QDVC sees it as a priority to continuously improve working and living conditions for workers employed by its subcontractors and temporary work agencies.
QDVC’s CSR department discussed workers’ fundamental rights with management as well as with the project, procurement and health and safety teams very early on in the tendering process and throughout the contract execution phase.
The following prerequisites must be fulfilled before awarding a contract to a particular subcontractor:
- - An audit of the accommodation provided to workers employed by the subcontractor and/or the temporary work agencies must be conducted.
- - An audit or at least an assessment questionnaire relating to requirements under Qatari labour laws (administrative management of key HR considerations, such as recruitment conditions, freedom of movement, contracts, working hours, health insurance and access to complaints procedures) must be submitted during the pre-qualification phase.
- - An improvement plan, for both accommodation and labour rights, must be formally submitted, along with a detailed timeline indicating when the subcontractor will be fully compliant.
QDVC reserves the contractual right to conduct accommodation and labour rights audits and assessments in relation to its subcontractors and their lower-tier subcontractors, including their headquarters, premises and workers’ accommodation. Many resources have been allocated to housing inspections or on-site controls through the mobilisation of specifically trained people within various departments (CSR, health and safety, etc.).
| Labour law audit criteria | Worker accommodation audit criteria |
|---|---|
| Recruitment | Housing and drinking water |
| Sponsorship and free movement | Bathrooms and toilets |
| Contracts | Accommodation |
| Wages and benefits | Kitchen and catering |
| Working conditions | Transportation |
| Workers’ representation | Medical care |
| Medical coverage (health insurance) | Construction standards and fire safety |
| Grievance mechanism | Well-being and leisure activities |
Regular follow-up audits help ensure the improvement plan is implemented. When subcontractors do not meet the accommodation standards required by QDVC, they are asked to upgrade or replace their accommodation. Repeated instances of non-compliance with the agreed accommodation and labour rights improvement plan may result in the application of financial penalties, the suspension of payments, contractual restrictions or the termination of the subcontracting agreement, depending on how serious the non-compliance is and how proactive the subcontractor is in addressing it.
QDVC teams conduct follow-up audits to ensure the corrective action plans agreed upon during the pre-qualification phase were being implemented, ensuring subcontractors supported its commitment to continuous, effective and controlled improvement through to the end of their contract.
Subcontractors are also required to make sure that their lower-tier subcontractors comply with QDVC’s standards throughout the subcontracting agreement. QDVC therefore organised tailored special training courses and shared resources with its subcontractors to ensure they had the right tools and knowledge to conduct audits of their own lower-tier subcontractors.
The CSR department developed a functional reporting database to record the subcontractors and temp agencies that work on its projects along with their CSR performance (audit results, incidents or best practice). CSR audit results form part of the criteria used in the annual and final assessments of the performance of the subcontractor agreement.. The subcontractors’ CSR score (which is the average of their final scores for the accommodation audit and labour rights audit) helps determine whether, at the end of the agreement, they should be recommended for future calls for tender. This database enables QDVC to monitor checks on subcontractors’ CSR compliance and establish framework agreements with the subcontractors that have the best CSR practices.
For instance, between 2017 and 2018, a particularly busy period for QDVC, 400 CSR audits were conducted – 35 focusing on workers’ rights and working conditions, and 365 on the accommodation provided by subcontractors and temporary work agencies.
For a single project between 2018 and 2021 (the largest ongoing QDVC project), 114 accommodation audits were carried out during the subcontractor shortlisting phase and 63 thereafter. For this project, all subcontractors were audited in relation to human rights, labour rights and living conditions. Subcontractors had made significant progress between the initial and subsequent audits.
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