Texts of pending comments

The Committee notes that the Government’s report has not been received. It hopes that the next report will contain full information on the matters raised in its previous comments.

Repetition

Article 2(2)(c) of the Convention. Collective agreements. The Committee notes that, in reply to its previous comment, the Government reiterates in its report that, following the ratification of the Convention, the tripartite partners issued a Tripartite Declaration on Equal Remuneration for Men and Women Performing Work of Equal Value, where they recommended that unionized companies adopt the equal pay principle by incorporating a clause on equal remuneration into their collective agreements. The Government also indicates that, according to the National Trade Unions Congress (NTUC), as of 20 December 2018, about one third of all collective agreements in force had equal remuneration clauses applying to all categories of employees covered by the agreement (compared to 26 per cent in 2011). It adds that there were no disputes on equal remuneration clauses so far. The Committee however notes that the Government still does not provide any information on the manner in which such clauses are effectively applied in practice during the wage-setting process at the enterprise level. Recalling the important role that collective agreements can play in the application of the principle of equal remuneration for men and women for work of equal value, the Committee asks the Government to continue to provide information on the progress made in including equal remuneration for work of equal value clauses in collective agreements, further to the Tripartite Declaration issued in this regard. It asks once again the Government to provide summaries of such clauses, as well as specific examples of the manner in which they are applied in practice when wages are set at the enterprise level. The Committee further asks the Government to provide information on any measures taken to raise awareness of the existence of equal remuneration clauses in collective agreements among workers, in particular women workers, as well as on any disputes regarding the application of such clauses that have been dealt with by the courts.

Article 3. Objective job evaluation. The Committee notes the Government’s repeated indication that the Tripartite Alliance for Fair Employment Practices (TAFEP) promotes fair and objective recruitment practices. The Government adds that, as a result of the Skills Framework for Human Resources, human resources professionals will be able to design progressive human resources and practices that reward employees fairly based on ability, performance, contribution and experience. The Committee wishes to draw the Government’s attention to the fact that the concept of “equal value” laid down in the Convention requires some method of measuring and comparing the relative value of different jobs. There needs to be an examination of the respective tasks involved, undertaken on the basis of entirely objective and non-discriminatory criteria to avoid the assessment being tainted by gender bias. While the Convention does not prescribe any specific method for such an examination, Article 3 presupposes the use of appropriate techniques for objective job evaluation, comparing factors such as skill, effort, responsibilities and working conditions (see 2012 General Survey on the fundamental Conventions, paragraph 695). Given the persistent gender wage disparities, the Committee asks the Government to provide information on the concrete measures taken to develop, promote and implement objective job evaluation methods, using criteria that are free from gender bias, such as qualifications and skills, effort, responsibilities and conditions of work, in the public and private sectors.

Enforcement. Recalling that workers can submit a complaint to the TAFEP in case of discrimination at work, the Committee notes the Government’s indication that, so far, the TAFEP has not received any complaints related to pay inequality. In this regard, the Committee wishes to draw the Government’s attention to the fact that where no cases or complaints are being lodged, this is likely to indicate a lack of an appropriate legal framework, a lack of awareness of rights, a lack of confidence in or absence of practical access to procedures, or fear of reprisals (see 2012 General Survey, paragraph 870). In light of the absence of legislation reflecting the principle of the Convention, the Committee asks the Government to provide information on the proactive measures taken, including in collaboration with employers’ and workers’ organizations, to raise public awareness of the principle of the Convention, the procedures and remedies available, as well as on the impact of such measures on the persistent wage disparities between men and women. It also asks the Government to provide information on the number and nature of cases or complaints of gender pay inequality dealt with by the TAFEP, the labour inspectors, the courts or any other competent authority, specifying any sanctions imposed and remedies granted.

The Committee notes that the Government’s report has not been received. It is therefore bound to repeat its previous comments.

Repetition

Articles 1 and 2 of the Convention. Assessing and addressing the gender pay gap. The Committee recalls the lack of legislation requiring equal remuneration for men and women for work of equal value. The Committee previously noted the Guidelines issued by the Tripartite Alliance for Fair Employment Practices (TAFEP) on 3 May 2007, which include a section on remuneration stating that “[e]mployers should pay employees wages commensurate with the value of the job […] regardless of age, gender, race, religion and family status, employees should be paid and rewarded based on their performance, contribution and experience”. It notes, from the TAFEP’s website, that as of September 2019, 7,144 organizations have signed the Employers’ Pledge for Fair Employment Practices, which is a public commitment from employers to create fair and inclusive workplaces according to the TAFEP’s Guidelines. The Committee notes the Government’s statement, in its report that, in July 2017, Tripartite Standards (TSes) were introduced to enhance fair and progressive employment practices on flexible work agreements, recruitment practices and unpaid leave for unexpected care needs. Noting that the TAFEP continued training workshops to assist employers implementing fair and progressive employment practices, the Committee notes the Government’s indication that the Human Capital Partnership (HCP) Programme was launched in 2017 by tripartite partners to “grow an inclusive community of progressive employers”, and will be managed by the TAFEP. The Committee however observes that the Government does not provide information on any measures taken by the TAFEP to promote specifically the principle of equal remuneration for men and women for work of equal value. While noting the Government’s statement that the gender pay gap was estimated at 11.8 per cent in 2017 with broad-based improvement across most occupational groups, the Committee notes, from the statistical information provided by the Government, that in 2017 the median gross monthly salary of women employed in the same occupational category as men was systematically lower than that of men, except for clerical support workers where it was slightly higher. It notes in particular that the gender wage gap was estimated at 12.2 per cent for managers and administrators; 18.7 for working proprietors; 14.4 for professionals and still remains wider for craftsmen and related trades workers (22.3 per cent) and plant and machine operators and assemblers (19.1 per cent). The Committee notes the Government’s indication that the wage gap can be attributed to the fact that women are more likely to exit the workforce or have intermittent patterns of work, for reasons such as childcare and the care of the elderly. The Government adds that its approach to address the gender pay gap is to empower women with choices to stay in the workforce, instead of having to exit it to fulfil caregiving responsibilities. In this regard, the Committee welcomes the adoption and implementation of measures to assist women to enter, re-enter or remain in the workforce, including through flexible working arrangements and the introduction of measures to encourage shared parental responsibilities (such as a two weeks paid paternity leave and the possibility for fathers to share up to four weeks of their wife’s maternity leave). The Committee however notes that, in its 2017 concluding observations, the United Nations (UN) Committee on the Elimination of Discrimination against Women (CEDAW) remained concerned about: (i) the persistent gender wage gap in all occupational categories, except clerical support; (ii) the continued vertical and horizontal occupational segregation in both the public and private sectors; (iii) the persistence of discriminatory stereotypes about the role of women as primary caregivers, including as caregivers of older persons; (iv) the fact that women still remain underrepresented in traditionally male-dominated fields of study, such as engineering, electronics and information technology, at the tertiary level; as well as (v) the underrepresentation of women on corporate boards, notwithstanding their high educational and professional achievements and qualifications. The Committee further notes that the CEDAW recommended that “the Government reduces the gender wage gap by regularly reviewing wages in sectors in which women are concentrated and by establishing effective monitoring and regulatory mechanisms for employment and recruitment to ensure that the principle of equal pay for work of equal value is adhered to in all sectors” (CEDAW/C/SGP/CO/5, 21 November 2017, paragraphs 18, 26, 28 and 29). The Committee notes that the CEDAW, as well as the UN Independent Expert on the enjoyment of all human rights by older persons, also expressed specific concern that older women frequently lack sufficient savings to sustain a living as a result of the gender pay gap, a lack of employment opportunities and their caregiving responsibilities, and are therefore forced to continue to work beyond their retirement age in low-paid and low-skilled occupations (CEDAW/C/SGP/CO/5, 21 November 2017, paragraph 38 and A/HRC/36/48/Add.1, 31 May 2017, paragraphs 27 and 93). In light of the absence of a legislative framework providing for equal remuneration for men and women for work of equal value and the persistence of significant gender wage gaps, in particular in sectors where women are traditionally concentrated, the Committee asks the Government to take proactive measures, including legislative measures in the framework of the Tripartite Alliance for Fair Employment Practices, to establish the principle of the Convention and raise awareness among workers, employers and their respective organizations, as well as among law enforcement officials of the right to equal remuneration for men and women for work of equal value. It also asks the Government to continue to take measures to address the underlying causes of the gender wage gap, such as vertical and occupational gender segregation and stereotypes relating to the aspirations, preferences and abilities of women, including by encouraging girls and women to choose non-traditional fields of study and professions and promoting their access to jobs with career prospects and higher pay. The Committee asks the Government to continue to provide statistical information on the level of earnings of men and women, disaggregated by economic activity and occupational group, both in the public and private sectors.

