LADOL Communication on Progress Report 2022
- Participant
- Published
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- 08-Oct-2022
- Time period
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- October 2021 – October 2022
- Format
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- Stand alone document – Basic COP Template
- Differentiation Level
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- This COP qualifies for the Global Compact Active level
- Self-assessment
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- Includes a CEO statement of continued support for the UN Global Compact and its ten principles
- Description of actions or relevant policies related to Human Rights
- Description of actions or relevant policies related to Labour
- Description of actions or relevant policies related to Environment
- Description of actions or relevant policies related to Anti-Corruption
- Includes a measurement of outcomes
- Statement of continued support by the Chief Executive Officer
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Statement of the company's chief executive (CEO or equivalent) expressing continued support for the Global Compact and renewing the company's ongoing commitment to the initiative and its principles.
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To our stakeholders:
I am pleased to confirm that LADOL Free Zone (LADOL) reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.
In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture, and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.
Sincerely yours,
Dr. Amy Jadesimi
Managing Director
08/10/2022
- Human Rights
- Assessment, policy and goals
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Description of the relevance of human rights for the company (i.e. human rights risk-assessment). Description of policies, public commitments and company goals on Human Rights.
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To ensure workers are provided safe, suitable, and sanitary work facilities.
To protect workers from workplace harassment, including physical, verbal, sexual or psychological harassment, abuse, or threats.
To take measures to eliminate ingredients, designs, defects, or side-effects that could harm or threaten human life and health during manufacturing, usage, or disposal of products.
- Implementation
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Description of concrete actions to implement Human Rights policies, address Human Rights risks and respond to Human Rights violations.
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Provision of appropriate Personal Protective Equipment (PPE) to workers in the discharge of their daily duties and responsibilities. Ensuring that employees always observe safety measures. Empowerment of the employees to stop work whenever activities are perceived unsafe using. The Stop Work Card which is authorized by the Managing Director backed by the Stop Work Authority Policy which is available to every employee is the instrument used to invoke this authority.
LADOL provided suitable sanitary convenience for both male and female (In line with PART II – HEALTH (General Provisions of the Factories Act 1987) regularly kept clean and maintained by sanitary officers employed for the sole purpose keeping the facility in a state of cleanliness. In addition, industrial washing machines with dedicated laundry personnel is made available to all residents on the base. Continuous monitoring of safety through Safety rules and best practices.
LADOL also provided support for employees in the workplace by providing procedures guiding relationships at work and any form of harassment, abuse, or threat.
Monthly engagement with employees for them to know their rights and privileges as it concerns discharge of their duties and responsibilities. A reporting pattern is established and known to all employees to report workplace harassments.As part of measures to eliminate defects or side effects from product that could harm or threaten life and health during handling of dangerous products. We have in place both soft and hard controls to manage such risk. We set operational controls documented in operational control procedures. We have the chemical handling procedure, Personnel were trained to handled chemicals in Hazard communication standards (Aligns with the United Stated Department of Labour Standard 29 CFR 1910.1200), CHIP regulations and the Globally harmonized system for the classification of chemicals (GHS). We also implement the requirements of those standards.
In addition, we do have the lifting operations procedure which also aligns with LEEA COPSULE and LOLER Regulations 1998. We conduct the monthly inspection of equipment as part of proactive monitoring process and the third-party thorough examination. This is necessary to detect defects and correct them before the occurrence of undesired events which could harm or threaten human life. The use of risk assessment is also another proactive measure to prevent undesired exposure to harm.
Some of the policies and procedures we have include:
Child and Forced Labour Policy
Grievance Mechanism Procedure. Employee handbook p.25
Employee Handbook – P.10 – Anti-discriminatory/Anti-harassment statement in employee handbook
- Measurement of outcomes
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Description of how the company monitors and evaluates performance.
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Monthly engagement with employees is conducted to know how they are faring. Issues raised in the cause of the engagement has been taken care of and resolved amicably.
No issue of reported human right abuses or child labour
Continuous safe working conditions. Minimized work related incidents and reports.
Employees speaking out and reporting unsafe working conditions.
Less report of personnel to the infirmary.
- Labour
- Assessment, policy and goals
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Description of the relevance of labour rights for the company (i.e. labour rights-related risks and opportunities). Description of written policies, public commitments and company goals on labour rights.
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To Ensure that the company does not participate in any form of forced or bonded labour.
To Comply with minimum wage standards.
To Ensure that employment-related decisions are based on relevant and objective criteria.
- Implementation
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Description of concrete actions taken by the company to implement labour policies, address labour risks and respond to labour violations.
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The company has a policy on Child and Forced labor. It is also stated in the recruitment procedure. Compliance with the section 27 (4) of the Nigerian Labour Act 1990.
Request of official identification document – Birth Certificates – to verify age during employment documentation. We conduct at least one legal audit a year. This audit includes the reviews of the activities of all departments in LADOL and their adherence to regulatory provisions, including the Child's Right Act, 2003, Nigerian Labour Act 1990, and Factories Act, 1987. There is a company policy that prohibits any form of forced or bonded labour.LADOL is in compliance and adherence to regulatory provisions, including the National Minimum Wage (Amendment) Act, 2011, Employees’ Compensation Act, 2010, and Finance Act, 2021 of the Federal Republic of Nigeria, no employee of LADOL is paid below the national minimum wage.
Provision of Job Description with job specific criteria to all employees within the organization for them to know their responsibilities and what is expected of them.
The JDs are based on the Job positions. Yearly performance appraisal is also conducted based on the employee performance with respect to these criteria and objectives as stated in their Job Description.
