Communication Folder Revised-4

7/29/2019 Communication Folder Revised-4

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Brookes Pharma (Private) Limited

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HSE & SA-8000 Communication FolderFor Suppliers / Contractors / Sub-Contractors / Interested Parties / Stake Holders

List of Contents

S.No. Contents

1. QHSE & SA Policy

2. HSE Requirements for Suppliers/ Contractors / Sub-Contractors

a. What are High risk jobs: These require PTW

b. Risk Assessment for high-risk jobs

3. SA Policies and Procedures

a. Recruitment & Selection/Hiring

b. Employees Orientation

c. Remuneration Policyd. Discrimination

e. Working Hours

f. Overtime

g. Weekly and Gazetted Holiday

h. Policy and Procedure for Remediation of Child Labor & Young Worker

i. Forced & Compulsory Labour

j. Health & Safety

k. Disciplinary Practices

l. Access to Verification

4. Joint Works Council

5. Training

6. Facilities provided to Employees

7. Management Review Results


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The Q.H.S.E. & S.A. Policy

Brookes has a strong commitment to produce pharmaceutical products of the highestquality while operating in a safe, environment-friendly and socially responsible andaccountable manner.

To fulfill the above commitment, the organization;

Follows the pharmaceutical industry standards of quality by using appropriatesystems of production, storage, distribution, quality control and quality assurance.

Prevents incidents (injuries, ill-health & accidents) by managing health, safety andenvironmental risks involved in all the various operations.

Promotes environmental awareness among its employees and affiliated parties andadopts efficient techniques to prevent environmental pollution.

Complies with the applicable national and international laws, standards andrequirements of environment, health, safety and social accountability andsafeguards the interest of all the stakeholders by acting in a socially responsiblemanner.

Makes continual efforts to enhance quality, environment, health & safety systemsby improving customer satisfaction, preventing errors, team work and humanresource development.


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2 . HSE Requirements for Suppliers/Contractors/Sub-Contractors

The requirement related to product and services that can have any impact on theHSE. This requirement includes but not limited to:

Handling/packaging/identification requirements. Requirements of transporting carrier/storage. Information about the product composition/MSDS. Compliance of Brookes procedure for performing the activity. Usage of protective gears. Training requirements. Handling and disposal of waste etc.Brookes ensures that all Suppliers / Contractors / Sub-Contractors selected for anyMaterial / Service / Contract provision are able to meet HSE requirements. This

includes the following,

Read, understand and implement Permission to Work (PTW) requirementsassociated with all high risk jobs listed on PTW.

Follow all HSE requirements specified by Brookes. Monitor and ensure all contractor staff follows all HSE requirements including

use of PPEs. Report any violation of HSE, accident or incident to contract coordinator

immediately.

a. What are the High Risk Jobs; These require PTW.

The High Risk Jobs are but not limited to:

a) Constructionb) Maintenance of pipelines, vessels, boilers, etc.c) Waste Disposald) Handling and transportation of Hazardous Materials such as chemicals, gases,

lubricants, fuels, and oil etc.

e) High Voltage electrical workf) Working in Confined Spacesg) Laying, replacement and maintenance of pipelines or air-conditioning ducts.h) Working at heighti) Working in areas/equipment whose environments require microbiological or

sanitation control.


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The Requisitioner department identifies HSE requirements in the bidding/ tenderdocuments along with the following details (as applicable), that contractor have toperform.

Working Procedures HSE Risk assessment of the job. Requirements of transporting carrier, machinery/equipment and tools. Handling/Packaging/Identification requirements. Information about the product composition/MSDS. Compliance of HSE procedure for performing the activity.

