HUMAN RESOURCES MANAGEMENT POLICIES



EMPLOYMENT EQUITY PLAN

EEA13

DAIRY 360

1 SEPTEMBER 2016- 31 AUGUST 2018

| [pic] PAGE 1 OF 16 EEA13 |

|PLEASE READ THIS FIRST | |

| |DEPARTMENT OF LABOUR |

| | |

| | |

|PURPOSE OF THIS FORM |TEMPLATE FOR EMPLOYMENT EQUITY PLAN (Section 20) |

|Section 20 requires designated employers to | |

|prepare and implement an Employment Equity | |

|Plan which will achieve reasonable progress |Employer Details |

|towards employment equity in the employer’s | |

|workforce. An Employment Equity Plan must | |

|state- |Trade name: DAIRY 360 (PTY) LTD |

| | |

|(a) The objectives to be achieved for each |DTI Registration name: DAIRY 360 (PTY) LTD |

|year of the plan | |

|(b) The affirmative action measures to be |PAYE/SARS No : 7940783329. |

|implemented as required by section 15(2); | |

|(c ) Where under representation of people form|EE Ref No : 820702 |

|designated groups has been identified by the | |

|analysis, the numerical goals to achieve the |Industry/Sector: AGRICULTURE |

|equitable representation of suitably qualified| |

|people from designated groups within each |Province: KWAZULU NATAL |

|occupational level in the workforce, the | |

|timetable within which this is to be achieved,|Tel No…0824955172 |

|and the strategies intended to achieve those | |

|goals; |Fax No…N/A |

|(d) The timetable for each year of the plan | |

|for the achievement of goals and objectives |Postal address: P.O. Box 1474 HOWICK 3290 |

|other than numerical goals; | |

|(e) The duration of the plan, this may not be | |

|shorter than one year or longer than five |Physical address: LOSKOP FARM |

|years; | |

|(f) The procedures that will be used to |KARKLOOF |

|monitor and evaluate the implementation of the| |

|plan and whether reasonable progress is being |3290 |

|made towards implementing employment equity; | |

|(g) The internal procedures to resolve any | |

|dispute about the interpretation or |Province: KWAZULU NATAL |

|implementation of the plan; | |

|(h) The persons in the workforce, including |Name & Surname of the CEO/Accounting Officer : Stuart Mackenzie |

|senior managers, responsible for monitoring | |

|and implementing the plan; and | |

|(i) Any other prescribed matter. |Email address: stuart.mackenzie@dairy360.co.za |

| | |

CONTENTS:

Page:

1. INTRODUCTION AND OVERVIEW 4

2. POLICY STATEMENT 5

3. DURATION OF PLAN 5

4. EMPLOYMENT EQUITY ANALYSIS 5

• Employment policies, procedures analysis

• Employee profile analysis

• Staff turnover

• Progress made since last EE plan

5. PLAN FOR 2017 - 2018 9

▪ Objectives, Numerical goals and Affirmative actions,

5.1 PLAN FOR 2017 10

▪ Numerical goals, Affirmative actions,

Timing and Responsibility

5.2 PLAN FOR 2018 10

▪ Numerical goals, Affirmative actions,

Timing and Responsibility

6. POLICIES AND PROCEDURES FOR EMPLOYMENT EQUITY PLAN 11

• Responsibility, Monitoring and evaluating the plan, dispute

Resolution, Fair treatment

7. ANNEXURES 14

1: Analysis of employment policies, practices, procedures, and work

environment

2. Employee profile analysis (occupational categories)

3. Numerical Goals and targets

4. Terms of reference of training committee

1. INTRODUCTION AND OVERVIEW

The Employment Equity Act (EEA) was assented to on 12 October 1998, and implemented in 2000. The Act introduced legislative measures aimed at removing the barriers for those who have been previously denied proper access to all forms and levels of jobs, skills and education.

The effectiveness of the Act will be determined by the extent to which the Act promotes, and employers proactively implement, workplace policies, procedures and practices that enhance equity and the removal of any discrimination in the workplace.

“The purpose of the Act is to achieve equity in the workplace by promoting equal opportunity and fair treatment through the elimination of unfair discrimination, and implementing affirmative action measures to redress the disadvantages in employment experienced by designated groups, in order to ensure their equitable representation in all occupational categories and levels in the workforce”.

[Employment Equity Act, 1998, Section 2]

Explained in another way:

“The Act seeks to give effect to our Constitution by prohibiting discrimination on the one hand and entrenching equity in the workplace through the use of affirmative action on the other. These twin objectives are designed to complement one another. Removing discrimination on its own will not ensure equality in employment opportunities for those who have been denied access to jobs, education and skills in the past. The Act therefore has to go further and place an obligation on employers to introduce affirmative action steps to redress these imbalances.

