Martur employs around 4,850 as of 2016 all in its facilities/offices including its subsidiary companies in Turkey, Russia, Romania and Algeria, as well as its design offices in France, Italy, Germany, Russia and Romania.

Third party workers are employed in cleaning, catering, bus transport and some maintenance services. Only in Romania, many of blue-collar workers (403 of 420) are engaged through an employment agency based on short-term contracts. All other employees are engaged through long-term contracts. 
The company expansion is expected to create a 17% increase in Martur’s workforce directly and new jobs at its suppliers.

Human Resources Policies and Procedures: 
Human resources (HR) policy, systems and procedures are centrally designed and applied to all Ustunberk Holding companies and are consistent with local labor laws and IFC PS2. Corporate HR department coordinates with the HR teams at each facility and ensures that necessary adjustments are made to align with the national laws of the country. 

Compliance of facilities with labor laws of respective locations is currently followed through compliance charts in Turkey and this system is expected to expand to other locations of Martur and the subsidiaries as specified under ESAP #6 under PS2. 

All workers engaged by the Company are given employee’s handbook together with the labour contract, which articulates their rights under Turkey, Russia, Romania and Algeria labor regulations respectively, and any applicable labor agreements, including working hours, compensation, benefits, maternity, holiday and disciplinary procedures, ethics code, HR policy, performance management, training, health and safety policy, company presentation and certifications, emergency management and  corporate social responsibility (CSR) policy.

Grievance Mechanism: 
There are different channels for receiving and addressing worker grievances in Martur and subsidiary facilities. Grievances can be received through the worker representatives system which is currently present only in the facilities in Kutahya, Bursa and partially in Romania. A suggestion system is present in all facilities, accessible through SAP (via kiosks for blue-collar workers) or suggestion boxes, which seems mainly focused on quality improvement.

For all the facilities in Turkey, there is an ethics e-mail for reporting violation of business ethics policy by any personnel, provided by Ustunberk Holding. These submissions are handled by the Ethics Committee reporting to the chairman of the board. The employees are informed of this procedure during recruitment however, visibility of the ethics e-mail was not observed in the facilities. 

In cases where none of these channels is prevalent, the general practice is to raise the grievances with supervisors or HR teams. As per ESAP action item #4, Martur shall develop a formalized grievance mechanism including a procedure for receiving and handling grievances, which will be implemented and communicated identically across all its locations, covering both direct and contractor employees. This formal grievance process provides alternatives for employees to raise concerns other than to immediate supervisors and allows grievances to be presented anonymously without the risk of oppression.

Workers Engaged by Third Parties: 
Martur has a contractor management policy and handbook applicable to all its subsidiaries. All contractor workers are required to abide by OHS rules of Martur and show proof of their social security registration as required by their contracts. The records of all contractor workers and the contractor’s regulatory compliance as well as the environmental risk assessment of the contractor company are maintained in the contractor management system. 

For all facilities, catering, transport, cleaning, construction and some maintenance services are contracted. Moreover, as specified in the previous sections, many of blue-collar workers (403 of 420) in Romania are employed through an intermediary agency (IHM Total Consult). Martur management sees this as a transitionary arrangement due to being a new entrant to Romanian market and states that they aim to directly employ the trained workforce in the long run. IHM Total Consult is one of the largest employment agencies operating in Romania, working with several well-known national and multinational clients. As per their contract explaining their duties and rights, the workers are entitled to working hours, wage and annual paid leave rights as rest of Martur workers. 

There are specific hygiene and evaluation procedures for the catering services and the contractors are required to be ISO 22000 HACCP (Hazard Analysis and Critical Control Points) certified. All contractors are annually audited. They are also shadowed by in-house employees in charge of catering and transport.

All contractor employees to work in Martur or subsidiary sites are required to undergo a 2 hours OHS training and additional trainings based on the specific requirements of the site. They have to score 70% marks from the following examination to have access to sites. The managers/owners of contractor companies are also trained once per year. 

Main logistic supplier for Martur and subsidiaries is Rento fleet management, which is another Ustunberk Holding company. A risk analysis report for the fleet services in Bursa is prepared, all transportation employees receive OHS training and guidelines, including each transportation worker’s obligations and responsibilities. There are no major accidents reported.
 
Working Conditions and Terms of Employment: 
The company has established Employee Relation Procedures and has a HR Manual in line with labor laws and IFC PS2 requirements applicable to all operations. Employees either work in a 3 or 2-shift system based on production needs of the section. In the 3-shift system, each employee works in shifts of 7.5 hours with lunch and two short breaks, for 6 days of the week. In 2-shift system, each employee works in shifts of 9 hours for 5 days of the week. During the month of August, production is halted for 2 weeks in all locations and workers are given their annual leaves. Other paid annual leave rights are defined in the employee handbook based on minimum requirements specified in national regulations. 

