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Repetition In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on labour inspection, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and 129 (labour inspection in agriculture) together.Article 3(1) of Convention No. 81 and Article 6(1) of Convention No. 129. Functions of labour inspectors in the area of freedom of association. The Committee notes the Government’s indication in its report, in reply to its previous request, that following legislative changes to the Labour Inspection Act LXXV of 1996, the labour inspectorate no longer has any competence in the area of freedom of association. The Committee refers in this respect to its comments under the Right to Organise and Collective Bargaining Convention, 1949 (No. 98), concerning the powers of the Equal Treatment Authority in the area of anti-union discrimination and the request made by the Committee concerning effective enforcement procedures in relation to acts of interference. The Committee requests the Government to provide information on the existing enforcement mechanisms in relation to freedom of association, and the agencies responsible in this area. The Committee also requests the Government to provide statistical information on relevant enforcement activities in practice, including, where applicable, information on the number of inspections, complaints made, subjects covered, and penalties imposed.Articles 4 and 11 of Convention No. 81 and Articles 7 and 15 of Convention No. 129. Organization of the labour inspection services and allocation of sufficient budgetary resources for their effective functioning. The Committee previously noted the reorganization of the labour inspection services under the Ministry for National Economy, including the integration of the labour inspection and occupational safety and health (OSH) units within the metropolitan and district administrative authorities (appointed as regional labour authorities). It notes the Government’s indication that while these units report to, and receive professional guidance from, the Employment Supervision Department and the OSH Department of the Ministry for National Economy, acting as the central labour authority, they receive their material resources (including office space and transport facilities) from the metropolitan and district administrative authorities. The Committee notes the Government’s indication that the required budget for the metropolitan and district administrative authorities is provided annually, but without specifications concerning its allocation. The Committee requests the Government to provide information on how it is ensured that sufficient budgetary resources are allocated for labour inspection units as a result of their integration into the metropolitan and district administrative authorities.Article 5(a) of Convention No. 81 and Article 12 of Convention No. 129. Effective cooperation between the labour inspection services and the justice system. The Committee welcomes the information provided by the Government, in response to its previous request, on the cooperation between the labour inspection services and the judicial authorities, including the publication of judicial decisions on the website of the courts, and the presentation of instructive legal cases on the intranet of the OSH authority.Articles 17 and 18 of Convention No. 81 and Articles 22, 23 and 24 of Convention No. 129. System for the enforcement of administrative penalties. The Committee notes the Government’s indications, in response to the Committee’s request, concerning the enforcement procedure for administrative penalties in relation to labour law violations. The Committee notes the observations made by the workers’ representatives of the Tripartite National ILO Council that the level of penalties and fines which may be applied by the public authorities is insufficient. In this context, the Committee also notes the Government’s indication that pursuant to section 6/A(2) of the Labour Inspection Act, a fine shall not be imposed if the employer pays outstanding wages within the deadline set by the labour inspectorate. In its 2017 General Survey concerning certain occupational safety and health instruments, paragraph 471, the Committee recalled that it is essential for the credibility and effectiveness of regulatory systems that penalties are sufficiently dissuasive and that they are defined in the national legislation in proportion to the nature and gravity of the offence. The Committee requests the Government to indicate how it is ensured that penalties for labour law violations, including in the area of the payment of wages, are sufficiently dissuasive, and are effectively enforced.Articles 20 and 21 of Convention No. 81 and Articles 26 and 27 of Convention No. 129. Annual reports on the activities of the labour inspection services. The Committee notes that while no annual labour inspection reports were submitted, the Government has provided statistical information in its reports under Conventions Nos 81 and 129 on the subjects listed in Article 21(a),(b),(d),(e) and (f) of Convention No. 81 and Article 27(a),(b),(d),(e) and (f) of Convention No. 129. Noting that labour inspection reports have not been received since 2009, the Committee once again requests the Government to regularly publish and communicate to the ILO annual reports on the work of the labour inspection services, in accordance with Article 20 of Convention No. 81 and Article 26 of Convention No. 129, which include information on all the items under Article 21 of Convention No. 81 and Article 27 of Convention No. 129. Issues specifically concerning labour inspection in agricultureArticle 9 of Convention No. 129. Capacities of labour inspectors to carry out effective inspections in the agricultural sector. The Committee notes the Government’s indication, in reply to the Committee’s request, that no specific training on labour matters in the agricultural sector were provided to labour inspectors, as the national labour inspection system covers all economic sectors. The Committee requests the Government to provide information on whether the general training provided to labour inspectors also touches upon issues that are particularly relevant to agriculture, such as the handling of chemicals and pesticides, agricultural machinery, the lifting of heavy weights, etc.
