• Promote fair and equitable labour practices for the fair treatment, non-discrimination and equal opportunity of workers;
• Establish, manage and promote a healthy management-worker relationship;
• Protect workers’ rights including migrant and third party workers; and
• Promote healthy, safe, secure and comfortable accommodation that does not impact negatively on the communities in the surrounding area;
• Address child labour, and prevent worst forms of child labour;
• Prevent the use of all forms of forced labour;
• Protect workers, including vulnerable workers such as women, persons with disabilities and migrant workers, contracted workers, and primary supply workers, as appropriate;
• Provide a Grievance Redress Mechanism (GRM) for workers to raise their concerns. Applicable Regulations, Standards and Guidelines
• UN Guiding Principles on Business and Human Rights,
• ILO Declaration on Fundamental Principles and Rights at Work,
• The sustainability principles advocated by UN Global Compact

Roles and Responsibilities

Offshore will ensure that the LMP is regularly updated and all the changes or the updates have been communicated to all employees, contractors, subcontractors and the primary suppliers. It is the employee’s responsibility to comply with the plan or seek clarifications if needed. The following roles and responsibilities will be in the plan;

E&S team
• Lead in the development and review of the Labour Management Plan working closely with other departments;
• Carry out self-assessment and monitor Offshore’s operations to determine if the plan has been implemented.
Departmental Managers
• Ensure the department’s LMP are aligned to Offshore’s regulations and international practices;
• Ensure provision of necessary resources, including budget and competent personnel are provided to manage labour issues being aligned with requirements and commitments; and
• Ensure the Offshore’s LMP is monitored and regularly reviewed.
Human Resources team
• Ensure all employees have access to the LMP at all times in a language they understand;
• Working closely with the E&S teams to develop and implement the LMP;
• Monitor working hours and overtime hours of employees to ensure compliance with law;
• Working closely with the E&S team to receive grievance, ensure they are documented properly into the database;
• Participate in the review, investigation, resolving and following up grievances; and
• Ensuring that all employees have understood and signed the Code of Conduct.
Subcontractors
• Develop their own Labour Management Plan in line with Offshore’s guidelines;
• Implement the Labour Management Plan for all the Offshore’s operations they are supporting;
• Ensure no child or forced labour is involved in the Offshore’s operations;
• Develop a separate grievance mechanism which is in line with Offshore to collect and resolve grievance raised by their employees; and
• Prepare and submit quarterly and annual report during their operations as per Offshore’s guidelines respectively.
Employees
• Participate in related trainings;
• Comply with requirements in the Plan; and
• Cooperate with the employer and others to enable them to fulfil their legal obligations.

Labor Management

The Labour Management Policy shall be communicated in languages which are understood by the employees, contractors/subcontractors and primary suppliers for further compliance and implementation.
The Labour Policy shall cover the following areas: Working Relationship, Working conditions & Terms of Employment, Gender Equity, Harassment and Abuse, Workers’ Organizations, No Discrimination & Equal opportunity, Retrenchment, Grievance Mechanism, Child Labour and Forced Labour, Occupational Health and Safety, Workers Engaged by Third Parties and Supply Chain.
Labour Use on Offshore’s operations

Categorization of the workforce

The world Bank Environmental and Social Standards 2: Labour and Working (ESS2) categorizes workers into four categories:
• Direct workers: People employed or engaged directly to work specifically for an operation.
• Contracted workers: People employed or engaged by third party contractors to perform work related to core function of an operation, regardless of location.
• Primary supply workers: People employed or engaged by the primary suppliers.
• workers: People employed or engaged in providing community
Any migrant worker who might be involved in Offshore’s operations like the international consultants will be required to adhere to individual countries laws regarding labour which include possessing a work permit.

Assessment of Key Potential Labour Risks

Most of the labour risks in Offshore’s operations will be associated with health and safety during the operational activities such as exposure to physical hazards such as: trip and fall hazards, exposure to noise, falling objects, exposure to hazardous materials and exposure to electrical hazards from the use of tools and machinery. Many workers will be exposed to occupational health and safety hazards, primarily including but not limited to:
• Working at height
• Movement and working on steep and treacherous terrain.
• Traffic accidents.
• Ergonomic hazards
• Welding hazards (fumes, burns and radiation)
• Steel erection (Racks) hazards.
• Gender based violence (GBV) risks

Terms and Conditions of Employment

Terms and conditions of direct workers are determined by their individual contracts. Permanent staff will have individual agreements (labour contract or service contract) with fixed monthly wage rates all as agreeable with both parties for all Offshore operations. Recruitment procedures will be documented and filed in accordance to the requirements of in country labour legislation and the ESS2. Requirements and conditions of overtime and leave entitlements are agreed as part of individual contracts. Offshore will ensure that contractors are aware of, and comply with, labour management and OSH policies and procedures outlined in this LMP. Each contractor will be required to submit an assessment of environmental and social risks (including labour risks) associated with their activities and risk mitigation measures in accordance with the environmental and social requirements either quarterly or annually.