Blue-collar workers’ wage is calculated based on their hourly work. The hourly rates are determined each year based on several factors: inflation rates, type of work, seniority of employees, union rates for relevant sectors, sectoral benchmarks, and minimum wage in respective countries. 

In line with the overtime procedure, overtime work requests are communicated to workers at least one day in advance and a formal request has to be made through the SAP. Overtime payments are being made in line with country specific regulations. 

Fringe benefits are offered depending on country or location, including bank promotions, food or fuel supply for the family, social gatherings etc. Workers can also benefit from the workplace dietician and the psychologist. Food during working hours is offered either in plant cafeterias or in the form of lunch tickets. Bus transport is also provided. 

Workers’ Organization: 
Martur and subsidiary employees are considered free to become member of the unions, though this is not explicitly articulated in the HR policy of the company. Currently there are no active workers’ unions at any of the Martur or subsidiary facilities in Turkey and abroad. 

Martur implements its own employee representation system. Representatives elected through secret votes for each group of 30 workers, have direct semi-annual meetings with top management. Pay rises and fringe benefits are negotiated in these meetings without constituting a formal collective bargaining agreement, also the company’s overall strategies are shared. Representatives, also work with HR department regularly. The worker representatives system is currently present in Bursa and Kutahya and it is anticipated to be expanded to other locations. A similar system and a formal collective bargaining agreement is in place only for white collar workers in Romania, as it is required for companies employing more than 20 workers. 

As per ESAP action item #5a, Martur shall include a statement in its HR policy and the employee handbook to express recognition and respect of employees’ rights to join a lawful organization of their own choosing and commitment to comply with the laws pertaining to freedom of association and collective bargaining across all its locations, whether there is a representation system or not. 

Non-discrimination and Equal Opportunity: 
Martur has a business ethics policy disclosed on its website, covering all its operations, committing to ensure a fair work environment, being an equal opportunity employer, respecting privacy of employees and confidentiality of their information, and also expressing intolerance for any discrimination based on language, race, sexual and political orientation, belief, religion, sect, age, physical disability and other reasons whatsoever.  

Martur management is committed to raise share of women employees to 35%, which is currently 25%. Seat cover sewing sections in Pitesti (Romania) and Kutahya (Turkey) were observed to be composed almost 100% by women. In both locations, Martur had a positive impact in economic empowerment of women, by training and recruiting housewives to become wage earners. Kindergarten is provided to employees’ kids in Kutahya as required by national regulations in Turkey. Screening of local regulations defining conditions of women’s employment, maternity rights, night work, and specifications regarding establishment and operation of kindergartens and breastfeeding rooms is coordinated by Martur HR department for all Martur and subsidiary operations. 

Retrenchment: 
Martur generally has an increasing number of workforce. However, as the car industry is prone to impacts of economic crisis, only major retrenchment had occurred in following the 2008 global crisis. A case by case approach was adopted towards each worker, providing them retraining, transfer or compensation schemes. As per ESAP action item #5b, Martur shall incorporate into its HR policy/procedures a formal statement regarding its retrenchment policy expressing commitment to prepare a plan when necessary applicable to all its subsidiaries, in line with IFC’s Good Practice Note on Managing Retrenchment and PS2 requirements. 

Protecting the Work Force: 
The Business Ethics Policy and Rules of Martur applicable to all its operations states that `employment of children is strictly prohibited and may not be tolerated`. The HR policy states corporate minimum working age as 18 years old and involves adequate verification mechanisms for workers both in Martur facilities and contractors. 

Only in Algeria where national laws permit hazardous work between 16-18 years old, Martur currently has two out of 99 employees within this range who are only assigned simple legwork in assembly operations and trainees from vocational schools in other locations. As per ESAP action item #6, Martur shall develop a documented HR procedure for its facility in Algeria, for managing adolescent workers; which will include (i) a list of the hazardous operations based on a complete risk assessment, where adolescent workers between 16-18 years old, shall not be allowed to work in line with its corporate HR policy and, (ii) maximum allowable 40 hours of work per week subject to the work being age appropriate, nonhazardous, not jeopardizing their physical, mental or moral health. Martur will also integrate these procedures into its OHS management procedures. 

Martur is not employing any forced labor, in line with its business ethics policy and relevant country regulations. 

Occupational Health and Safety: 
All the facilities of Martur (7 in number) and its subsidiary Fompak (5 facilities) have implemented OHSAS 18001 management system including Martur Romania. Facilities of their subsidiaries viz. Bestal, Berk, Indesta in Turkey and Martur International’s facilities in Russia and Algeria (in total 5 plants) currently do not have such certified OHS management systems. 

The OHS management system including a screening and monitoring mechanism for OHS related regulatory requirements; as well as improvement plans based on risk assessment exist in the certified plants. These risk assessment studies identify source of the environmental impact/hazard/risk; potential root causes; exposed persons, environment, material or facility; potential risks with risk calculation table; related legal requirements; corrective actions identified and implemented; responsibilities and risk calculation after corrective actions. 