Repetition The Committee notes the observations received on 1 September 2017 from the International Trade Union Confederation (ITUC), which are reflected in the present observation. It also notes the observations of the workers’ group of the National ILO Council at its meeting of 11 September 2017, included in the Government’s report, which relate to issues under examination by the Committee and contain allegations that Act XLII of 2015 resulted in trade unions formerly established in the area of civilian national security not being able to operate properly. The Committee requests the Government to provide its comments in this respect. Freedom of expression. In its previous comments, the Committee had noted with concern that sections 8 and 9 of the 2012 Labour Code prohibit workers from engaging in any conduct, including the exercise of their right to express an opinion – whether during or outside working time – that may jeopardize the employer’s reputation or legitimate economic and organizational interests, and explicitly provide for the possibility to restrict workers’ personal rights in this regard. The Committee had requested the Government to provide detailed information on the results of the “For Employment” project, under which an assessment of the impact of the Labour Code on employers and workers had been undertaken, as well as on the outcome of the consultations on the modification of the Labour Code within the framework of the Permanent Consultation Forum of the Market Sector and the Government (VKF). The Committee had expressed the hope that the review of the Labour Code would fully take into account its comments with respect to the need to take any necessary measures to ensure respect for freedom of expression. The Committee notes that the Government confines itself to indicating that the negotiations in question have not been closed yet. The Committee regrets that no information has been provided by the Government on the outcome of the “For Employment” project (completed in August 2015) or on the consultations undertaken since 2015 within the framework of the VKF with a view to elaborating consensus-based proposals for the review of the Labour Code. The Committee highlights once again the need to take all necessary, including legislative, measures to guarantee that sections 8 and 9 of the Labour Code do not impede the freedom of expression of workers and the exercise of the mandate of trade unions and their leaders to defend the occupational interests of their members, and expects that its comments will be fully taken into account in the framework of the ongoing review of the Labour Code. It requests the Government to provide information on any progress achieved in this respect. Article 2 of the Convention. Registration of trade unions. In its previous comments, the Committee had noted the allegation of the workers’ group of the National ILO Council that numerous rules in the new Civil Code concerning the establishment of trade unions (for example, on trade union headquarters and the verification of its legal usage) obstructed their registration in practice. The Committee had requested the Government to: (i) assess without delay, in consultation with the social partners, the need to simplify the registration requirements, including those relating to union headquarters, as well as the ensuing obligation to bring the trade union by-laws into line with the Civil Code on or before 15 March 2016; and (ii) take the necessary steps to effectively address the difficulties signalled with respect to registration in practice, so as not to hinder the right of workers to establish organizations of their own choosing. The Committee had also requested the Government to provide information on the number of registered organizations and the number of organizations denied or delayed registration (including the grounds for refusal or modification) during the reporting period. The Committee notes the Government’s indication that Act CLXXIX of 2016 on the amendment and acceleration of proceedings regarding the registration of civil society organizations and companies, which entered into force on 1 January 2017, amended the 2011 Association Act, the 2013 Civil Code and the 2011 Civil Organization Registration Act. The legislative amendments were adopted to: (i) simplify the contents of association statutes; (ii) rationalize the court registration and change registration procedures of civil society organizations (court examination limited to compliance with essential legal requirements on number of founders, representative bodies, operation, mandatory content of statutes, legal association objectives, etc.; notices to supply missing information no longer issued on account of minor errors); and (iii) accelerate the registration by courts of civil society organizations (termination of the public prosecutor’s power to control the legality of civil society organizations; maximum time limit for registration). The Committee notes, however, that the ITUC reiterates that trade union registration regulated by the Civil Organization Registration Act is still being subjected to very strict requirements and numerous rules that operate in practice as a means to obstruct the registration of new trade unions, including the stringent requirements on trade union headquarters (unions need to prove that they have the right to use the property), and alleges that in many cases judges refused to register a union because of minor flaws in the application form and forced unions to include the enterprise name in their official names. The Committee further notes that the workers’ group of the National ILO Council states that, when the new Civil Code entered into force, all trade unions had to modify their statutes to be consistent with the law