The Committee is raising other matters in a request addressed directly to the Government.

The Committee hopes that the Government will make every effort to take the necessary action in the near future.

Article 17(2) of the Convention and Part V of the report form. Application in practice. In its previous comment, the Committee requested an explanation on the reported drop in inspections in ports and penalties imposed, between 1995 and 2011. The Committee notes the clarification provided by the Government on the apparent drop in inspections in ports and sanctions imposed between 1995 and 2011, notably that the numbers of inspections cited in the reports of 1996 and 2012 included complementary inspections carried out by different government agencies. The Government adds that the safety and health legislative framework in place under the Workplace Safety and Health (WSH) Act encourages safety and health ownership at all levels. WHS inspectors undertake inspections in relation to the WSH Act. These actions include the analysis of statistics to identify problem areas and hotspots, before designing the interventions. Such an approach may result in fluctuations in inspection numbers in different years. Lastly, the Government indicates that there have been significant improvements in the safety and health records in ports in the past ten years, due to the focus on engagement in workplace safety and health issues. In this regard, the Workplace Safety and Health Council (WSHC) has a Logistics and Transport Committee, comprising of sector leaders, to address specific challenges in ports. The WSHC sets standards and provides resources such as guidelines, case studies, videos and posters, and encourages good practices through capability programmes and awards. The Committee requests the Government to continue providing detailed information on the manner in which the Convention is applied, including any relevant measures from the WSHC in relation to the protection of dockworkers against accidents, relevant reports from the inspection services and details on the number of inspections carried out, the number of violations detected and the nature and causes of accidents recorded.

Prospects for the ratification of the most up-to-date Convention. The Committee encourages the Government to review the decision adopted by the Governing Body at its 328th Session (October–November 2016) approving the recommendations of the Standards Review Mechanism Tripartite Working Group, and to consider ratifying the Occupational Safety and Health (Dock Work) Convention, 1979 (No. 152), which is the most up-to-date instrument in this subject area. The Committee requests the Government to provide information on any measures taken in this regard.

Article 2 of the Convention. Insertion of labour clauses in public contracts. The Committee previously requested the Government to take all appropriate measures to ensure that all public contracts falling within the scope of the Convention are awarded only to enterprises (including any subcontractors) which guarantee to their workers’ wages, hours of work and other conditions of labour not less favourable than those set out in existing collective agreements or generally observed in the same sector or industry by employers in a similar situation. The Committee recalled that, as clarified in paragraph 112 of its 2008 General Survey on labour clauses in public contracts, in those countries where the employment conditions which are laid down in the national legislation constitute both maximum and minimum standards, which may not be exceeded by more favourable collective agreements or arbitration awards, a reference in the public contracts to the relevant provisions of the national legislation would be sufficient for the purpose of giving effect to the Convention. The Committee noted that, therefore, in situations where no arrangements exist for the effective regulation of wages and other employment conditions through collective bargaining, the Convention may not be deemed to require contractors to do more than to merely conform to the national labour legislation. The Committee also requested the Government to transmit copies of the legal text(s) regulating the accreditation and grading systems of cleaning and security services. The Government reports that, in the absence of industry-level collective agreements, contractors and vendors are required to provide their workers with adequate standards equivalent to those established by national laws. It adds that companies engaged under public contracts are required to ensure wages, hours of work, and other conditions of labour that are not less favourable than those established for work of the same character in the trade or industry. The Committee notes with interest the information provided by the Government on additional measures taken (with effect from 31 January 2019) to safeguard the basic employment rights of outsourced workers in the cleaning, security and landscape sectors. It further notes that, as part of the applicable licensing/registration requirements, cleaning, security, and landscape companies must demonstrate that they have a progressive wage structure in place such that the employees concerned receive wages that are commensurate with the higher training, standards and productivity required of them. In addition, to meet licensing and registration requirements, companies must ensure that they have not breached employment laws or defaulted on Employment Claims Tribunal Orders for a specified period of time. The Committee welcomes the copies of the specific instruments regulating the accreditation and grading systems for cleaning and security services communicated by the Government. The Committee welcomes the information provided by the Government and requests that it continue to provide information on the general manner in which the Convention is applied, including, for instance, labour inspection reports, indicating the number of inspections of public administration contracts carried out, the number and type of violations detected and the sanctions imposed, if any. Please also provide information on any practical difficulties encountered in the application of the Convention.