Employers and workers should be able to implement the laws in ways that can enhance productivity, efficiency and good employment practices”.

[Minister of Labour, Statement on 29 April 1999]

The Employment Equity Act requires that ‘designated employers’ endeavour to develop and implement plans to achieve “reasonable progress” [see Section 20(1)] towards achieving employment equity/affirmative action by setting realistic and achievable numerical goals. The Act also provides flexibility – plans can be revised annually. Further, in assessing compliance the Act notes several factors that can be taken into account, including: the regional demographics of the economically active population; the pool of suitably qualified people from ‘designated groups’; positive or negative economic factors in the industry sector; economic and financial circumstances of the employer; staff turnover and planned vacancies; progress made by other designated employers in the industry sector and in comparable circumstances, etc.

In short, whereas employers are asked to make real reasonable progress, the Act does provide a flexible framework within which to do so, as well as recognizes factors which could be constraints to progress. As such, the organisation can proactively subscribe to, and make realistic efforts and progress towards meeting the requirements of the Act.

As per EEA13 and Section 20 of the EE Act, an employment equity plan is required to state:

• The objectives to be achieved for each year of the plan

• The affirmative action measures to be implemented as required by section 15(2);

• Where under representation of people from designated groups has been identified by the analysis, the numerical goals to achieve the equitable representation of suitably qualified people from designated groups within each occupational level in the workforce, the timetable within which this is to be achieved, and the strategies intended to achieve those goals;

• The timetable for each year of the plan for the achievement of goals and objectives other than numerical goals;

• The duration of the plan, this may not be shorter than one year or longer than five years;

• The procedures that will be used to monitor and evaluate the implementation of the plan and whether reasonable progress is being made towards implementing employment equity;

• The internal procedures to resolve any dispute about the interpretation or implementation of the plan;

• The persons in the workforce, including senior managers, responsible for monitoring and implementing the plan;

• Any other prescribed matter.

2. POLICY STATEMENT

The following Policy Statement has been adopted by Dairy 360 and by the appointed Employment Equity Committee:

“Dairy 360 has identified the requirements of the Employment Equity Act as an opportunity for:

• constructively and realistically providing growth and development opportunities to employees in the designated groups, whilst not excluding persons from non designated groups;

• ensuring there are equitable human resources policies and procedures;

• setting realistic and achievable targets towards equitable demographic representation across the different occupational categories and levels in our organization.

To achieve these goals and targets, Dairy 360 will

i) actively participate in and support the work of the Employment Equity

Committee.

ii) monitor progress being made on employment equity and provide necessary support and assistance”.

3. DURATION OF PLAN:

Section 20 indicates that the duration of the Employment Equity Plan may not be shorter than one year or longer than five years. The duration of this plan is 2 years and it starts on

1 September 2016 and ends on 31 August 2018.

4. EMPLOYMENT EQUITY ANALYSIS (Section 19 of EE Act)

In order to develop an Employment equity plan, it is necessary to analyse the following:

• Employment policies, practices, procedures and the working environment in order to identify employment barriers which adversely affect people from designated groups as per Section19 (1)

• Employee profile to determine the under-representation of people from the designated groups in the various occupational levels in the workforce as per Section 19 (2)

• Employee profile

• Staff turnover

• Progress made since last EE plan

4.1 Employment Policies, practices and procedures and the work environment

The analysis of the employment Policies, practices and procedures and the work environment was reviewed together with the barriers to EE and Affirmative action measures. Any new barriers identified were included and redundant barriers removed. Any new affirmative action measures were then identified to minimize these barriers. This analysis as per EEA12 and Section 19 (1) is recorded in Annexure 1: Analysis of employment policies, practices, procedures, and working environment.

A summary of the analysis revealed the following:

Barriers to Employment Equity

• Africans are not sufficiently represented in management positions due to:

• low turnover of current employees in these positions.

• No new management positions required (Flat structure of the business)

• Disabled are not sufficiently represented in the workplace due to;

• the physical requirements of the jobs

• Lack of applicants

• Safety risk

• Indian and Coloured employees are not sufficiently represented in the workplace as:

• there is a lack of applications (limited pool in the area)

• they are not interested in the unskilled positions

Affirmative Action measures

Within this area of transformation employment equity follows on from working on the organizations talent pipeline. With the implementation of careful affirmative action policies and the correct attraction and retention of employees the Company’s Employment Equity status should steadily correct itself if it is not currently in line with the Economically Active Population as determined and published by Stats SA (latest version 3rd Quarter 2015)

Dairy 360 has yet to achieve race and gender representation in the occupational levels of the organization (as per analysis below). However through a policy of identifying and procuring suitable persons from members of the designated groups, this can be done progressively.