and at the same time report the changes to the courts, and reiterates that these regulations pose a serious administrative burden on trade unions. The Committee observes the persisting divergence between the statements of the Government and the workers’ organizations. The Committee requests the Government to provide its comments on the observations of the ITUC and the workers’ group of the National ILO Council concerning in particular the stringent requirements in relation to union headquarters, the alleged refusal of registration due to minor flaws, the alleged imposition of including the company name in the official name of associations, and the alleged difficulties created or encountered by trade unions because of the obligation to bring their by-laws into line with the Civil Code. The Committee recalls that, although the formalities of registration allow for official recognition of workers’ or employers’ organizations, these formalities should not become an obstacle to the exercise of legitimate trade union activities nor allow for undue discretionary power to deny or delay the establishment of such organizations. Accordingly, the Committee requests the Government to: (i) engage without delay in consultations with the most representative employers’ and workers’ organizations to assess the need to further simplify the registration requirements, including those relating to union headquarters; and (ii) take the necessary measures to effectively address the alleged obstacles to registration in practice, so as not to impede the right of workers to establish organizations of their own choosing. In the absence of the solicited information, the Committee also requests the Government once again to provide information on the number of registered organizations and the number of organizations denied or delayed registration (including the grounds for refusal or modification) during the reporting period. Article 3. Right of workers’ organizations to organize their administration. The Committee notes that the ITUC alleges that trade union activity is severely restricted by the power of national prosecutors to control trade union activities, for instance by reviewing general and ad hoc decisions of unions, conducting inspections directly or through other state bodies, and enjoying free and unlimited access to trade union offices; and further alleges that, in the exercise of these broad capacities, prosecutors questioned several times the lawfulness of trade union operations, requested numerous documents (registration forms, membership records with original membership application forms, minutes of meetings, resolutions, etc.) and, if not satisfied with the unions’ financial reporting, ordered additional reports, thereby overstepping the powers provided by the law. The Committee notes the Government’s indication that, while public prosecutors no longer have the right to control the legality of the establishment of the civil society organizations, they retain the power to control the legality of their operation. The Committee generally recalls that acts as described by the ITUC would be incompatible with the right of workers’ organizations to organize their administration enshrined in Article 3 of the Convention. The Committee requests the Government to provide its comments with respect to the specific ITUC allegations above. Right of workers’ organizations to organize their activities. The Committee had previously noted that: (i) the Strike Act, as amended, states that the degree and condition of the minimum level of service may be established by law, and that, in the absence of such regulation, they shall be agreed upon by the parties during the pre-strike negotiations or, failing such agreement, they shall be determined by final decision of the court; and (ii) excessive minimum levels of service are fixed for passenger transportation public services by Act XLI of 2012 (Passenger Transport Services Act), both at the local and suburban levels (66 per cent) and at national and regional levels (50 per cent); as well as with regard to postal services by Act CLIX of 2012 (Postal Services Act), for the collection and delivery of official documents and other mail. The Committee trusted, in view of the consultations undertaken on the modification of the Strike Act, that due account would be taken of its comments during the legislative review. The Committee notes that the Government refers again to the relevant provisions of the Strike Act (section 4(2) and (3)) and to the Passenger Transport Services Act and Postal Services Act. In the Government’s view, by regulating the extent of sufficient services in respect of two basic services that substantially affect the public and thus creating a pre-clarified situation, the legislature promoted legal certainty in the context of the exercise of the right to strike. The level of sufficient services was determined seeking to resolve the potential tension between the exercisability of the right to strike and the fulfilment of the State’s responsibilities to satisfy public needs. The Government further indicates that negotiations on the amendment of the Strike Act took place in the framework of the VKF throughout 2015 and 2016, in the course of which the trade unions considered that the extent of sufficient services in the passenger transport sector was excessive. The employees’ and employers’ sides managed to agree on a few aspects of the amendment of the Strike Act, but failed to reach an agreement regarding, inter alia, which institution should be authorized to determine the extent of sufficient services in the absence of a legal provision or agreement. Stressing the importance of a compromise of the social partners on the amendment proposals of the Strike Act, the Government adds that, since