Usage of protective gears PPEs. Competence/training requirements of workers. Handling and Disposal of Waste etc. The need to take PTW, where required. Emergency procedures. Accident/incident reporting Legal requirements

b. For any of the high-risk jobs, Brookes may ask the supplier/contractor tocarry out a risk assessment before awarding a contract. At a minimumrisk assessment must include:

Potential exposure to worksite hazards and their risks Nature of work-materials to be utilized Potential consequences of incidents Operation control to mitigate the risk


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SA- 8000 Policies and Procedures

1. Purpose

The purpose of this Manual is to describe the SA-8000 policies applicable to BrookesPharma (Private) Limited and to communicate the same to stakeholders for the betterexecution of the organizational processes.

2. ScopeThis Manual covers all applicable requirements related to Social Accountability ManagementSystem of Brookes Pharma (Private) Limited.

3. Policies

3.1 Recruitment & Selection / Hiring

Brookes welcomes the talent of people from diverse backgrounds to provide the

expertise, dedication, and imagination to propel toward a prosperous future. It looksfor individuals with daring spirits and inquisitive minds who seek a broad range of

opportunities for personal and professional growth, and whose efforts are realized inthe improved health of people.

Brookes is an exciting organization, which offers a variety of career opportunities. Itsrecruitment process aims to achieve the highest level of candidates care by listeningto their interests and treating them like a valued customer.

Brookes is committed to recruit and select the best human capital through internal or

external hiring. Its hiring needs depend upon the business plan and specific request ofline managers.

The specific request is received through a specified format naming Human ResourcesRequisition Form which is filled in by the sectional/departmental head and thenforwarded to H.R Department for searching out the best candidate.

The H.R Department analyzes the job need and if found genuine then forward it toVice President for approval that leads to the initiation of proper recruitment process.If the vacancy is assessed to be filled in by the internal candidate then companysearches out the candidate by looking into the talent inventories followed by furtherproceedings.

However, for the external hiring company follows the method of (i) advertisement innews papers (ii) using online recruitment partner (iii) search out the candidatethrough H.R. Data Bank (iv) through labor contractor (v) and sometimes get theservices of Head Hunters.


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After creating a pool of desired candidates through one of the above cited methods,the candidates are shortlisted in view of the job specification followed by interviewsand other selection process.

3.2 Employees Orientation

All the newcomers are oriented right after their joining with the company and itsrules, regulations, policies, people and organization structure etc.

3.3 Remuneration

Every employee is paid a monthly gross salary as per his/her pay scale which isnot less than the prevailing minimum wages along-with some additionalpayment on account of conveyance allowance for those who are either notprovided with the company transport facility or those who are eligible but havewillingly opted for conveyance allowance rather than company transport.

Brookes is strictly adhered to not deduct any employees salary for disciplinarypurpose.

Brookes does not focus on hiring labor only through contractor to avoidfulfillment of obligations rather it gives precedence direct employment overthrough contractor.

Brookes ensures that workers working under the contracting agreement arereceiving the same minimum salary as the people directly employed bycompany.

Brookes also ensures that the employees irrespective of their employmentcategory are enrolled in Social Security, Life Insurance, E.O.B.I. etc.

3.4 Discrimination

Brookes is committed to avoid discrimination in remuneration, recruitment &selection, training & development, promotion, termination or retirement basedon race, cast, national origin, religion, disability, gender, sexual orientation,union membership, political affiliation or age.

Brookes does not interfere with the exercise of personnels rights to observetenets or practices, or to meet needs relating to race, national or social origin,religion, disability, gender, sexual orientation, family responsibilities, unionmembership, political opinions, or any other condition that could give rise todiscrimination.

Brookes does not allow any behavior that is threatening, abusive, exploitative,or sexually coercive, including gestures, language, and physical contact, in theworkplace and, where applicable.

Brookes does not subject personnel to pregnancy or virginity tests under anycircumstances.


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3.5 Working HoursNo employee works more than 48 working hours per week as per the followingdistribution.

Normal Timings:

Monday Through Thursday 8:00 to 5:30 p.m. Friday 8:00 to 6:00 p.m. Saturday & Sunday Off-DaysShift:

Monday Through Saturday 7:00 a.m. to 3:00 p.m.3:00 p.m. to 11:00 p.m.11:00 p.m. to 7:00 a.m.