- Measurement of outcomes
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Description of how the company monitors and evaluates performance.
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All LADOL’s employees are above the minimum age as stated by the Nigerian Labour Act 1990 which is 18years.No employee is paid below the minimum wage as stated in the minimum wage Act (As Amended) of the Federal Republic of Nigeria.
All employees are given their Job description at the point of been employed or promoted.
Use of the Employee Records in Microsoft NAVISON and Excel to spool and monitor demographics.
Recruitment and Selection procedure used for personnel recruitment and onboarding.
Conduct ISO & UNGC internal audit.
Conduct of external ISO9001:2015, ISO14001:2015 & ISO45001:2018.
Management Review Meetings Where Senior management review of compliance with the requirements of ISO 9001:2015 Quality Management System, ISO14001:2015 Environmental Management System and ISO 45001:2018 Occupational Health and Safety Management System, UNGC & it's principles, UNSGDs.
Conduct of Legal Audit for the assessment of compliance with relevant statutory and regulatory requirements by the processes as indicated in the Enterprise’s Legal Requirements Register of Legal Requirements, 2022.
- Environment
- Assessment, policy and goals
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Description of the relevance of environmental protection for the company (i.e. environmental risks and opportunities). Description of policies, public commitments and company goals on environmental protection.
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Avoiding environmental damage via regular maintenance of production processes and environmental protection system (air pollution control, waste, water treatment systems, etc.).
Ensure emergency procedures to prevent and address accidents affecting the environment and human health.
Minimize the use and ensure safe handling and storage of chemical and other dangerous substances
- Implementation
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Description of concrete actions to implement environmental policies, address environmental risks and respond to environmental incidents.
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Dangerous substances are handled in bund walls built to prevent spills from contaminating the soil and water body. We also have in place bonded trail that we do use to manage secondary spill. All employees are also trained in emergency spill response training. We have effective waste management process that helps us manage our waste from cradle to grave using the waste transfer note.
LADOL have trained emergency response personnel to handle spill. We have spill kits and bunded trays to manage spills. The availability of bun walls that is non – permeable with a control valve to monitor and manage spill or storm water discharging to the environment. Make use of environmentally friendly solution by engaging vendors to install renewable technology for the generating of electrical energy.
To manage the hazards, we conducted training that meets global standards such as meet the Globally Harmonized System for the classification of chemical, CHIP, COSHH Regulations / Dangerous goods movement (IMDG) code. Provision of use of non-permeable bund walls for areas where chemicals are stored. The use of the Dangerous Goods Hand Over Note to communicate the chemicals travelling on board a vessel to the master each time chemical transfer is made. The use of trained emergency response personnel. Provision and use of secondary containment tray and reference to the SDS for handling and storage of the chemicals and use of labelling.
- Measurement of outcomes
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Description of how the company monitors and evaluates environmental performance.
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Rate of occupational diseases and injuries on the low side.
Carbon footprints are reduced and adequately monitored.
Maintaining the biodiversity of our operational base.
- Anti-Corruption
- Assessment, policy and goals
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Description of the relevance of anti-corruption for the company (i.e. anti-corruption risk-assessment). Description of policies, public commitments and company goals on anti-corruption.
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Assessing the risk of corruption when doing business.
Mention “anti-corruption” and/or “ethical behavior” in contracts with business partners.
Ensure that internal procedures support the company’s anti-corruption commitment.
- Implementation
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Description of concrete actions to implement anti-corruption policies, address anti-corruption risks and respond to incidents.
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LADOL recognizes that bribery and corruption are punishable and unacceptable to the Law. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously. There is a company anti-bribery and corruption policy, Fraud and Malpractice Policy and LADOL Code of Business Ethics.
LADOL standard agreements make provisions for anti-corruption or ethical behaviors. For instance, section 15 of our standard MSA provides that parties shall perform their obligations under this Agreement in accordance with Good Industry Practice, including in relation to Combating Bribery in International Business Transactions and any applicable anti-bribery legislation to which they are subject. Thorough Due Diligence is conducted on business partners, and where we are unable to use LADOL standard draft, we ensure that agreements contain the standard provisions in line with best practices.
We conduct legal audit yearly. This audit includes the reviews of the activities of all departments in LADOL and their adherence to regulatory provisions, including the Corrupt Practices & Other Related Offences Act, 2000, Money Laundering (Prohibition) Act, 2022, The Economic & Financial Crimes Commission Establishment Act, 2002, Foreign Corrupt Practices Act 1977, Advance Fee Fraud and other Fraud Related Offences Act 2006, and Public Procurement Act 2007. The LADOL Employee Handbook provides for Ethical Standards. There is also a company policy on Anti-Bribery and Corruption, Fraud and Malpractice Policy and LADOL Code of Business Ethics.
- Measurement of outcomes
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Description of how the company monitors and evaluates anti-corruption performance.
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There have been no incidents of corruption or breach of any anti-corruption or bribery regulations.
All business partners agree to these standards by signing/executing contracts with LADOL.
We have robust internal control measures against anti-corruption. LADOL constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate.
LADOL recognizes that bribery and corruption are punishable and unacceptable. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously. There is a company anti-bribery and corruption policy. A legal Audit was conducted to interrogate compliance with laws, regulations, and best practices on 14th and 15th July 2022.
LADOL standard agreements make provisions for anti-corruption or ethical behaviors. For instance, section 15 of our standard MSA provides that parties shall perform their obligations under this Agreement in accordance with Good Industry Practice, including in relation to Combating Bribery in International Business Transactions and any applicable anti-bribery legislation to which they are subject. Thorough Due Diligence is conducted on business partners.