Affirmative Action recommendations can be seen in Annexure 1 and are further addressed in the Plan from 1 September 2016 to 31 August 2018

4.2 Employee profile analysis (Annexure 2)

The employee profile was analysed in EEA12 as follows:

1. A snapshot of the Current workforce profile as at 1 September 2016

2. Analysis of workforce profile by occupational level

4.2.1.A snapshot of the Current workforce profile as at 1 September 2016

Workforce profile Information contained in the two tables below in terms of race, gender and disability is as at 01 /09/2016 (dd/ mm/ yyyy). The first table contains information on all employees, including people with disabilities, and the second table only contains information on people with disabilities.

Table 1: Snapshot of all employees, including people with disabilities

|Occupational Levels | | | |Total |

| |Male |Female |Foreign Nationals | |

| |A |C |I |W |

Staff turnover is a result of a number of reasons: retirement, resignation, death and disability, retrenchment and dismissal. It is not possible to predict with any certainty the degree of staff turnover each year for the next 2 years.

Past record may be of some assistance, but cannot be relied upon with too much confidence. Nevertheless, turnover in the past year shows that there were terminations, or 0 % of total staff complement.

During the same period, 0 staff were promoted (0%), and 2 staff were employed (4%)

4.4 Progress of EE plan 2015/2016

No progress reviewed as reporting for the first time.

5. PLAN FOR 2016 - 2018

Objectives for each year of the plan

| | |

|TIMEFRAMES |OBJECTIVES |

|YEAR 1 |1 September 2016-31 August |Improve the equitable representation of designated groups by implementing the numerical goals set in the Section|

| |2017 |19 (1) quantitative analysis |

| | |Eliminate unfair discrimination by implementing Affirmative action measures as identified from the Section 19 |

| | |(2) Qualitative workforce analysis |

| | |Train and develop designated groups through training and development identified to support the numerical goals |

| | |and AA measures above |

|YEAR 2 | |Improve the equitable representation of designated groups by implementing the numerical goals set in the Section|

| |1 September 2017-31 August |19 (1) quantitative analysis |

| |2018 |Eliminate unfair discrimination by implementing Affirmative action measures as identified from the Section 19 |

| | |(2) Qualitative workforce analysis |

| | |Train and develop designated groups through training and development identified to support the numerical goals |

| | |and AA measures above |

Detailed EE plan for Year 1 and Year 2

The numerical targets and goals and affirmative action measures results from the Qualitative analysis [Section 19 (1)] in Annexure 1 and the Quantitative analysis [Section 19 (2)] in Annexure 2 have been combined into the detailed EE plans for Year 1 and 2 below.

No growth is expected over the next 2 years. Our EE strategies will therefore focus on some recruitment and skills development of existing staff. There is a possibility of 1 retirement expected.

Year 1 (1 Sept 2016 – 31 August 2017)

|Numerical targets |Timeframes |Responsibility |

|Promote 1 B/M Herd controller (skilled) to Diary controller (skilled) |1 Sept 16 – 31 Aug 17 |EE Manager |

|Recruit 1 B/M Tractor driver (semi skilled) | | |

|Affirmative Action Measures | | |

|Upskill : |1 Sept 16 – 31 Aug 17 |EE Manager |

|1 B/M driving skills | | |

Year 2 (1 Sept 2017 – 31 August 2018)

|Numerical targets |Timeframes |Responsibility |

|Promote 1 B/M Herd controller (skilled) to Diary controller (skilled) |1 Sept 17 – 31 Aug 18 |EE Manager |

|Affirmative Action Measures | | |

|Upskill : |1 Sept 17 – 31 Aug 18 |EE Manager |

|1 B/M driving skills | | |

Numerical goals and targets (Annexure 3)

The actual numerical targets and goals for the entire workforce including people with disabilities for the next 2 years are illustrated in Annexure 3

• Numerical Targets Year 1 : 1 September 2016 – 31 August 2017

• Numerical Goals Year 2 : 1 September 2017 – 31 August 2018

6. POLICIES AND PROCEDURES FOR EMPLOYMENT EQUITY PLAN

Senior Manager assigned to monitor and implement the plan

• The Senior manager Stuart Mackenzie, is responsible for ensuring that the employment equity plan is monitored and implemented. An appropriate budget will be provided when required and access to other resources and time off as required.