Article 5(1) of the Convention. Effective tripartite consultations. In its previous comments, the Committee requested the Government to continue to provide information on the content and outcome of the tripartite consultations held on each of the matters covered by Article 5(1) of the Convention, particularly in connection with the re-examination of unratified fundamental Conventions and the Employment Policy Convention, 1964 (No. 122), a governance Convention (Article 5(1)(c)). The Government reports that the Singapore Ministry of Manpower (MOM) continues to consult extensively and regularly with the tripartite partners. The Government indicates that, during the period 2014-18, in the context of the annual review of Singapore’s baselines concerning the promotion and realisation of ILO fundamental principles and rights at work, the Singapore National Employers Federation (SNEF) and the Singapore National Trades Union Congress (NTUC) were consulted in relation to the fundamental Conventions not yet ratified by Singapore, and their comments were reflected in the reports submitted to the ILO (Article 5 (1) (c)). The SNEF and the NTUC were also consulted on replies to questionnaires concerning items on the agenda of the International Labour Conference and government comments on proposed texts to be discussed by the Conference (such as those relating to the Employment and Decent Work for Peace and Resilience Recommendation, 2017 (No. 205) and the Violence at Work Convention (No. 190) and Recommendation (No. 206), 2019 (Article 5 (1) (a)), as well as in relation to Article 19 and 22 reports (Article 5(1)(b) and (d)); and on proposals for the denunciation of ratified Conventions (Article 5(1) (e)). The Committee notes that, in 2018, the tripartite partners met twice to discuss the matters specified under Article 5 of the Convention. With regard to the re-examination of unratified Conventions, the Government indicates that in 2018 the tripartite partners discussed the possibility of re-ratifying the Abolition of Forced Labour Convention, 1957 (No. 105). The Government indicates that progress had been made in addressing forced labour as illustrated by the 2014 amendments to the Prisons Act, but that it would take some time to bring its entire legislative framework into full compliance with Convention No. 105. The Government reports that the NTUC expressed the view that Singapore should work toward the re-ratification of Convention No. 105 as soon as possible. Regarding Convention No. 122, the Government indicates that it has active labour market policies in place and provides information on a series of initiatives aimed at job creation and skills upgrading; however, it does not provide specific information on tripartite consultations relating to Convention No. 122. The Committee reiterates its request that the Government provide detailed and precise information on the content, frequency and outcome of tripartite consultations held on all matters relating to international labour standards covered by the Convention and other activities of the ILO, including consultations on the re-examination of unratified fundamental Conventions, as well as on Convention No. 122, a priority governance Convention (Article 5(1)(c)).

In the context of the global COVID-19 pandemic, the Committee recalls the comprehensive guidance provided by international labour standards. It encourages the Government to engage in tripartite consultation and social dialogue more broadly as a solid foundation for developing and implementing effective responses to the profound socio-economic impacts of the pandemic. The Committee invites the Government to continue to provide updated information in its next report on the impact of the measures taken in this respect, in accordance with Article 4 of the Convention and Paragraphs 3 and 4 of Recommendation No. 152, including with regard to steps taken to reinforce the capacity of the tripartite constituents and strengthen mechanisms and procedures, as well as challenges and good practices identified.

Articles 1(1), 2(1) and 25 of the Convention. 1. Trafficking in persons. Noting that the national plan of action for 2012–15, developed by the Inter-Agency Taskforce on Trafficking in Persons, provided for a review of all legislation related to trafficking in persons, the Committee requested the Government to pursue its efforts to strengthen the legal framework to combat trafficking. The Committee also requested the Government to provide information on the measures taken to prevent, suppress and combat trafficking in persons, and on the steps taken to assist and protect victims.

The Committee notes with interest the adoption of the Prevention of Human Trafficking Act 2014 (PHTA) in November 2014, which prohibits trafficking in persons and contains provisions regarding protection and assistance to victims of trafficking. The Government indicates that, under this Act, perpetrators are liable to imprisonment of up to ten years and to a fine for the first offence. The Committee further notes that, in the case of a second or subsequent offence, perpetrators are liable to imprisonment for a term not exceeding 15 years and to a fine (section 4). The Government indicates that from the enactment of the PHTA, on 1 March 2015, to the end of November 2018, there have been ten cases charged under this Act, out of which four have resulted in convictions for trafficking for sexual exploitation. Penalties included imprisonment ranging from 38 to 80 months, and fines. The other six cases are currently undergoing court proceedings; half involve trafficking for sexual exploitation and the other half involve trafficking for labour exploitation.

The Committee also notes the Government’s indication that the Inter-Agency Taskforce on Trafficking in Persons launched the National Approach against Trafficking in Persons (2016-2026), following the National Plan of Action against Trafficking in Persons (2012–15). The National Approach against Trafficking in Persons aims at: (i) preventing trafficking in persons, through public awareness raising and training of relevant stakeholders in identifying and dealing with trafficking in persons cases; (ii) comprehensively investigating and prosecuting all offenders who may be involved in trafficking or in the exploitation of victims; (iii) appropriately protecting and supporting all victims of trafficking; and (iv) developing domestic and international partnerships. The Government indicates that it works closely with civil society organisations to provide support services to victims of trafficking in persons and potential victims. The Committee notes that, in its concluding observations of 21 November 2017, the Committee on the Elimination of Discrimination against Women (CEDAW) remained concerned that Singapore continues to be a destination and transit country for trafficking in women and girls for purposes of sexual and labour exploitation and at the lack of access to sufficient measures of support and protection for victims of trafficking (CEDAW/C/SGP/CO/5, paragraph 22). The Committee welcomes the comprehensive measures taken to combat trafficking in persons, and encourages the Government to continue to provide information on the application of the PHTA in practice, including the number of investigations, prosecutions, convictions and to specify the penalties imposed. The Committee requests the Government to indicate the manner in which the desired outcomes of the National Approach against Trafficking in persons 2016-2026 have been implemented and their impact in preventing trafficking in persons in practice. Lastly, the Committee requests the Government to provide information on the number of victims of trafficking who have benefitted from protection and assistance.

