved local agents (particularly in Indonesia), its personnel travel to Nepal and Indonesia to oversee the recruitment process (meet workers and communicate to them the employment terms, nature of work, living and working conditions). SFI needs to further strengthen procedures to prevent agents/sub-agents charging additional amounts to facilitate employment in SFI. It will also upgrade its foreign worker related practices to meet PS2 provisions particularly those relating to: equitable employment terms and working conditions for foreign workers as compared to local workers; ensuring a consent process is followed before holding passports (including for foreign workers employed by contractors); and avoiding practices that restrict free movements. Further, SFI will put in place appropriate procedures to ensure that labor including foreign labor engaged through contractors are; a) paid the minimum wage, b) not exposed to restrictive practices like holding passports and there are no restrictions on free movement;, c) have access to an effective grievance mechanism; (d) ensure OHS policies of SFI are applicable to contractors as well; and (e) contractors are periodically audited for compliance with relevant provisions of PS2 including those related to OHS.

There is an ongoing litigation since 1998 in relation to formation of a union at SFI, which remains a key concern of the workers. While in the interim a joint consultative committee has been set up, SFI has committed to not opposing formation of a union and will undertake steps to facilitate union formation.

SFI commissioned an independent audit of its labor working conditions and has developed an action plan including measures to: a) update/strengthen the HR policies and procedures so they align with PS 2 requirements, b) ensure proper communication and disclosure of HR policies (in a language and format understandable to all workers), c) ensure payment of minimum wages (including retrospective payments), d) manage and ensure compliance to overtime norms, e) ensure equitable employment terms for local as well as migrant workers (in accordance with local law), f) adopt zero tolerance on restrictive practices akin to forced and bonded labour, g) develop and implement a contractor management system including robust oversight systems and processes for management of contract workers; (h) strengthen the grievance mechanism;  and h) conduct periodic internal as well as external audit to assess compliance with statutory and PS 2 requirements and progress on the implementation of the action plan. 

SFI’s has implemented two Occupational Health & Safety (OHS) management system namely OSHAS 18001:2007 and MS 1722: 2011.  The OHS team currently comprises of ten personnel and OHS processes include tool box talks, work permit system, safety induction, training, incident and accident monitoring, investigation, corrective action and reporting. There have been four fatalities since 2011 (2 in pulp and paper and 2 in plantation) and for FY2013 the Lost Time Injury Frequency Rates (LTIFR i.e. LTCs per million person hours worked) are: i) 3.3 in plantations; ii) 5.9 in pulp and paper mill; and iii) 7.0 in ITC. These need to be reduced in case of pulp and paper (2.0) and ITC (5.5 for sawmills) to meet corresponding OSHA benchmarks. SFI has also procedures in place to prevent, detect and control fires both in plant and in the forestry operations. Data indicates that there has been on average one recordable fire incident either in the plant or in the concession every year (since 2011).