Wage

All Offshore employees will be paid based on their performance and skills regardless of employees’ characteristic such as gender, age, race, religion, disability, nationality, political beliefs, membership of unions, ethnic origin, religious beliefs, as well as sexual orientation. The base monthly salary shall be determined according to wage scale and shall not be lower than the regional minimum wage.

Freedom of Association

Offshore will recognize the freedom of its employees and those of its sub-contractors to be able to participate in collective bargaining agreements. Workers shall be allowed to establish and join work-based organizations if they wish to negotiate wages and other working conditions.

Equality of Treatment

The ILO conventions to be applied include the C 100 -Equal Remuneration 1951; and C111- Discrimination (Employment and Occupation 1958) Conventions. Discrimination means denying someone a job or training on the basis of a factor, which does not affect their ability to perform that job. Offshore is committed to ensuring that men and women hired for work receive equal rates of pay for equal types of work. It will not discriminate in its hiring and employment practices on any basis of sex, race, culture, religion, sexual orientation, or other aspect as per ILO convention.

Age of Employment

Offshore target countries have ratified both the ILO Minimum of Age Convention (C138) and the ILO Worst Forms of Child Labour Convention (C182). The minimum age of employment will be 18 years. To ensure compliance, all employees will be required to produce an identification form as per in country legislation to identity and age. This shall be applicable for contractors and their sub-contractors.

Occupational Health and Safety

The Offshore OHS measures are based on the requirements of the relevant sections of intranational best practices and country legislations. Offshore’s E&S team shall establish OSH guidelines for all workers, monitor and implement training on OHS for workers and establish a system for regular monitoring and reporting on OSH performance including documentation and reporting of occupational accidents, diseases and incidents. Offshore’s managers will ensure effective methods are put in place for responding to identified hazards and risks, establishing priorities for taking action and evaluating outcomes. Please refer OHS management plan below.

Sexual Exploitation and Abuse and Sexual Harassment

Provisions to prevent sexual exploitation and abuse and sexual harassment will be included in the Code of Conduct for staff and for contracted workers in line with relevant international standards and national legislation. A separate Sexual Exploitation and Abuse Harassment policy has been developed to ensure that all risks related to SEAH have been mitigated.

Forced Labour and Child Labour

Forced labour in line with ILO Convention is defined as any work or service extracted from a person under threat or penalty, which includes penal sanctions and the loss of rights and privileges, where the person has not offered him or herself voluntarily. It includes slavery and abduction, misuses of public and prison works, forced recruitment, debt bondage and domestic workers under forced labour situations, and internal or international human trafficking. Offshore commitments to follow the requirements are emphasized in the ILO conventions, IFC PS 2, GCF environmental and social policy and local relevant laws in terms of prohibition of forced labour in any form, including slavery and human trafficking. Offshore takes a firm stand against all forms of forced labour and expects the same of its primary suppliers, partners, contractors and subcontractors. Offshore will not tolerate child labour under circumstances. A clear distinction between child labour and young worker shall be established according to internationally recognized standards. The employment of young workers, I,e, minor aged 15 years to under 18 years who have reached the minimum age of employment and completed compulsory schooling, is allowed under strict conditions and in compliance with requirements of internationally recognized standards and local relevant laws and regulations.

Worker Grievance mechanism

Grievance mechanism entails a formal process for receiving, evaluating and redressing Offshore grievances from affected workers, communities and the general public. Typical work place grievances include demand for employment opportunities; labour wage rates; delays of payment; disagreement over working conditions; and health and safety concerns in work environment Offshore has established a Grievance Redress Mechanism which shall be applicable to managing labour related issues in all its operations. Training of workers, contractors, subcontractors, community, and suppliers on Grievance Redress mechanism shall be implemented. Please refer to Grievance Redress Mechanism above.

Human Immunodeficiency Virus/ Acquired Immunodeficiency Syndrome (HIV/AIDS)

Risky sexual behaviour and engagement in illicit sex by both genders is real risk. In order to counter the risk of spreading HIV/AIDS, the Offshore operations will develop a HIV/AIDS strategy or policy consistent with ESS2 and ESS4 that shall spell out sensitization and awareness creation strategies for contractors and other employees.