Employment Equity consultation

• The Employment Equity Committee has been appointed following a process of calling for nominations from employees. The Committee is comprised of persons that are broadly representative of occupational categories and levels.

|Name |Gender |Race |Employee/ Mgt |Disabled Y/N? |SA Citizen/ Foreign |

|Sue Mackenzie |Female |White |Mgt |N |SA Citizen |

|Stuart Mackenzie |Male |White |Mgt |N |SA Citizen |

|Slindi Mbonambi |Female |Black |Employee |N |SA Citizen |

|Thoko Ndlela |Female |Black |Employee |N |SA Citizen |

|Sean Touche |Male |White |Employee |N |SA Citizen |

|AJ Liebenberg |Male |White |Employee |N |SA Citizen |

Monitoring and evaluating the plan

|STAKEHOLDER |ROLE/RESPONSIBILITY |FREQUENCY |

|CEO/ Accounting Officer |Ensure implementation of plan and submission of reports |Annually |

| |Resolve any disputes reported | |

| | |As and when necessary |

|Employment Equity Manager |Monitor the implementation of the EE plan |Quarterly |

| |Chair all Consultative forum/EE committee meetings and take | |

| |minutes and register |Quarterly |

| |Submit annual reports to Dept of Labour | |

| |Develop EE plan |Annually |

| |Report disputes to CEO | |

| | |Every 2nd year |

| | |As and when necessary |

|Consultative forum/EE committee |Monitor the implementation of the EE plan |Quarterly |

| |Attend all Consultative forum/EE committee meetings | |

| |Assist with developing EE plan |Quarterly |

| |Report on any discrimination to EE committee | |

| | |Every 2nd year |

| | |As and when necessary |

Dispute resolution mechanisms

Should any dispute about the interpretation or implementation of the plan arise, the

following procedure should be followed:

|Action |Timeframe |Stakeholder/s involved |

|Informal attempt to resolve the dispute |7 days |Complainant |

|Lodge a formal complaint by setting out the nature of the dispute in writing |7 days |Complainant |

|and refer it to the Employment Equity Manager | |EE manager |

|The Employment Equity manager will meet with the Employment Equity committee to| |EE manager |

|discuss and attempt to resolve the dispute |7 days |EE committee |

|In the event of the dispute not been resolved by the Employment Equity | 7 days |EE manager |

|Committee, an external facilitator will be retained to resolve the dispute | |Complainant |

| | |External facilitator |

Fair treatment

• Regarding recruitment, selection, development, promotion and access to employment opportunities, the following principles are adhered to:

- there is no discrimination based on race, gender, pregnancy, marital status, family responsibility, ethnic or social origin, colour, sexual orientation, age, disability, religion, HIV status, conscience, belief, political opinion, culture, language, and birth

• All policies and practices are fair and do not undermine the affirmative action process.

Terms of reference for training committee

• Refer to Annexure 4

SIGNATURE OF THE CHIEF EXECUTIVE OFFICER/ACCOUNTING OFFICER

|Chief Executive Officer/Accounting Officer |

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|I --------------------------------------------------------------------------- (full Name) CEO/Accounting Officer of |

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|----------------------------------------------------------------------------------------------------------------------------------- |

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|hereby declare that I have read, approved and authorized this EE Plan. |

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|Signed on this -----------------day of -------------------------------------------------year---------------------------- |

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|At place:----------------------------------------------------------------------------------------------------------------- |

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|------------------------------------------------------------------- |

|Chief Executive Officer /Accounting Officer |

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Annexure 1: Analysis of employment policies, practices, procedures, and working environment

1. Barriers to Employment Equity and Affirmative action measures as per Section 19 (1) Qualitative analysis and EEA 12

|CATEGORIES |BARRIERS AND AFFIRMATIVE ACTION MEASURES |

| |Tick (√) one or more cells for each category |BARRIERS |AFFIRMATIVE ACTION MEASURES | | |

| |below to indicate where barriers exist in | |(PLEASE PROVIDE NARRATION) |TIME-FRAMES |RESPONSIBILITY |

| |terms of policies, procedures and/or practice|(PLEASE PROVIDE NARRATION) | | |(Designation) |

| | | | | | |

| | | |(briefly describe the | | |

| | |(briefly describe each of the barriers identified in|affirmative action measures to | | |

| | |terms of policies, procedures and/or practice for |be implemented in response to | | |

| | |each category) |barriers identified for each | | |

| | | |category) | | |

| |POLICY |PROCEDURE |PRACTICE |

| |Yes | | |

|Do you have ablution facilities for both male and female? | | | |

| | |No |Limited scope to employ disabled people in manual labour |

|Do you have facilities for disabled? | | |positions. |

|Ramps for wheelchairs | | | |

|Parking bay for disabled | | | |

|Toilets for disabled | | | |

|Do you have an HIV/ AIDS policy? |Yes | | |

| | |No |There are clinics that can counsel persons affected. People |

|Do you have an HIV/AIDS programme? | | |are then encouraged and given time to follow the appropriate |