Monday Through Friday 7:00 a.m. to 4:30 p.m.3.6 Overtime

No employee is allowed to stay for overtime for more than 12 hours per week and 48hours per month.

3.7 Weekly and Gazetted Holidays:

Employees are at least entitled to have one off-day in a week but generallytwo off-days in a week (Saturday & Sunday) are given to those who work in ageneral shift.

Employees are also entitled for all the gazetted holidays announced by theGovernment of Pakistan.

3.8 Policy and Procedure for Remediation of Child Labor & Young Worker:

Policy:

Brookes Pharma (Private) Limited will neither employ/engage in child labour (specified

as < 15 years of age) nor employ young workers (specified as >=15 and


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2. If Child or Young Worker found to be working then Brookes will take the followingactions:a) Ask them to discontinue work immediately.b) Provide adequate support to enable such children to attend and remain in school

until no longer a child.c) Pay for their tuition related expenses, such as uniforms, books, and a stipend to

replace essential lost income.d) In addition to providing school fees and/or contracting with a local group (if no

free public education is available), the company should either;

(i) offer to hire the parents, guardians, elder siblings or members of theextended family of the children

OR(ii) pay a stipend to replace lost income.

e) Inform interested parties who are experts on childrens welfare such as localgovernment and /or NGOs.

f) If no schools exist in that area, the company will work with local community andgovernment to resolve this issue.

However, after attaining the age of 15 years for children and 18 years for youngworkers, there will be no liability on part of the company with regard to child or youngworker payments / rehabilitation.

3.9 Forced and Compulsory Labor

Brookes does not engage in or support the use of forced or compulsory labor asdefined in ILO Convention 29, nor shall personnel be required to pay deposits orlodge identification papers with the company upon commencing employment.

Neither Brookes nor any entity supplying labor to the company withholds any partof any personnels salary, benefits, property, or documents in order to force suchpersonnel to continue working for the company.

All the personnel at Brookes have the right to leave the workplace premises aftercompleting the standard workday, and are free to terminate their employmentprovided that they give reasonable notice to the company.

Neither Brookes nor any entity supplying labor to the company engages in orsupport trafficking in human beings.


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3.10 Health And Safety

The Brookes is committed to;

Provide a safe and healthy workplace environment and take effective steps toprevent potential accidents and injury to workers health arising out of, associatedwith, or occurring in the course of work, by minimizing, so far as is reasonably

practicable, thecauses of hazards inherent in the workplace environment, and bearing in mind theprevailing knowledge of the industry and of any specific hazards.

Provide to personnel on a regular basis effective health and safety instructions,including on-site instruction and, where needed, job specific instructions. Suchinstructions are repeated for new and reassigned personnel and in cases whereaccidents have occurred.

Brookes maintains written records of all accidents that occur in the workplace andin company-controlled residences and property.

Provide at its expense appropriate personal protective equipment to personnel. Inthe event of a work related injury the company provides first aid and assists theworker in obtaining follow-up medical treatment.

Undertake to assess all the risks to new and expectant mothers arising out of theirwork activity and to ensure that all reasonable steps are taken to remove or reduceany risks to their health and safety.

Provide for use by all personnel, access to clean toilet facilities, access to potablewater, and, where applicable, sanitary facilities for food storage.

To ensure that any dormitory facilities provided for personnel are clean, safe, andmeet the basic needs of the personnel.

All personnel have the right to remove themselves from imminent serious dangerwithout seeking permission from the company.

3.11 Discip linary Practices

Brookes treats all personnel with dignity and respect. It does not engage in ortolerate the use of corporal punishment, mental or physical coercion, or verbalabuse of personnel. No harsh or inhumane treatment is allowed.

3.12 Access to Verifi cation

Brookes shall ensure access to its premises and to reasonable information requiredby the auditor in case of announced and unannounced audits of the company forthe purpose of certifying its compliance with the requirements of this standard.