Contractor Management

Each contractor engaged by the Offshore to provide services will be expected to adopt the protective measures outlined in this document. The contracts drawn by Offshore will include provisions, measures and procedures to be put in place by the contractors to manage and monitor the relevant OHS, child labour, forced labour, and other employment terms and conditions issues.

Primary Supply Workers

Offshore will identify potential risks of child labour, forced labour, and serious safety issues which may arise in relation to primary suppliers as part of the environmental and social assessment in accordance with ESS2 para.39. Based on the scope there is potential for child labour, forced labour and safety risks related to the hazardous nature of the equipment to be procured. Offshore will conduct a mapping exercise to identify possible suppliers and the extent to which they may present the potential risks in accordance with ESS2 GN39.1. In case it will be impossible to identify specific primary suppliers, Offshore will review the general industry labour issues and risks relating to the supply of such specialized equipment for Offshore’s operations. Based on the provisions of ESS2 GN39.2 Offshore will periodically update the assessment of potential risks that may arise in relation to primary suppliers.

Monitoring

Offshore shall develop processes for monitoring, assessment and audit will be developed to document the implementation and effectiveness of management and mitigation measures, assess actual impacts against predicted impacts and demonstrated compliance with applicable legal and other requirements. Offshore will conduct both desktop and field-based inspections programs to confirm that specified mitigation measures are being implemented effectively and achieving the intended outcomes. SMART Performance indicators, both lagging and leading, shall be developed and shared.

Reporting

Offshore will ensure that a aperiodic report is complained to address the labour and working conditions which are contained in this plan. Some of the key areas to be included in the report include grievances lodged by the workers and community, induction training, number of employees, issues raised by workers committees, any incidents or accident reported among others.

Training and Awareness

A training need analysis shall be established to determine the relevant trainings which shall be conducted. The needs analysis will be based on the requirements of this plan. It involves a basic assessment of the knowledge and skills of the people involved in training implementation. Some of the key areas to be covered in training shall include disciplinary and grievance procedures, cultural awareness, code of conduct, health safety and security,, human rights awareness among others.

Communication

Offshore shall ensure that the Labour Management Plan is disclosed to its staff, contractors, subcontractors and O&M contractors. Any grievances raised by workers shall be logged and followed up in accordance with the Offshore Grievance Mechanism.

Guideline on Code of Conduct

A satisfactory code of conduct will contain obligations on all workers (including sub-contractors) that are suitable to address the following issues, as a minimum. Additional obligations may be added to respond to particular concerns based on the location and the sector or to specific operational requirements. The Code of Conduct will be written in plain language and signed by each worker to indicate that they have: received a copy of the code, had the code explained to them, acknowledged that adherence to this Code of Conduct is a condition of employment and understood that violations of the Code can result in serious consequences, up to and including dismissal, or referral to legal authorities. Offshore and her contractors will conduct awareness raising and training activities to ensure that workers abide by the Code of Conduct (such as through toolbox talks). The Contractor will also ensure that local communities are aware of the Code of Conduct and enable them to report any concerns or non-compliance. The issues to be addressed include:
• Compliance with applicable laws, rules, and regulations of the jurisdiction
• Compliance with applicable health and safety requirements (including wearing prescribed personal protective equipment (PPE), preventing avoidable accidents and a duty to report conditions or practices that pose a safety hazard or threaten the environment)
• The use of illegal substances
• Non-Discrimination (for example on the basis of family status, ethnicity, race, gender, religion, language, marital status, birth, age, disability, or political conviction)
• Interactions with community members (for example to convey an attitude of respect and non-discrimination)
• Sexual harassment(for example to prohibit use of language or behaviour, in particular towards women or children, that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate)
• Violence or exploitation (for example the prohibition of the exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour)
• Protection of children (including prohibitions against abuse, defilement, or otherwise unacceptable behaviour with children, limiting interactions with children, and ensuring their safety in all areas)
• Sanitation requirements (for example, to ensure workers use specified sanitary facilities provided by their employer and not open areas)
• Avoidance of conflicts of interest (such that benefits, contracts, or employment, or any sort of preferential treatment or favours, are not provided to any person with whom there is a financial, family, or personal connection)
• Respecting reasonable work instructions (including regarding environmental and social norms)
• Protection and proper use of property (for example, to prohibit theft, carelessness or waste)
• Duty to report violations of this Code
• No retaliation against workers who report violations of the Code, if that report is made in good faith.
• Disturbing wildlife or bushmeat hunting workers prohibited under any circumstances from engaging in any disturbance of wildlife or bushmeat hunting during the entire duration of their employment/engagement