2. Vulnerable situation of migrant domestic workers with regard to the exaction of forced labour. The Committee notes that the Employment of Foreign Manpower (work passes) Regulations 2012 provides that foreign employees who are issued with a work permit shall work only in the occupation and sector and for the employer specified in the work permit (Fourth Schedule, Part VI, paragraph 1). The Committee thus notes that migrant workers have a legal status tied to a particular employer, which has sponsored the worker. According to the information available on the website of the Ministry of Manpower, there were 972,600 migrant workers benefiting from a work permit in Singapore in December 2018, out of which 253,800 were migrant domestic workers. The Ministry of Manpower also indicates that every employer has to pay a security bond of up to 5,000 Singaporean dollars for each foreign domestic worker hired, which may be forfeited if the worker violates any of the conditions of the work permit or if he/she goes missing.

The Committee further notes that the CEDAW, in its concluding observations of 21 November 2017, was concerned at ongoing allegations related to the exploitation and abuse of female domestic workers by their employers, including non-payment of salaries, deprivation of food and adequate rest, confiscation of passports, restrictions on freedom of movement and sexual, physical, verbal and psychological abuse (CEDAW/C/SGP/CO/5, paragraph 34). Recalling the importance of taking effective action to ensure that the rules governing the employment scheme for migrant workers do not place the workers concerned in a situation of increased vulnerability, the Committee requests the Government to provide information on the measures taken to ensure that migrant domestic workers are fully protected from abusive practices and conditions that could amount to the exaction of forced labour. The Committee also requests the Government to provide information on the existing measures allowing migrant domestic workers victims of abusive practices to assert their rights effectively and to be protected.

Articles 1(1) and 2(1) of the Convention. Work exacted from destitute persons in welfare homes. The Committee previously noted that, according to the Destitute Persons Act, 1989, destitute persons may be required, subject to penal sanctions, to reside in a welfare home (sections 3 and 16) and to engage in any suitable work for which the medical officer of the home certifies them to be capable (section 13). It noted the Government’s statement that the work skills programme, which aims at providing residents with skills for independent living, requires written consent from the residents who are willing to work and that residents receive an allowance or income for the work performed. The Committee accordingly encouraged the Government to bring section 13 of the Destitute Persons Act into line with both the indicated practice and the Convention.

The Government reiterates its statement, in its report, that welfare home residents have to be certified medically fit for work and have to provide their consent before being placed on work schemes. The Committee takes due note of the copies of signed documents indicating the consent to work of the residents of welfare homes, communicated by the Government along with its report. In this regard, the Government indicates that regular audits are made by Ministry of Social and Family Development staff including the review of samples of the signed consent forms and the interview of some residents, to understand any concerns that they may have regarding their treatment in welfare homes. Accordingly, the Committee requests the Government to indicate any measures taken to align section 13 of the Destitute Persons Act with both the Convention and the indicated practice, according to which the residents express their consent to perform work.

Legislation. The Committee notes the information provided by the Government, in response to its previous request, concerning amendments to the Central Provident Fund Act (CPFA), the Employment Act (EA), and the Workplace Safety and Health Act (WSHA). The Government also provided information on the WorkRight Initiative, under which more than 28,000 proactive workplace inspections have been conducted since 2012, aimed at educating employers on employment laws and ensuring that they fulfil their responsibilities towards their employees, including migrant workers. The WorkRight Initiative also includes outreach activities aimed especially at vulnerable low-wage workers; the Government indicates that its “roadshows” have attracted over 100,000 individuals, including migrant workers, since 2012. The Committee notes this information.

Article 3(2) of the Convention. Additional functions entrusted to labour inspectors. The Committee notes the Government’s indication, in reply to its previous request, that the Ministry of Manpower (MoM) enforces employers’ statutory obligations to all migrant workers, regardless of their legal status. The Government states that the MoM educates all migrant workers to approach it if they do not receive their statutory benefits. The Government states that labour inspectors carry out controls of irregular work and employers’ obligations under the Employment of Foreign Manpower Act (EFMA). In 2017, over 2,300 inspections focused on compliance with the EFMA (compared with 5,000 inspections under the WorkRight initiative and 6,000 OSH inspections), which resulted in approximately 300 prosecutions for the EFMA offences and the imposition of over 1,000 compositions or financial penalties. The Committee requests the Government to provide information on specific actions undertaken by the MoM to ensure the enforcement of the statutory rights of migrant workers found to be in an irregular situation under the terms of the EFMA. It also asks 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, social security benefits, or the conclusion of an employment contract, including cases where the workers in question have left the country or are liable to expulsion..

Articles 4, 6 and 7 of the Convention. Supervision and control of the central authority. Recruitment and qualifications of labour inspectors. In its previous comments, the Committee noted that following the extension of the WSHA to all workplaces, the Government engaged the Auxiliary Enforcement Agency (AEA), with a view to extending the enforcement efforts of the MoM. It requested the Government to provide detailed information on the legal basis on which the AEA operates, the administrative organization, as well as the manner in which the AEA reports to, and is supervised by, the central labour inspection authority. The Committee notes the Government’s indication in response that the team of 20 inspectors from the AEA, who are gazetted under the WSHA, conducts approximately 12,000 inspections per year. This complements the MoM’s existing enforcement resources and maintains enforcement oversight on lower-risk workplaces. AEA officers focus on basic compliance with the WSHA such as the implementation of risk management as well as targeted operations including forklift management. AEA inspectors are required to follow up with rectification actions or bring the non-compliant workplaces to the MoM for enforcement action to be taken. In this respect, the Committee notes that the 12,000 inspections conducted in 2017 by the AEA were comparable in number to the 13,300 inspections conducted by labour inspectors under the statutory provisions and initiatives described above. The Committee further notes that pursuant to section 7 of the WSHA, inspectors for workplace safety and health shall be appointed by the Commissioner for Workplace Safety and Health. Recalling that Article 4 of Convention No. 81 requires placing labour inspection under the supervision and control of a central authority, the Committee requests the Government to provide further information on the manner in which the AEA reports to and is supervised by the central labour inspection authority, including the manner in which its inspection activities are coordinated with OSH inspection activities of the MoM. It also requests the Government to provide an organizational chart of the labour inspection system. In addition, recalling that, under Article 6 of the Convention, labour inspection staff shall be composed of public officials whose status and conditions of service are such that they are assured of stability of employment and are independent of improper external influences, the Committee requests the Government to provide information on the status and conditions of service of inspectors of the AEA and to indicate whether AEA inspectors are appointed in accordance with section 7 of the WSHA.