the trade unions had announced proposals at the end of 2016 but had not submitted them during the first half of the year, no further discussions have taken place in 2017. The Committee further notes that the workers’ group of the National ILO Council reiterates that the strike legislation contains an obligation to provide sufficient service during strike action which in some sectors virtually precludes the exercise of the right to strike (for example by requiring 66 per cent of the service to be provided during the strike and ensuring the feasibility of this rate through extremely complicated rules). The Committee recalls that, since the establishment of a minimum service restricts one of the essential means of pressure available to workers to defend their economic and social interests, workers’ organizations should be able, if they so wish, to participate in establishing the minimum service, together with employers and public authorities; and emphasizes the importance of adopting explicit legislative provisions on the participation of the organizations concerned in the definition of minimum services. Moreover, any disagreement on such services should be resolved by a joint or independent body responsible for examining rapidly and without formalities the difficulties raised by the definition and application of such a minimum service, and empowered to issue enforceable decisions. The Committee further recalls that the minimum service must genuinely and exclusively be a minimum service, that is one which is limited to the operations which are strictly necessary to meet the basic needs of the population or the minimum requirements of the service, while maintaining the effectiveness of the pressure brought to bear; and that, in the past, it has considered that a requirement of 50 per cent of the volume of transportation may considerably restrict the right of transport workers to take industrial action. The Committee therefore once again highlights the need to amend the relevant laws (including the Strike Act, the Passenger Transport Services Act and the Postal Services Act) in order to ensure that the workers’ organizations concerned may participate in the definition of a minimum service and that, where no agreement is possible, the matter is referred to a joint or independent body. The Committee expects that the consultations on the modification of the Strike Act undertaken within the framework of the VKF will continue. It requests the Government to provide up-to-date information on the status or results of the negotiations with particular regard to the manner of determining minimum services and the levels imposed in the postal and passenger transport sectors, and expects that the Committee’s comments will be duly taken into consideration during the legislative review.
Repetition In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on labour inspection, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and 129 (labour inspection in agriculture) together. Article 3(1) and (2) of Convention No. 81 and Article 6(1) and (3) of Convention No. 129. Additional functions entrusted to labour inspectors. The Committee previously noted that combating illegal employment was a priority for labour inspection, and that the labour inspection services were regularly associated in joint inspections to eradicate illegal migration, among others, in cooperation with the police and the custom authorities. In this respect, the Committee notes the Government’s reference to the Labour Inspection Act, which entrusts labour inspectors, among other things, with the control of the work and residence permits of foreign workers, and the notification to the immigration police of any decision concerning the infringement of the provisions on the employment of foreign workers (sections 3(1)(i) and 7/A(7) of the Labour Inspection Act). The Committee once again notes that the Government has not provided the information requested on the role of labour inspectors in granting foreign workers in an irregular situation their due rights resulting from their employment relationship. The Committee recalls that, pursuant to Article 3(1) and (2) of Convention No. 81 and Article 6 of Convention No. 129, the functions of the system of labour inspection shall be to secure the enforcement of the legal provisions relating to conditions of work and the protection of workers while engaged in their work, and any further duties which may be entrusted to labour inspectors shall not be such as to interfere with the effective discharge of their primary duties. In this respect it stated in its 2006 General Survey, Labour inspection, paragraph 78, that any function of verifying the legality of employment should have as its corollary the reinstatement of the statutory rights of all the workers if it is to be compatible with the objective of labour inspection, which is to protect the rights and interests of all workers and to improve their working conditions. In this respect, the Committee also recalls that in its 2017 General Survey on certain occupational safety and health instruments, it indicated that workers in a vulnerable situation may not be willing to cooperate with the labour inspection services if they fear negative consequences as a result of inspection activities, such as the loss of their job or expulsion from the country (paragraph 452) or that their complaint will not be kept confidential. The Committee requests the Government to take measures to ensure that the functions assigned to labour inspectors do not interfere with the main objective of labour inspectors to ensure the protection of workers in accordance with labour inspectors’ primary duties as provided for in Article 3(2) of Convention No. 81 and Article 6(3) of Convention No. 129. It also once