1. INTRODUCTION The Labour Management Procedures (LMP) were developed as a requirement of the World Bank in support of the Digital Government for Resilience (DG4R) Project. The procedures seek to ensure that measures are in place to manage risks associated with employment under the project and help to determine the resources necessary for planning and management. It sets out the approach to meeting national requirements as well as the objectives of the World Banks’s Environmental and Social Framework, specifically the objectives of Environmental and Social Standards 2 (ESS2): Labour and Working Conditions and Occupational Health and Safety. Based on the Project’s Environmental and Social Assessment, risks as it relates to labour and working conditions and occupational health and safety are minimal. These risks are understood and are expected to have a limited impact on the project if managed by the procedures set out in this Plan. The government is committed on a continuous basis throughout the life of the project, to evaluate risks and impacts and to have in place adequate measures and procedures to manage adverse impacts. It is important to note the LMP is a live document and can be updated to meet the demands of the project. 2. OVERVIEW OF LABOUR USE ON THE PROJECT Project workers as it relates to the applicability of EES2 refers to workers that will be employed or engaged under the project, whether full-time, part-time, temporary, seasonal and migrant workers. The main type of workers anticipated to work under this project is contracted workers, who would be engaged based on the classification of workers to perform the core functions of the project. Based on ILO Standards, most of the jobs can be classified as: 251 Software and applications developers and analysts 252 Database and network professionals 261 Legal professionals 262 Librarians, archivists and curators 121 Business services and administration managers It is envisaged that the workers will be a blend of national, regional and international contractors and sub-contractors. The project will be implemented by the Department of Implementation, Ministry of Infrastructure, Public Utilities, Energy and Transportation with support from THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 the Ministry of Finance, specifically the Procurement Unit and the Accountants General Department and Inland Revenue Department. Also integral to the project is the Ministry of Information Communication and Technologies (ICT), Births and Death, Ministry of Health, the office of the Chief Information Officer and the Department of Public Administration. To support project implementation, staff would be assigned and engaged to work directly with the project at different stages throughout the life of the project. These workers can be referred to as Direct Workers on the project. It is envisaged that approximately 143 persons will be engaged to work on the project. The workers are expected to be over the age of 18. Table 1 below provides information on the estimated number of persons that would be engaged. Table 1:Whi Showing Required Actions and Estimated Number of Persons to be engaged under the Project Action Description of Action Estimated # of Persons Management and 1. Develop the project work 1 Team Leader Technical Advisory plans 1 Change Management Firm: 2. Develop a detailed project Expert coordination, management, 1 E-government advisor Team of long term monitoring, controls and /expert Advisors evaluation plan; 1 Tax Administration Short term advisors 3. Provide capacity Expert development, technical Among others (Overall project assistance and knowledge Project Managers – management/coordi transfer to GOG Est. 4 PM nation using a counterparts on the Project Management institutional and technical Project Control Officers Officer) aspects of digital 4 officers government transformation; 4. Develop the terms of It is estimated that the reference, technical firm may have up to 8 specifications and requests persons hired to support for proposals for all digital the project on the island. platforms and consultancy An external consulting services to be procured firm will be hired to under the project; provide the project 5. Work with the relevant GOG management office units to support 1 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Action Description of Action Estimated # of Persons procurement processes and functions that are ensure compliance with required by the DG4R. World Bank fiduciary and The government will safeguards measures; provide 1 CIO and 3 team 6. Manage and update the members (2 ICT and 1 IS) project’s results framework; as a shared resource to 7. Provide quality control of support this PMO. deliverables produced by vendors and service providers; 8. Develop, manage and implement a comprehensive change management strategy; 9. Develop a Master Plan for the project. 10. Elaborate the recommended Governance & Implementation Arrangements, through stakeholders’ consultations, review of the general environment in which the bodies, structures and mechanism will have to function, as well as laws and regulations governing Civil Service in Grenada, among others; 11. Enterprise Architecture Monitoring. 12. Recommend and set up the Governance structure for the operational aspects of the GOG, digital systems. 13. Recommend a sustainability plan for all systems and initiatives using a 15-year timeline. 