Article 7(3). Training for labour inspectors. The Committee takes note of the information provided by the Government, in reply to its previous request, that the MoM provides both initial and continuing training for inspectors. This includes a foundation programme as well as on-the-job training for new inspectors. The Government further indicates that specialist inspectors in the areas of WSHA undergo training in specific areas such as pressure vessel safety, crane safety, and occupational hygiene. The Committee notes this information.

Article 12(1). Investigation powers and the right of free access of labour inspectors to workplaces. The Committee previously noted the Government’s intention to empower labour inspectors under the EA to enter workplaces without previous notice through legislative changes. The Committee takes note of section 103(1)(aa) of the EA that empowers the Commissioner or any inspecting officer to enter without previous notice at any reasonable time any place of employment for the purpose of conducting any audit in relation to the terms and conditions of employment of any employee. Recalling that pursuant to Article 12(1)(a) labour inspectors with proper credentials shall be empowered to enter workplaces liable to inspection at any hour of the day or night, the Committee requests the Government to provide information on the implementation of section 103(1)(aa) in practice, including the proportion of unannounced inspections in relation to total labour inspections under the different statutory provisions.

Articles 20 and 21. Publication and content of an annual labour inspection report. The Committee notes the Government’s reference, in response to its previous request concerning the publication of annual labour inspection report, to the MoM and the Gazette websites. The Committee observes that these websites do not appear to contain statistics related to the labour inspection system and its activities. However, it takes due note of the Government’s indication that it will continue to consider publishing an annual report. The Committee requests the Government to pursue its efforts to publish and transmit to the ILO an annual labour inspection report, which covers all the subjects listed in Article 21 (a)–(g) of the Convention.

Legislative developments. The Committee takes note of the Government’s indication that the Industrial Relations Act (IRA), which provides for the regulation of the relations of employers and employees and the prevention and settlement of trade disputes by collective bargaining, conciliation, arbitration and tripartite mediation of individual disputes, was amended in 2015. The Committee notes that, as a result of the amendment, rank-and-file trade unions are now allowed to represent the executive employees on a collective basis. The Committee requests the Government to provide information on the practical impact that this amendment has had on the application of the Convention and in the conclusion of collective agreements.

Application of the Convention in practice. The Committee requests the Government to provide information on the number of collective agreements in force, the sectors concerned and the percentage of workers covered.

The Committee notes the information provided by the Government, which answers the points raised in its previous direct request and has no further matters to raise in this regard.

The Committee notes the Government’s second report on the application of the Maritime Labour Convention, 2006, as amended (MLC, 2006). The Committee notes that the amendments to the Code approved by the International Labour Conference in 2014 and 2016 entered into force for Singapore on 18 January 2017 and 8 January 2019, respectively. It further notes that the Government’s report was received before the entry into force of these amendments. Following a second review of the information and documents available, the Committee draws the Government’s attention to the following issues.

Article II, paragraphs 1(f), 2 and 3. Seafarers. In its previous comments, the Committee noted the definition of seafarer in section 2 of the Merchant Shipping (Maritime Labour Convention) Act 2014 (hereinafter, “MLC Act”). It further noted that pursuant to paragraph 2 of the Merchant Shipping (Maritime Labour Convention) (Definition of Seafarer) Order 2014, certain categories of persons are not regarded as seafarers. Noting that in accordance with the wording of paragraph 2 of the Schedule a person could be working on board a ship for periods of up to 45 consecutive days and up to an aggregate of four months per year on one ship, followed by similar periods working on board other ships, without being considered a seafarer, the Committee requested the Government to provide clarifications on this issue. The Committee notes the Government’s indication that all cases of exclusion of the definition of seafarer must fall within all statutory limits and be submitted to the Director of Marine for approval. The Government further indicates that, since the Convention came into force, the Maritime and Port Authority of Singapore (MPA) has never granted any exclusion to any persons under paragraph 2 of the Merchant Shipping (Maritime Labour Convention) (Definition of Seafarer) Order 2014. The Committee further note the detailed explanations on the consultations process conducted in the framework of the Tripartite Working Group regarding all aspects of implementation of the Convention. The Committee requests the Government to provide information with respect to any exclusion granted in the future under paragraph 2 of the Merchant Shipping (Maritime Labour Convention) (Definition of Seafarer) Order 2014.

Article II, paragraph 6. Ships. In its previous comments, the Committee noted that under section 4(1)–(3) of the MLC Act, the MPA may determine that it is not reasonable or practicable to apply any provision of the Act or regulations made under the Act to a Singapore ship of less than 200 gross tonnage not engaged in international voyages and in making such an exemption, the Authority may also impose conditions on the ship or particular categories of ships including those set out in any other laws or in a term of a seafarer’s employment agreement (SEA) or of a collective agreement or in other measures in lieu of any provision of the Act. The Committee had requested the Government to provide information concerning the recourse to this possibility. The Committee notes the Government’s indication that no exemptions have been granted so far, and that in case an exemption is granted, the ships concerned need to comply with Singapore’s port and harbour craft regulations as well as Singapore’s Employment Act. The Committee recalls that Article II, paragraph 6, of the Convention, provides flexibility with respect to the application of “certain details of the Code” to ships of less than 200 gross tonnage that do not voyage internationally, if determined that it would not be reasonable or practicable at the time of the exemption to apply certain details of the Code. The Committee requests the Government to provide detailed information on measures currently adopted, or envisaged, in accordance with section 4(1)–(3) of the MLC Act in order to ensure that any exemption granted is limited to certain details of the Code as required by Article II, paragraph 6, of the Convention.

The Committee had noted that sections 53(12) and 80 of the MLC Act provide that the Director of Marine may grant ships dispensation of requirements in specific circumstances and had requested information on the use of this possibility. The Committee notes the Government’s indication that these powers to grant exemptions are to be exercised by the Director of Marine only when absolutely necessary, and that the legislative and policy intent behind such exemption provisions are to allow the administration the necessary flexibility to deal with extreme circumstances, such as force majeure. It also notes the Government’s indication that no exemptions have been granted under sections 53(12) and 80 of the MLC Act since the Convention came into force. Bearing in mind that under the MLC, 2006, exemptions are possible to a limited extent and only where they are expressly permitted by the Convention, the Committee requests the Government to provide information on any exemption granted in the future under sections 53(12) and 80 of the MLC Act.