Martur aims to minimize any equipment related incident by choosing proper technologies. The forklifts and automated guided vehicles (AGV) are equipped with speed control mechanisms (maximum 10 km/hr) and photocell system to avoid collisions by auto-stopping. The pressing and metal stamping machines used manually by workers in Bestal are equipped with photocells and censors to avoid hand trapping.
 
Martur and subsidiaries have adequate organizational capacity to plan, manage and audit OHS issues at company and plant level. OHS issues are managed by plant level OHS teams supervised indirectly by Martur’s central OHS team and are generally observed to be in line with corporate procedures, national and the OHS risks of the operations of respective facilities. During site visits, strong OHS implementation was observed in all visited facilities in Turkey and Romania with adequate signage, demarcated walking ways, SOPs backed by regular peer-audits and OHS team audits. The degree of personal protective equipment (PPE) respect, voluntary audits and housekeeping varies among facilities and somewhat weaker implementation was observed in non-certified plants. The difference in OHS management was also based on different requirements imposed by OEM clients (some including peer-audits, specific awareness and award programmers etc.). As discussed under ESAP action item #2 PS1, Martur will conduct gap analysis for its OHS non-certified facilities vis-a-vis the certified facilities, and develop an improvement plan, SOPs for monitoring and audit procedures for the currently non-certified facilities.

Due to absence of a common workplace monitoring program, different practices are observed depending on country regulations, and the manufacturing process. In Romania, for instance, indoor air quality is measured instantaneously to check the amount of isocyanate, a hazardous chemical used in foam production which cause indoor VOC emissions. In Turkey, for similar process sections it is measured every two years as required by the national law together with heat, vibration, noise and light intensity measurements. 

According to the workplace monitoring data for 2014 provided for all Martur and subsidiary plants in Turkey, the facilities were found to be generally in line with national and international standards (OSHA – National Occupational Safety and Health Administration, NIOSH - National Institute for Occupational Safety and Health etc.). The indoor measurements for Algeria have not started and for Russia very basic reporting is available at this stage.

As per ESAP action item #7, Martur shall develop and implement a common workplace monitoring plan to be applied to all its subsidiaries, that cover at least annual monitoring of workplace including temperature, vibration, noise, illumination and volatile organic compounds (VOCs) in the workplace as per the World Bank Group (WBG) General EHS Guidelines. Moreover, for the workstations which involve working with hazardous substances (e.g. methylene chloride, isocyanate and others) this monitoring plan will include regular monitoring of relevant parameters (such as VOCs) to verify effectiveness of the air extractors and subsequent treatment of gas stream for removing VOCs.

Furthermore, as per ESAP action item #8, for its workstations that involve working with hazardous substances, Martur and subsidiaries shall review its air extraction and ventilation systems vis-à-vis the specific local regulatory requirements, the WBG EHS Guidelines on Metal, Plastic, Rubber Products Manufacturing; and the permissible short term exposure limits specified by OSHA for hazardous substances mentioned above. Depending on the outcomes of this review, the company shall take necessary measures such as: upgrade the air extraction, ventilation and appropriate gas treatment systems; restricting access / presence of any personnel without proper PPE in the area, and removal or complete isolation of unequipped workstations. 

Martur has a zero incident policy and OHS incidents are among the monthly KPIs followed by top management for all Ustunberk Holding companies. The incident reporting system that also covers the contractors, tracks near misses and first aid incidents as well as lost time incidents. The reporting system in Algeria and Russia are about to be established. The frequency of lost time accidents are observed to be higher than international benchmark reference values in some facilities of Martur, but generally fall within benchmark values for Turkey. To reduce this gap, Martur’s corporate environmental management team will conduct a thorough root cause analysis for the OHS performance gaps among the facilities, and develop an action plan that would involve more frequent audits, trainings and awareness programs and also update its OHS audit procedures to be consistent among all facilities as per ESAP action item #9. 

As part of its workplace health and safety measures, Martur also pays attention to improve work ergonomics. Such ergonomics measures implemented at facilities range from trainings to OHS team members, conveyors and lifting supports to fit the operations into golden zone of workers, standing supports and ergonomic carpets for sewing workers who stand all day. Bearing in mind that ergonomic practices are not evenly present around all Martur facilities and considering the repetitive and intensive nature of the operations, Martur shall also develop an occupational disease monitoring program supported by necessary awareness raising measures and ergonomic supports to be applied to all its facilities as part of its workplace monitoring program as described in ESAP action item #8.

Supply Chain: 
Martur has supplier screening mechanism for its facilities in Turkey, mainly focused at the contracting stage by requesting environmental and OHS risk assessment of the supplier and social security records of its employees.