2 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Action Description of Action Estimated # of Persons Electronic Payment To develop a national The PMO firm will project Platform electronic payment service manager this component that will be used across GOG. as a subproject. This includes retrofitting A specialized payment existing applications to take firm will be hired with its advantage of this service. own staff– Local/Regional or International. Build capacity in the GOG The E-payment firm will staff at the Accountant be tasked to provide Legal General’s Department in and framework services supporting the system at the along with a full list of operational level. requirements for the implementation of a Ensure governance structure whole of government is established to maintain the payment system. related software and The payment firm will platforms. then be tasked to implement the full system, test and then commission with all security and enhancement reports. It is expected that the Payment Consultant team composes: Legal experts, Payment experts, banking system specialize, IT and IS systems. Est. 5 resources Single Sign-On To develop a single sign-on the The PMO firm will provide (SSO) Digital digital identifier platform that the Project Manager as a Identifier Platform will be used across GOG. This resource to guide this includes retrofitting existing process. applications to take advantage A specialist in single sign- of this service. on (digital identification) and Identification system will be hired to execute the analysis, and legal processes to facilitate the execution of a Single 3 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Action Description of Action Estimated # of Persons Sign-on system for Grenada. The GOG will provide the CIO,1 Legal drafts person, 1 Customs and Immigration Senior Official, 1 Register of Birth, 1 Home Affairs Officer, Officials from the National Security. Identity company to have at least 2 employed on this matter. A drive or campaign to get persons to register can also increase the number of staff employed in this activity. There can be up to 5 employees on this activity. Spatial Data To develop a single To be led by the Land Use Platform acknowledged spatial data Division in conjunction infrastructure that will be used with ICT. across GOG to provide access The CIO and Land Use to critical geo-spatial data that Officer (Senior) will be the facilitate revenue generation GOG supporting lead. and contributes to resilience The Ministry of ICT will be the technical support to implement planned activities. There will be five consultants hired to execute the tasks. Est 3 regional or international Est. 2 local. Data Interoperability To develop a data CIO & implement interoperability framework Ministry of ICT web and Framework Firm that will be used across GOG. application development specialist 4 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Action Description of Action Estimated # of Persons Legal consultant IT consultant Project management services (Project manager short terms) to foster and develop a data share agreement and related policies for data sharing. Data Integration and Management Consultant to ensure that data technique for all GOG services is developed, planned and tested for implementation. Est. 6 The Enterprise To perform a full enterprise The Consultant or team Architecture Firm architecture of the entire will design an Enterprise GOG. Architect blueprint which is the conceptual “ideal platform� to support the Government of Grenada digital channels. The CIO and Ministry of ICT technical staff will provide support during the process and will accept the deliverables. Est. 2 Security Services To develop the necessary Design of a data security Platform security mechanisms needed to and management plan for support electronic payment, the payment platform in digital identity and the keeping with best provision of digital services practices from NIST-800 across the GOG landscape. principles. This also includes base Develop and implement security services relevant to the plan in conjunction cybersecurity. The Vendor will with GOG staff in the be expected to work with and 5 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Action Description of Action Estimated # of Persons coordinate multiple Ministry of Finance, AG stakeholders during the office. execution of this task. This will be a hired consultant’s team. With legal expert, IT, data and security experts. Est. 4 Vertical Services: To develop and implement a Est. 4 persons to system of all taxes and implement the tax system Tax Administration licenses whereby allowing 9 locals for data entry or taxpayers to register, file and migration can also be pay online; employed. Data migration from old syntax to the new system is A company to develop and expected. This can lead to data or deploy the software Civil Registry entry jobs. application: Est. 3 (Software To have a fully online system employees. application) where citizens can request key Data Migration can create documents and pay for them local employment for 6 online. persons. This system will have some data migration to perform, this can lead to data entry jobs. Record Preservation To digitize and move into The Supreme Court with electronic format key records Land Registry Records: that will assist in the Business Registry preservation of government Records: functions in times of crises and Parliament Records facilitate the speedy reconstitution of government after disasters: Estimated local persons  Ministry of Finance to do digitization up to 80 (tax, financial data workers instruments, statistics, payroll, HR, etc.)  