Regulation 1.4 and the Code. Recruitment and placement services. The Committee notes that section 15 of the Merchant Shipping (Maritime Labour Convention) (Seafarer Recruitment and Placement Services) Regulations 2014, requires recruitment and placement services to establish “a system of protection, by way of insurance or an equivalent appropriate measure, to compensate seafarers for monetary loss that they may incur as a result of the failure of a recruitment and placement service or the relevant shipowner under the seafarer’s employment agreement to meet its obligations to them”. The Committee requests the Government to provide detailed information with respect to the system of protection that is required under Section 15 of the Merchant Shipping (Maritime Labour Convention) (Seafarer Recruitment and Placement Services) Regulations 2014, and its conformity with Regulation 1.4 and Standard A1.4, paragraph 5(vi), of the Convention.

Regulation 2.2 and the Code. Wages. The Committee notes that section 20, paragraph 1 of the MLC Act requires wage payments to be made in full and on a monthly basis “except as otherwise provided in this Act or any other written law”. It also notes that section 20(6) and (7) of the MLC Act provides for any adjustment to the amount stated in the account of the seafarer, without, however, providing for grounds on which such adjustment is made or for the seafarer’s right to request explanations. Recalling that Standard A2.2, paragraph 1, of the Convention provides that each Member shall require that payments due to seafarers working on ships that fly its flag are made at no greater than monthly intervals and in accordance with any applicable collective agreement, the Committee requests the Government to provide full information with respect to the exceptions provided under section 20, paragraph 1, of the MLC Act. It further requests the Government to clarify the grounds for adjustment of wages provided for under section 20, paragraphs 6 and 7, of the MLC Act.

Regulation 2.3 and the Code. Hours of work and hours of rest. In its previous comment, noting that section 16(9) of the MLC Act provides that the Director may make exceptions to the minimum hours of rest with conditions and that the Declaration of Maritime Labour Compliance (DMLC), Part I, states, in connection with hours of rest, that: “Provisions in a collective agreement or any other agreement between a seafarer and shipowner may set out exceptions” from the required hours of rest, the Committee had requested the Government to provide information clarifying the use of these possible exceptions. The Committee notes the Government’s indication that Singapore ships not subject to collective agreements may encounter situations where exceptions to the hours of work and hours of rest are required for certain circumstances, such as during rough weather situations or an unexpected work requirement to safeguard the safety and security of the ship. These exceptions must be documented in an agreement made between the shipowner and the seafarer, and must be registered with the Director of Marine. The Government further indicates that, as stated in section 6(2) of the DMLC, Part I, any exceptions to the hours of work and hours of rest must fulfil the requirements of the 2010 Manila Amendments to the International Convention on Standards of Training, Certification and Watch keeping for Seafarers (STCW). The Committee recalls that pursuant to Standard A2.3, paragraph 14, the master of a ship has a right to require a seafarer to perform any hours of work necessary for the immediate safety of the ship, persons on board or cargo, or for the purpose of giving assistance to other ships or persons in distress at sea. All other exceptions to the minimum hours of rest shall, in accordance with Standard A2.3, paragraph 13, be provided in a collective agreement. The Convention however does not envisage exceptions being made in agreements between a shipowner and a seafarer. The Committee requests the Government to indicate the measures taken to ensure that all possible exceptions to the minimum hours of rest are allowed in full compliance with the Convention.

The Committee also notes that section 16(8) of the MLC Act provides that a seafarer shall be given a record of his/her daily hours of rest that has been endorsed by the master or his/her representative. Recalling that Standard A2.3, paragraph 12, of the Convention provides that a copy of the records of seafarer’s daily hours of work or rest has to be endorsed both by the master and the seafarer, the Committee requests the Government to provide information on how it is ensured full compliance with this requirement of the Convention.

Regulation 2.4, paragraph 2. Entitlement to leave. Shore leave. Noting that section 22, paragraph 4(c) of the MLC Act, provides that temporary shore leave by agreement between the shipowner and the seafarer under the seafarer’s employment agreement (SEA) is not counted as part of seafarer’s annual leave, the Committee had requested the Government to provide information as to whether seafarers on ships flying Singapore’s flag are given shore leave in accordance with Standard A2.4, paragraph 2 of the MLC, 2006, even when such leave is not provided for in the SEA. The Committee notes with interest that the MPA Shipping Circular to Shipowners No. 4 of 2017/Rev.1 has revised the DMLC, Part I, on this point and now requires shipowners to provide seafarers on ships flying Singapore’s flag with shore leave even when such leave is not provided for in the seafarer’s employment agreement. The Committee takes note of this information.

Regulation 2.4 and Standard A2.4, Paragraph 3. Entitlement to leave. Prohibition of agreements to forgo annual leave. The Committee notes that section 14(8) of the MLC Act provides that any term in an employment agreement to forgo any part of the minimum annual leave prescribed under section 22 of the Act shall be unenforceable in so far as it purports to deprive the seafarer of that right or to remove or reduce the liability of the shipowner to grant the minimum annual leave except under such circumstances as may be prescribed by the Authority. The Committee requests the Government to indicate if the competent authority has prescribed any circumstances under which a part of the minimum annual leave can be forgone.

Regulation 2.5 and Standard A2.5.2. Repatriation. Financial security. Abandonment. In relation to the 2014 amendments to the Code of the Convention, the Committee recalls that, pursuant to Standard A2.5.2, the Government shall ensure the provision of an expeditious and effective financial security system to assist seafarers in case of their abandonment. The Committee brings the Government’s attention to the following questions included in the revised report form for the Convention: (a) does national legislation require the provision of an expeditious and effective financial security system to assist seafarers in the event of their abandonment (if yes, specify if the financial security system was determined after consultation with the shipowners’ and seafarers’ organizations concerned); (b) has your country received requests to facilitate repatriation of a seafarer and, if yes, how did your country respond; (c) what are the circumstances under which a seafarer is considered abandoned according to national legislation; (d) does national legislation provide that ships that need to be certified according to Regulation 5.1.3 must carry on board a certificate or other documentary evidence of financial security issued by the financial security provider (if yes, specify if the certificate or other documentary evidence must contain the information required by Appendix A2-I and has to be in English or accompanied by an English translation, and if a copy must be posted in a conspicuous place on board); (e) does national legislation require that the financial security system is sufficient to cover outstanding wages and other entitlements, all expenses incurred by the seafarer (including the cost of repatriation), and the essential needs of the seafarers, as defined in Standard A2.5.2, paragraph 9; and (f) does national legislation provide for at least 30 days of notice by the financial security provider to the competent authority of the flag State before the financial security can cease? The Committee requests the Government to reply to the above-mentioned questions, indicating in each case the applicable national provisions. The Committee also requests the Government to provide a copy of a model certificate or other documentary evidence of financial security containing the information required in Appendix A2-I of the Convention (Standard A2.5.2, paragraph 7).

