To ascertain that its contractors work in compliance with government labor laws and ICL’s requirements, the Company conducts audits carried out by an external auditor engaged by ICL. The process consists of a sample annual contractor compliance examination with the threshold conditions laid out in ICL’s policy appendix.
The appendix also requires the contractor’s auditor to conduct an internal examination of the employment conditions of such contractor’s employees and submit a semi-annual report. The audit is conducted in accordance with standard auditing proceduresto achieve a reasonable degree of confidence that the data presented does not contain any substantive errors.
The Law for Enhanced Enforcement of Labor Laws, which came into effect in 2013, added another layer, complementary to the fair contractor employment enforcement mechanisms already used by ICL.
As part of the Company’s enforcement plan, ICL audits its contractors who are subject to the Enforcement Law, namely cleaning, catering and security contractors. The audit findings, including details regarding the nature of deficiencies, the names of relevant employees, the scale of deficiencies found, and a request to rectify such deficiencies are conveyed in full to the contractor.
During 2014, two different Expansion Orders were signed by the Israeli Ministry of Economy and Ministry of Finance. These Expansion Orders add new employment benefits to contract employees of cleaning and security contractors. Some of these benefits had already been included in the contracts with relevant ICL contractors and are already included in the audits performed. Following these orders, ICL incorporated these new benefits into the existing requirements relating to relevant contractors.