Customs & Excise  Immigration  Civil Registry  Motor Vehicle 6 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Action Description of Action Estimated # of Persons  Driver’s License  Electoral Records  Physical Planning Unit (GIS)  Gov't Info Services (Historical Parliamentary Audio Tapes)  Supreme Court Registry Other systems to be determined by consultation with the GOG Total Estimated No. of Contracted Workers to be 143 engaged under the Project At this stage, it is difficult to predetermine the gender of the persons that will be employed under the project. This will be determined upon engagement of the required contracted workers. It is the intention of the project to be guided by the rules and regulations that govern the project in this regard. It is important to note that the timing of labour requirements will be based on the project implementation schedule that will be developed for the project. The table below shows the anticipated sequencing of workers as it relates to achieving the projects’ results: Table 2: Number of persons anticipated to be engaged in a given Year 7 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Total # of Core Year 1 Year 2 Year 3 Year 4 Year 5 Workers Activities Project Coordination, Management & 4 3 3 1 1 12 Implementation Development of Enterprise 2 2 Architecture Electronic Payment 4 1 5 System Single Sign On (SSO) Digital Identifier 4 3 7 Platform Spatial Data Platform 3 2 5 Data Interoperability Framework 2 2 1 1 6 Firm Security Services 1 1 1 1 4 Platform Tax Administration 3 2 8 13 Civil Registry 2 5 2 9 Record Preservation 20 20 20 20 80 Total 32 44 42 23 2 143 8 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 3. ASSESSMENT OF KEY POTENTIAL LABOR RISKS Table 1 above provides a brief description of the project and the activities that will be undertaken under the project. Based on these activities, the labor risks involved with the project are viewed as minimal. Most of the labour risks will be related to extended hours of work mainly of the data inputting staff. There is also the possibility of the staff not working in properly ventilated buildings or buildings not equipped with proper cooling facilities. The probability of the incidence of child labour or forced labour is also minimal. The project requires technical staff with skills that require experience and education, which will not be possible for children or those below the age of 18 to possess. The issues of migrant and seasonal workers, labour influx or gender-based violence do not apply. A register of all persons under the age of eighteen years employed by the project and the dates of their births will be kept in keeping with the Employment Act of Grenada. No person under the age of eighteen years shall be employed or allowed to work between the hours of 9.00 p.m. to 6.00 a.m. Inputting of data related tasks is presently an area where female workers predominate. There is the potential for harassment including sexual harassment, intimidation and exploitation of young female workers. The project will adopt a zero-harassment policy for all of its workers and sub-contractors. The zero-harassment policy will be part of the workers Code of Conduct developed by the project.This policy will be broadcast to all workers through various mediums and several formats. The project will provide an extra layer of supervision for young workers to ensure they are educated of their rights, the project’s policies on harassment, intimidation and exploitation. There are minimal possibilities for accidents and emergencies related to the software development sector. However, the project through the labour management procedures plan will ensure that all applicable occupational health and safety provisions by the government of Grenada and International Labour Organizations conventions are observed. Information on the treatment of health and safety matters are expounded upon in Section 7. 4. BRIEF OVERVIEW OF LABOUR LEGISLATION: TERMS & CONDITIONS The overarching major national labour legislation in Grenada is the Employment Act of 1999 which regulates the terms and conditions of employment. The guiding principles reside on the prohibition of forced labour, discrimination, equal pay for equal works, as well as, remedies for infringements of rights. The Act makes it mandatory for employers to furnish employees with written particulars of employment, stating hours of work, wages, leave entitlements, job description, grievance procedures, benefits if any among others. 9 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Specifically, Part VI deals with the matter of hours of work and continuity of employment and will apply to the risk of extended hours of work as perceived as a minor risk to the project. Part VII speaks to Protection and Regulation of wages, Part VIII - Leave entitlements and other benefits and Part IX expounds on discipline and termination of employment. The Employment Act of Grenada strictly prohibits discrimination of employees based on race colour, national extraction, social origin, religion, political opinion, sex, marital status, family responsibilities or disability. An employee also has the right, by law, to remove himself or herself from a work situation which he or she reasonably believes presents an imminent or serious danger to life or health. 5. BRIEF OVERVIEW OF LABOUR LEGISLATION: OCCUPATIONAL HEALTH AND SAFETY There is no legislation on Occupational Health and Safety. Nevertheless, Grenada has an Occupational Health and Safety Policy which is discussed in Section 7 below. 6. RESPONSIBLE STAFF The Department of Implementation, through the project manager, will be responsible for the engagement and management of all project workers. The project manager will be the direct staff responsible for the engagement of project workers, contractors and subcontractors. The project manager will be responsible for the overall management of all project workers and contractors and subcontractors, who will be supported by the Management and Technical Advisory Firm. Occupational Health and Safety (OHS): Occupational Health and Safety (OHS) will be the responsibility of the Environmental and Social Safeguards Officer. Contractors will assign a member of staff with responsibility for matters related to health and safety. In large firms, this member of staff may be a specialist in the area of OHS, for smaller firms and sub-contractors a member of staff with training and experience in OHS can suffice. A Code of Conduct for workers is required and will be developed and implemented. The safety representative will ensure that any complaint on health and safety are recorded reported to the project safeguard officer. 