Regulation 2.7 and the Code. Manning levels. The Committee notes the information provided by the Government concerning its manning requirements. It notes, in this respect, that the requirements on manning composition do not take into account the ship’s cook or catering staff. It recalls that, under Standard A2.7, paragraph 3, the competent authority must take into account all the requirements within Regulation 3.2 and Standard A3.2 concerning food and catering. The Committee requests the Government to explain how it implements this provision of the Convention.

Regulation 3.1 and the Code. Accommodation and recreational facilities. Noting that section 3(4) of the Merchant Shipping (Crew Accommodation) Regulations (hereinafter, “Crew Accommodation Regulations”) authorizes the Director of Marine to exempt any ship from any provision of the Crew Accommodation Regulations, the Committee had requested the Government to explain how it is ensured that any such exemption may only be made within the limitations provided for under Standard A3.1. The Committee notes the Government’s indication that the Director of Marine has not authorized any exemptions in accordance with section 3(4) of the Crew Accommodation Regulations. Noting however that this provision confers wide-ranging authority on the Director of Marine to grant exemptions, the Committee requests the Government to adopt the necessary measures to ensure that the Crew Accommodation Regulations fully comply with Standard A3.1, paragraph 21. The Government further indicates that, based on the Committee’s previous remarks, the MPA, in consultation with the Singapore shipowners’ and seafarers’ organizations through the Tripartite Working Group, is in the process of reviewing the following provisions of section 10 of the Crew Accommodation Regulations: section 10(6)(a) to fully comply with Standard A3.1, paragraph 6(a), of the Convention, and section 10(5)(e) and 10(10) to be in accordance with Standard A3.1, paragraphs 9(i) and 9(j). The Committee requests the Government to provide the amended text of the Crew Accommodation Regulations once adopted.

Regulation 4.1 and the Code. Medical care ashore. The Committee notes the Government’s indication that seafarers on board ships voyaging in Singapore waters or visiting its ports are given access to medical facilities on shore when in need of immediate medical or dental care (Regulation 4.1, paragraph 3), subject to certain conditions where necessary for security and health reasons. The Committee requests the Government to provide information on the conditions that may be imposed on foreign seafarers to get access to medical care ashore.

Regulation 4.2 and Standards A4.2.1, paragraphs 8–14, and A4.2.2. Shipowners’ liability. Financial security. In relation to the 2014 amendments to the Code of the Convention, the Committee recalls that pursuant to Standards A4.2.1 and A4.2.2, national laws and regulations shall provide that the financial security system to assure compensation in the event of the death or long-term disability of seafarers due to an occupational injury, illness or hazard meet certain minimum requirements. The Committee brings the Government’s attention to the following questions included in the revised report form for the Convention: (a) what is the form taken by the system of financial security and was it determined after consultation with the shipowners’ and seafarers’ organizations concerned?; (b) how national laws and regulations ensure that the system of financial security meets the following minimum requirements: (i) payment of compensation in full and without delay; (ii) no pressure to accept payment less than the contractual amount; (iii) interim payments (while situation is being assessed) to avoid undue hardship; (iv) offsetting payment against any damages resulting from any other claim made by the seafarer against the shipowner and arising from the same incident; and (v) persons who can bring the claim for contractual compensation (seafarer, her/his next of kin, representative or designated beneficiary)?; (c) does national legislation provide that ships must carry on board a certificate or other documentary evidence of financial security issued by the financial security provider? (if yes, specify if the certificate or other documentary evidence has to contain the information required in Appendix A4-I, be in English or accompanied by an English translation, and if a copy must be posted in a conspicuous place on board); (d) does national legislation provide: (i) for at least 30 days of notice by the financial security provider to the competent authority of the flag State before the financial security can cease; (ii) that the competent authority is notified by the financial security provider if a shipowner’s financial security is cancelled or terminated; and (iii) that seafarers receive prior notification if a shipowner’s financial security is to be cancelled or terminated?; and (e) how does national legislation ensure that effective arrangements are in place to receive, deal with and impartially settle contractual claims relating to compensation in the event of the death or long-term disability of seafarers due to an occupational injury, illness or hazard, through expeditious and fair procedures? The Committee requests the Government to reply to the above-mentioned questions, indicating in each case the applicable national provisions. The Committee also requests the Government to provide a copy of a model certificate or other documentary evidence of financial security containing the information required in Appendix A4-I of the Convention (Standard A4.2.1, paragraph 14).

Regulation 4.3 and the Code. Health and safety protection and accident prevention. The Committee had requested the Government to provide information with respect to any national guidelines or other measures adopted to assist in the implementation of the health and safety requirements of the Convention. The Committee notes the Government’s indication that the MPA has issued several shipping circulars to assist in the implementation of the provisions of section 40 of the MLC Act and the Merchant Shipping (Maritime Labour Convention) (Health and Safety Protection and Accident Prevention) Regulations 2014, (hereinafter “OSH Regulations”) on board ships. The Committee requests the Government to provide a copy of the shipping circulars mentioned in its report. The Committee also notes the Government’s explanation in response to its previous request on how section 43 of the OSH Regulations providing for the establishment of a safety committee is applied. The Committee takes note of this information.

Regulation 4.4 and the Code. Access to shore-based welfare facilities. The Committee notes with interest the information provided by the Government, in reply to its previous comments, on activities of seafarers’ shore-based welfare facilities and services. It also notes that a Welfare Committee for Seamen has been set up. The Committee takes note of this information.

Regulation 4.5 and the Code. Social security. The Committee had requested the Government to indicate whether seafarers ordinarily resident in Singapore working on ships flying the flag of another country are provided with social security protection as required under Regulation 4.5 and the Code. The Committee notes the Government’s indication that Singaporean citizens and permanent residents are included in the mandatory national security fund. It further notes that the Central Provident Fund Act and other welfare schemes apply to Singaporean seafarers working on foreign-flagged vessels. The Committee takes note of this information which address its previous request.