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Joint Works Council

Brookes has established a Joint Works Council with an aim to provide a platform where workerssuggestions for improvements, grievances handling etc. can be discussed to maintain strongrelationships between Workers and Management in order to provide better communication andrepresentation. The council comprises of both male and female employees.

Management Representatives comprise of two representatives as under:

1. Syeda Saba Swaleh Senior Manager Packaging2. Syed Sajid Hassan Zaidi Senior Manager Commercial

Two workers representatives are currently members of this Joint Works Council. Their names are

as under:

1. Salman Ahmed Maintenance Technician (Representative of male workers)2. Shama Parveen Line Incharge (Representative of female workers)

The Convener of the Council:

Moghis Jalal Senior Manager Human Resources

The council meets and discusses issues after every six months. However, where there occurs anyemergency meeting can be held earlier and at short notice. A part from this arrangement,management provides open door policy to meet and facilitate employees at any time duringworking hours.

Training

Employees are given trainings about the SA-8000, Health and Safety. A part from this, other on jobtrainings are also imparted. To make them aware and updated on the important policies,procedures, guidelines, precautions etc., regular feedback sessions, house notices and e-mailmessages are sent out.

Facilities

Brookes provides various facilities to its employees which include, free meals, uniforms withwashing, hygienic toilets, company provided transport facility for female workers, additionalconveyance allowance for male workers, interest free loans etc.


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Management Review Results

Report for the period:- J uly 2011 to J une, 2012

Agenda Status EDTOs Decisionand Remarks

3.9 Status of SocialAccountability Management

System

3.9.0. Human ResourceManagement Process

3.9.1 Training, Awareness &Competence:

Trainings are beingconducted as per trainingplan and evaluatedaccordingly.

Excellent executionand documentation

3.9.2 Freedom of Association andRight to Collective Bargaining:

The joints works councilmeeting was last conductedon 11-06-12.

All points had beendiscussed properly.

3.9.3 Forced & Compulsory Labour The use of forced andcompulsory labor is not at allsupported.

In full compliance

3.9.4 Discrimination No discrimination is observedfor hiring, payingremuneration, training,promotion, termination orretirement, gender etc.

In full compliance

3.9.5 Disciplinary Practices Mental or physical coercionand verbal abuses are neitherobserved nor supported.

In full compliance

3.9.6 Working Hours Employee generally works for48 hours in a week atBrookes. However, in order tomeet the market demandovertime is done whichusually happens to be within48 hours in a month.

We strictly complyweekly hours andovertime limit.


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3.9.7 Remuneration Minimum wages are paid overand above the legalrequirement and is sufficientto meet the basic needs ofpersonnel which include somediscretionary income as well.

OK

3.9.8 Child Labour Child labour is not engagedand supported at Brookes.

We comply fully

3.9.9 Control of Suppliers/Sub-contractors and Sub-Suppliers

Audits are being done as perthe plan. Supplierscommitment of socialaccountability is availablewith Supply Chain.

OK

3.9.10 Health & Safety It is covered under QHAS-18000 and is discussed in theMR meeting of QHSE.

Fine

3.9.11 Outside Communication andStakeholder Engagement

Interested parties arecommunicated SA-8000policies and procedures forwhich communication folderhas been made. Wheneverthere occurs any change in thedocument, it is communicatedto them. However,Management Review resultsare communicated to themexcept confidential data. Wewould welcome dialogues withany stakeholder with respectto the compliance of SA-8000standard.

Our systems areworking well for SA-

8000 policiescommunication.

3.9.12 SA-8000 WorkerRepresentative

In place OK


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3.9.13 Access for Verification In case of announced andunannounced audits of thecompany for the purpose ofcertifying its compliance withthe requirements of SA-8000standard, we provide accessto our premises and toreasonable informationrequired by the auditor.

OK

Prepared By: SA- Management Representative Approved By: Executive Director Technical Operations

Sign & date: ________________ Sign & date: ________________

Communication Folder Revised-4

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