10 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Training of Workers: The safeguards officer will liaise with the contractors’ OSH representative for the necessary capacity building activities of the contractor’s management staff and workers. Training of workers in environmental and social standards and OHS will be the responsibility of the project safeguards officer. Training on the Code of Conduct will be conducted by the Project Manager with assistance from the project safeguards officer. Worker Grievances: The process for addressing workers grievance will be the Greviance Redress Mechanism of the project ( described in the section of the document on GRM). 7. POLICIES AND PROCEDURES In an effort to mitigate the environmental and social impact relating to the project, it is the intention that mitigation measures will be put in place by incorporating standardized clauses in the contract documents so that the contractors will be aware of environmental and social obligations under the project. The Department of Implementation will ensure compliance by the contractor with these clauses. The project will prevent any gender discrimination on the workplace, including gender pay gap. The project OHS policy will be as follows: 1.0 PURPOSE The primary purpose of this OHS Policy is the safety and health of all the project employees at work and the protection of the environment and conservation of resources associated with the project. The policy also establishes and defines the authority for the OHS and associate safety systems. The policy will be enforced on all activities of the project and contractors and sub-contractors of the project through contractual arrangements as is appropriate. 2.0 SCOPE Occupational safety and health (OSH), also commonly referred to as occupational health and safety (OHS), occupational health, or workplace health and safety (WHS), is concerned with the safety, health, and welfare of people at work. Safety is defined as “the well-being of project employees whilst at work or carrying out work duties�. Project Employee for the Project is defined as “anyone employed by activities of the project 11 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 including employees of contractors and sub-contractors on a full-time or a part-time basis. OSH Management System is the standards, policies, guidelines, that address project worker's safety, monitoring and evaluation of safety, worker's health, work and general environment. 3.0 POLICY The obligations of the project under the OSH policy includes the following:  Compliance with all national associated legislation (for example health associated legislation) and international OSH legislation that are applicable to Grenada and the World Bank  Compliance with the Environmental and Social Safeguards of the World Bank  Prevention of injury and ill health of all project workers  Establishment of safety systems, processes and performance;  Continuous improvement of Safety Systems  Management and mitigation of adverse environmental and social impacts  Prevention of use of faulty equipment or sub-standard equipment The project will commit to safety considerations in the conduct of all of its activities and that of contractors and sub-contractors. The project will provide systems, processes, procedures, the necessary safety equipment and gears, and training for all project employees so that all activities are conducted in a safe environment. Employees will be responsible, subject to their roles, for the maintenance of a safe environment including the assessment of risks and actions to mitigate minimize and manage risks to the safety of the work environment. The project will develop an OHS policy and implement systems, processes, supporting policies, and services that are national and international in compliance with national and international legal requirements including industry standards and best practices in relation to safety. Employees at all levels have the authority to stop any activity they consider to be a danger to themselves or other workers, the public or the environment. The project is committed to non-retaliation to stop-work actions by project workers. The Environment and Social Specialist of the project is responsible for the implementation and monitoring of the safety management systems of the project. The ESS will develop sub-policies, guidelines, procedures, instructions and training and awareness materials to support this policy. 12 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Dissemination and Awareness The OSH policy, developed for the project, will be disseminated to all project workers and stakeholders. The information will be dissemination in various formats including an adapted and summarized version. 8. AGE OF EMPLOYMENT The project will be guided by the (Grenada Employment Act , 1999) which states that the minimum age of employment in Grenada is sixteen (16) years old. In addition to the Employment Act, Grenada is a signatory to the following international conventions related to the minimum age of employment:  Convention on the Rights of the Child (CRC): “Signed on the 19th April 1990 and ratified on the 9th October 1990� (UNICEF, 2015)  Minimum Age Convention, 1973 (No.138) ( (International Labor Organization , 2017)  Forced Labour Convention, 1930 (No. 29) (International Labor Organization , 2017)  Worst Forms of Child Labour Convention, 1999 (No. 182) (International Labor Organization , 2017)  Medical Examination of Young Persons Convention, 1921 (No. 16) (International Labor Organization , 2017)  UN CRC Optional Protocol on Armed Conflict (U.S. Department of Labor , 2017)  UN CRC Optional Protocol on the Sale of Children, Child Prostitution and Child Pornography (U.S. Department of Labor , 2017)  Palermo Protocol on Trafficking in Persons (U.S. Department of Labor , 2017) Employees over the minimum age of 16 and under the age of 18, may be employed or engaged in connection with the project only under the following specific conditions: (a) the work