The Committee recalls that according to the Convention, Members shall give consideration to the various ways in which “comparable benefits” to those provided to seafarers ordinarily resident in the country can be provided to seafarers working on board the ships flying their flag, in the absence of adequate coverage (Standard A4.5, paragraph 6, of the Convention). The Committee requests the Government to provide information regarding the implementation of this requirement of the Convention.

Regulation 5.1.4 and Standard A5.1.4, paragraph 4. Flag State responsibilities. Inspection and enforcement. Intervals of inspection. In its previous comments, the Committee had requested the Government to provide information with respect to flag State inspection of Singapore flagged ships that are not required to carry a Maritime Labour Certificate or DMLC. The Committee notes the Government’s indication in this regard that the MPA’s flag State inspectors verify compliance with the MLC, 2006, by Singapore ships that are not required to be certified. The Government provides an example of the MLC, 2006, certification procedures and inspection (MAR-MMS-GL035) which refers to inspection when no certification is required. The Committee notes, however, that the intervals at which inspections have to be carried out are not addressed in this document nor in other existing regulations. The Committee requests the Government to indicate the measures taken to ensure that the interval between inspections for Singaporean ships that are not required to carry a Maritime Labour Certificate or DMLC does not exceed three years, as required by Standard A5.1.4.

Regulation 5.1.4 and Standard A5.1.4, paragraph 10. Flag State responsibilities. Inspection and enforcement. Confidentiality of sources of grievances or complaints. In its previous comments, the Committee requested the Government to provide information as to the procedures it has established with respect to receiving and investigating complaints regarding ships that fly its flag, and in particular as to the procedures for ensuring confidentiality. The Committee notes the Government’s reference to a standard operating procedure for the handling of crew complaints set up by MPA. The Committee notes however that this procedure is of a general nature and does not include any specific measures to ensure confidentiality. The Committee requests the Government to indicate any additional measures adopted to ensure that the procedures to receive and investigate complaints regarding ships that fly its flag, including the procedures for ensuring that the source is kept confidential, fully comply with the requirements of the Convention (Standard A5.1.4, paragraphs 5, 10 and 11(b)).

Regulation 5.1.5 and Standard A5.1.5, paragraph 3. Flag State responsibilities. On-board complaint procedures. Victimization. In its previous comments, the Committee noted that section 55(2)(c) of the MLC Act requires that on-board complaint procedures include adequate safeguards to ensure that the rights of the seafarers are not prejudiced by the making of complaints. Paragraph 5 of the model format for on-board complaint procedures contained in Shipping Circular No. 6 of 2013, requires the shipowner to put in place measures to safeguard against possible victimization for filing a complaint. The Committee notes the Government’s indication that MPA takes guidance from Singapore’s national tripartite guidelines, in particular the Tripartite Alliance for Fair and Progressive Employment Practices (TAFEP), which has in place a set of guidelines on “Grievance Handling”. However, these requirements remain general in nature. In addition, the existing legislation does not prohibit and penalize acts of victimization, as required under Regulation 5.1.5, paragraph 3. The Committee requests the Government to provide information concerning any additional guidance it may have adopted concerning specific measures and regulations in place against victimization, e.g. the possibility for a seafarer to be accompanied or represented during the complaints procedure, as prescribed under Standard 5.1.5, paragraph 3 of the Convention.

Regulation 5.2 and the Code. Port State responsibilities. Inspections of foreign ships in port. In its previous comments, the Committee noted that Part X of the MLC Act addresses and merges inspections of both Singapore flagged ships and ships operating under the flag of another country. Section 58(4) enumerates conditions in which a detailed inspection may be conducted. It also noted that section 58(8)(g) of the Act confers on inspectors the power to require rectification of deficiencies, but that section does not appear to provide that inspectors must in some cases bring the deficiencies to the attention of the appropriate seafarers’ and shipowners’ organizations, as provided under Standard A5.2.1, paragraph 4. The Committee notes the Government’s indication that the MPA adheres to the Guidelines for port State control officers on the Convention and consults with the Tripartite Working Group. The Committee takes note of this information which answers it previous request.

Regulation 5.2.2 and Standard A5.2.2, paragraph 7. Port State responsibilities. Onshore seafarer complaint-handling procedures. Confidentiality of the complaints. The Committee further notes that national legislation does not provide for procedures, including steps taken to safeguard confidentiality, for seafarers calling at Singapore ports to report a complaint alleging breach of the requirements of the Convention in accordance with Regulation 5.2.2, paragraph 1, and Standard A5.2.2, paragraphs 1–7. While section 3.14 of the Tokyo MOU states that “In the case that an inspection is initiated based on a report or complaint, especially if it is from a crew member, the source of information must not be disclosed”, it does not establish procedures. The Committee requests the Government to provide information on measures taken to fully comply with Regulation 5.2.2, paragraph 1, and Standard A5.2.2, paragraphs 1–7.

Additional documentation requested. The Committee notes that the Government has omitted to provide some of the documents requested in the report form. The Committee would be grateful if the Government would provide the following documents and information: an example of the approved document for seafarers’ record of employment (Standard A2.1, paragraphs 1 and 3); a copy of any documentation that is available informing seafarers and interested others about the procedures for making a complaint (in confidence) regarding a breach of the requirements of the Convention (including seafarers’ rights) (Standard A5.1.5, paragraph 5).

Comments adopted by the CEACR: Singapore

Adopted by the CEACR in 2021

C100 - Direct Request (CEACR) - adopted 2021, published 110th ILC session (2022)

C100 - Observation (CEACR) - adopted 2021, published 110th ILC session (2022)

Adopted by the CEACR in 2020

C032 - Direct Request (CEACR) - adopted 2020, published 109th ILC session (2021)

C094 - Direct Request (CEACR) - adopted 2020, published 109th ILC session (2021)

C144 - Direct Request (CEACR) - adopted 2020, published 109th ILC session (2021)

Adopted by the CEACR in 2019

C029 - Direct Request (CEACR) - adopted 2019, published 109th ILC session (2021)

C081 - Direct Request (CEACR) - adopted 2019, published 109th ILC session (2021)

C098 - Direct Request (CEACR) - adopted 2019, published 109th ILC session (2021)

C182 - Replies received to the issues raised in a direct request which do not give rise to further comments (CEACR) - adopted 2019, published 109th ILC session (2021)

MLC, 2006 - Direct Request (CEACR) - adopted 2019, published 109th ILC session (2021)