| | | |channels of treatment. |

|Do you have the summary of the EE Act visible to all employees? |Yes | | |

Annexure 2: Snapshot of Employee profile as at 1 September 2016 and analysis by occupational categories

compared to EAP Statistics as per EEA12

|Occ Levels |Mal|Fem|Tot|For|Dis|Fin|

| |e |ale|al |eig|abl|din|

| | | | |n |ed |gs:|

| | | | | | |Und|

| | | | | | |err|

| | | | | | |epr|

| | | | | | |ese|

| | | | | | |nte|

| | | | | | |d |

| | | | | | |as |

| | | | | | |per|

| | | | | | |KZN|

| | | | | | |EAP|

2016 Current year (as at 1 September 2016)

2017T Targets planned for 31 August 2017 (end of next reporting year)

2018G Goals planned for 31 August 2018 (end of EE plan)

Annexure 4: EE Committee Terms of reference

1. Scope and Purpose

A committee reflecting a broad cross-section of occupational levels and categories in the organization, is established in order to:

• Promote the objectives of the Employment Equity Act

• Enable meaningful consultation over employment equity matters as defined by the Act

2. The aims and objectives of the Committee will be:

• Identify employment barriers that adversely affect the appointment, training and development, promotion and advancement of employees from designated groups.

• To recommend steps to eliminate any employment barriers which adversely affect employees from designated groups.

• To determine the degree of under-representation of employees from designated groups in the various occupational levels and categories in the organisation.

• To recommend steps to address any under-representation of employees from designated groups within the occupational levels and categories.

• To prepare an Employment Equity Plan and submit for approval by Management.

• To provide input into the Employment Equity Report to be submitted to the Dept of Labour.

• To monitor progress towards implementation of the Plan.

• To advise all employees of Employment equity.

• content and application of the Act;

• Employment Equity;

• anti-discrimination issues;

• processes followed by the employer;

• and the need for stakeholder involvement

3. Composition of committee

• The committee will consist of less than 10 representatives.

• The representatives shall reflect management as well as the employees

• The committee members should be representative in terms of occupational level, occupational category, gender group, race group and disability.

• The Chairperson of the committee will be appointed by the committee, and shall hold this position for 24 months

4. Appointment of committee members

Committee members shall be appointed in the following manner: -

• Management shall ask for nominations at each work premises in order to install a new Committee or to replace members who leave

• The nominations shall be made anonymously on standard forms and individuals may nominate themselves

• Management shall select the committee members from the nominations.

5. Responsibilities of committee members

• To contribute to finding solutions to employment equity issues by identifying needs and by making recommendations to management

• To promote the implementation of Employment equity

• To monitor and review the implementation and progress of Employment equity.

6. Meetings

• Meetings will be held bi-annually.

• Meeting agendas will be prepared and distributed prior to the meetings, unless there is a need for an urgent meeting at short notice.

• Minutes of all meetings will record the proceedings and decisions taken and be distributed to all committee members within 10 working days of holding the meeting

7. Powers of the Committee

The committee shall act in terms of the duties assigned to it in the Employment equity Act. It is noted that the committee is not a bargaining forum, and has no powers to negotiate on matters such as employee salaries and conditions of employment

8. Confidentiality

Information of a confidential nature will be so identified and kept confidential to members of the Committee. Any breach in confidentiality is an offence in terms of the Employment Equity Act and will be treated as a serious form of misconduct in terms of the Company’s disciplinary policy

9. Reporting progress

The committee shall prepare the Employment Equity report in September of every year and submit this for the approval of management. Thereafter, the report will be submitted to the Dept of Labour

10. Dispute resolution

Should any dispute about the interpretation or implementation of the plan arise, the

following procedure should be followed:

|Action |Timeframe |Stakeholder/s involved |

|Informal attempt to resolve the dispute |7 days |Complainant |

|Lodge a formal complaint by setting out the nature of the dispute in writing |7 days |Complainant |

|and refer it to the Employment Equity Manager | |EE manager |

|The Employment Equity manager will meet with the Employment Equity committee to| |EE manager |

|discuss and attempt to resolve the dispute |7 days |EE committee |

|In the event of the dispute not been resolved by the Employment Equity | 7 days |EE manager |

|Committee, an external facilitator will be retained to resolve the dispute | |Complainant |

| | |External facilitator |

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