is not likely to be hazardous and is not harmful to the child’s health or physical, mental, spiritual, moral or social development, and will not interfere with the child’s education. (b) an appropriate risk assessment is conducted prior to the work commencing; and (c) the Borrower conducts regular monitoring of health, working conditions, hours of work and the other requirement of ESS2: Labor and working conditions. The following process will be followed to verify the age of project workers: 13 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 All project employees will be asked to produce identification documents (ID) that are acceptable in local laws, employment and human resources practices as “proof of age�. These forms of ID will be birth certificates, national drivers licenses and national registration cards. In the absence of one of those forms of IDs the project will apply and document an age verification process. The age verification process will consist of alternative methods including copies of academic certificates, testimony/affidavits from officials of the schools attended, a medical examination, statements from family members and parish/village officials/local authorities. In addition, all documents will be cross-referenced and subjected to a verification process to ensure the validity of the documents. In instances where the documents are thought to be falsified the project will conduct the same process to ensure their authenticity. In all of the processes the attendant care will be provided to ensure that the applicant or employee’s data are protected and their right to privacy is guaranteed. All copies of the IDs and documents pertaining to the applicant's age and other supporting materials will be kept in files with the human resources personnel. Audits and controls of the process will be a requirement of the contractors and included in the contracts, in keeping with the Grenada Employment Act of 1999. In the event that underage workers are found working on the project the following actions will be undertaken:  Termination of the contract and services agreement immediately as per the Labour Act of Grenada  Schedule a meeting with the child and seek to determine the reasons for seeking employment  Refer the child to other support services including social services and the Ministry of Education  Leverage the services of Non-government and Community Based Organizations to assist the child  Consider employing another adult member of the family if the child’s family is determined to be vulnerable or in dire circumstances The Grenada employment Act of 1999 will be used as a guide in the conduct of the assessment of risks associated with persons below the age of 18. The procedure for assessing the risks will be as follows:  All persons will be asked to provide a medical certificate with the results of a medical examination.  An assessment will be done of the tasks assigned, to ensure that persons below the age of 18 are not subjected to hazards and risks  There will be clear policy guidelines regarding supervision of young persons to prevent exploitation and sexual harassment 14 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018  Young persons will be provided with educational and awareness information on the policies of the workplace including sexual harassment policies and labour related grievances and the grievance redress mechanism of the project. 9. TERMS AND CONDITIONS The following terms and conditions apply to project workers in accordance with the Grenada Employment Act of 1999. Contracts The project, and sub-contractor, subcontractor, and assignees of contracts shall pay rates of wages and observe hours and conditions of employment which are not less favourable than those established in the country. Contractors and sub-contractors shall be certified according to the Government Requirements for governmental contractors including that contractors are certify that the wages and conditions of employment of all those employed by the contractor in the trade or industry in which the contractor is seeking to contract with the Government are fair and reasonable. The contracts will be guided by the principle of collective bargaining is applicable and where there is no minimum wage or rates established in the country, the guiding principle will be of fair wages and reasonable rates commensurate with governmental minimum wage and similar established rates and conditions. In keeping with the Employment Act, the contractor shall keep proper wage records and time sheets for all those employed in relation to the execution of the contract, and the contractor shall produce the wage records and timesheets for the inspection of any person authorised by the project or the Labour authorities of Grenada. Contractors are required by law, to post conditions of work in conspicuous places informing workers of their rights and conditions of work. The contractor shall ensure sufficient insurance so as to pay compensation to workers under the Workmen’s Compensation Act, Chapter 343. 9. A subcontractor shall be bound to conform to the conditions of the main contract and the main contractor shall be responsible for the observance of all contract conditions. Contractors and subcontractors shall recognise the right of their workers to be members of the trade unions. Minimum Wage 15 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 All project workers shall be paid a wage that is above or equal to the minimum wage as established by the Government of Grenada. Wages will be paid on a weekly, bi-weekly or monthly basis. Each employee is entitled to a statement accompanying pay that itemitised the following: “(a) the employee’s gross wages due at the end of that pay period; (b) the amount of every deduction from his or her wages during that pay period and the purpose for which each deduction was made; and (c) the employee’s net wages payable at the end of that pay period.