again requests the Government to indicate the manner in which the labour inspectorate discharges its primary duties in ensuring the enforcement of employers’ obligations with regard to any statutory rights workers may have in an irregular situation for the period of their effective employment relationship. It urges the Government to provide information on the number of cases in which workers found to be in an irregular situation have been granted their due rights, such as the payment of outstanding wages or social security benefits. In addition, the Committee requests the Government to provide information on the manner in which it ensures that labour inspectors treat as absolutely confidential the source of any complaint bringing to their notice a defect or breach of legal provisions. Articles 10 and 16 of Convention No. 81 and Articles 15 and 21 of Convention No. 129. Number of labour inspectors and effectiveness of the labour inspection system. The Committee previously noted a significant decrease in the number of labour inspectors from 696 to 401 between 2008 and 2013. In this respect, the Committee noted that the comments of the workers’ representatives of the Tripartite National ILO Council (included in the Government’s reports) had indicated that this decrease had compromised the efficiency of inspections as shown by the increase in the number of industrial accidents and violations detected in recent years. On the other hand, the Committee noted the Government’s reply to these comments indicating that the increased number of violations detected was in fact a result of the enhanced efficiency of inspections due to the establishment of labour inspection priorities which were determined by annual labour inspection plans (focused on high risk sectors). The Committee notes with concern from the statistics provided in the Government’s report that the number of labour inspectors continued to decrease to 393 labour inspectors (as of May 2017), and that the number of occupational accidents increased between 2010 and 2016 from 19,948 per year to 23,027. The Committee recalls from its 2017 General Survey on certain occupational safety and health instruments, paragraph 441, that focusing inspections on the most hazardous workplaces must not diminish the overall resource commitment of the labour inspectorate. Noting the significant decline in the number of inspectors since 2008, as well as the increase in the number of occupational accidents reported, the Committee requests the Government to take the necessary measures to ensure that the number of labour inspections are adequate to ensure the effective protection of workers. The Committee requests the Government to continue to provide statistical information on the number of labour inspectors, inspection visits, violations detected and penalties imposed. It also requests the Government to continue to provide information on the number of occupational accidents, and to provide an explanation for their increased number in recent years.
Repetition Article 5 of the Convention. Effective tripartite consultations. In reply to the Committee’s previous comments, the Government indicates that two tripartite seminars were held during the reporting period: a seminar entitled “Lawful and safe employment” in 2016, and a seminar on “The future of work: how do the challenges posed by digitalisation transform the world of work; the ILO standard relating to freedom of association” in 2018. The Committee nevertheless notes that the Government does not provide information regarding tripartite consultations held on the matters related to international labour standards set out in Article 5(1) of the Convention. The Committee therefore reiterates its request that the Government provide detailed information on the content and outcome of tripartite consultations held on all matters concerning international labour standards covered by the Convention, including with respect to: the Government’s replies to questionnaires concerning items on the agenda of the International Labour Conference (Article 5(1)(a)); the proposals to be made to the competent authorities upon the submission of instruments adopted by the Conference (Article 5(1)(b)); the re-examination at appropriate intervals of unratified Conventions and Recommendations to which effect has not yet been given (Article 5(1)(c)); reports to be made on the application of ratified Conventions (Article 5(1)(d)); and proposals for the denunciation of ratified Conventions (Article 5(1)(e)).
Repetition The Committee notes the observations of the workers’ side of the National ILO Council at its meeting of 3 September 2014 included in the Government's report, as well as the Government’s comments thereon. Article 5 of the Convention. Promotion of collective bargaining. The Committee notes that, according to the workers’ side of the National ILO Council, in case of publicly owned employers, the scope of issues that may be regulated by collective agreement is restricted by law. It also notes the Government's indication that the purpose of the limitation introduced for publicly owned employers in respect of entering into a collective agreement is to promote efficient management of assets in public ownership, fulfilment of public functions, prevention of concluding abusive agreements and the protection of public interest; and that parties must therefore observe the peremptory provisions of the Labour Code while regulating working conditions by means of collective agreement. The Committee requests the Government to indicate which subject matters are excluded from the scope of collective bargaining in case of publicly owned employers, specifying the relevant legislative provisions so as to enable the Committee to assess their conformity with the Convention.