� Hours of Work The maximum number of ordinary hours of work for employees shall be 40 hours per week with the ordinary working days being Mondays to Saturdays. Project employees are prohibited from working more than 10 hours per day inclusive of two hours for lunch and rest periods. No person under the age of eighteen years shall be employed or allowed to work between the hours of 9.00 p.m. to 6.00 a.m. Other provisions related to hours of work will be guided by the Employment Act on this matter. 10. GRIEVANCE MECHANISM The Grievance Mechanism for all Project Workers is as follows: Contractors and or Representatives will be the point of contact for all Grievances. In the case of project management staff, the point of contact will be the Permanent Secretary. The contractor will designate a staff member who will be responsible to receive grievances. Upon receipt of Grievances, the contractor staff / Permanent Secretary or Representative will notify the project manager and Environmental and Social Specialist (ESS). Grievances will be registered in a registry of complaint and all information related to the handling of the grievances will be recorded in the registry. In the case of issues with project management staff the Project Manager may be required to exclude her or himself it the compliant directly involves him or her. The contractor will attempt to address grievance within established time frame of 3 weeks upon receipt. In cases of timely or urgent matters a period of a minimum of 24 hours and a maximum of 15 days will be allotted for addressing a resolving the grievance. Grievances can be made in person, telephone call or writing. The Grievance Redress Mechanism of the project will be published on the Ministry of Finance’s website. In addition, it will also be disseminated via public notices and billboards on sub-project sites, brocures will be distributed in communities of project activity and messages will be placed in both print and 16 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 broadcast media advising of the mechanism and access points. Grievances can be made anonymously. A dedicated email and telephone number will be provided for all Grievances. For grievances made via telephone or in person, a written account will be compiled and the complainant will be asked to verify its authencity and sign that it is an accurate account. The staff member designed by the contractor will notify the Project Manager through a report of the successful resolution of any grievance. The complainant will also be informed via writing of the measures taken to address the grievance. If the grievance cannot be resolved by the contractor the contractor will inform the Project Manager and ESS. The ESS and Project Manager will meet with the project contractor and workers and attempt resolution. In the case of project management staff, the Permanent Secretary will meet directly with the staff. If issues cannot be resolved the issue will be referred to the Ministry of Labour for their action and pronouncement. The Ministry of Labour’s ruling would be the final tier of the grievance mechanism. If unresolved, either party may seek redress in the courts of the Country. Parties involved will be advised that they can directly contact the Project Office Ministry. Information about the GRM will be disseminated to workers through signs at the project work site, brochures and handbills at the project website and SMS messages sent to the workers phones. 11. CONTRACTOR MANAGEMENT It is mandated that the contractor execute the management of the contract in a manner that is acceptable to the client and is in accordance to the World Bank rules and regulations as it relates to ESS2, specifically relating to the selection process for contractors, management of labour issues, including health and safety, procedures for managing and monitoring of performance for contractors, as well as reporting on workers under the project. 17 THE WORLD BANK LABOR MANAGEMENT PROCEDURES: VERSION 1.0 – SEPTEMBER 6, 2018 Information on Public Records: The Contractor must have in place information on corporate registers and documents relating to the violation of applicable law, including reports from labour inspectorates and other enforcement bodies. Certification and Approval of Business and Workers: Documentation of approved business licenses, registration, permits and other approvals and workers’ certification/permits and training to perform the work. Health and Safety: Document and have in place labour management systems as it relates to organizational health and safety. Records of incidents and corresponding root cause analysis with a corrective mitigation plan. First aid cases, high potential near misses, and remedial and preventive activities required. Identification and establishment of safety committee and records of meetings Workers Payroll Records: Documentation of the number of hours work and pay received inclusive of all payments made on their behalf, for example payment made to the National Insurance Scheme and other entitlements regardless of the workers being engaged on a short- or long-term assign mentor fulltime or part time worker. 12. COMMUNITY WORKERS Due to the technical nature of the project, the project does not envisage the hiring of community workers on the work. However, in the case community workers are hired by the project, they will be provided with contracts similar to other project staff and workers. The Grievance Redress Mechanism of the project will also be applicable to community workers of the project. 13. PRIMARY SUPPLY WORKERS There is no significant risk of child or forced labor or serious safety issues in relation to primary suppliers. Based on the nature of the project, there will be no Primary Suppliers engaged. There is one Contract envisaged that relates to goods, that is IT equipment and accessories for Government and Civil Registries. This will be handled as a one-off contract. 18