To eliminate debt bondage and contract substitution, which are major contributing factors to the vulnerability of migrant workers in Qatar, QDVC quickly set up processes to monitor recruitment agencies in countries of origin (Bangladesh, India, Nepal, Philippines, etc.). It also provided clear rules specifying which costs are covered by QDVC, to prevent them from being passed on to workers. A full 100% of the contracts signed prohibit agencies from charging recruitment fees and include a reference to the Employer Pays Principle (https://www. ihrb.org/projects/employer-pays-principle) supported by VINCI, along with strict clauses to ensure its application, and the obligation to monitor downstream compliance. During recruitment campaigns, QDVC managers have visited agencies in home countries on several occasions to verify compliance with rules, reinforce messages to applicants that recruitment is free, examine the actual working conditions offered and participate directly in recruitment interviews.
A notable example of this joint work is QDVC’s participation in a study on ethical recruitment run by New York University’s Stern Center for Business and Human Rights. Based on quantitative and qualitative information provided by QDVC and interviews with workers, managers, recruitment and placement agencies and subcontractors, the report acknowledged the effectiveness of the due diligence measures in place and considered that “QDVC’s standard represents the most responsible recruitment practice that currently exists in the industry”. (*) The study aimed to determine whether QDVC’s responsible recruitment practices could be replicated elsewhere in construction or other industries to promote the rights of migrant workers. With most of its attributed infrastructure projects coming to an end, QDVC is not recruiting any more workers.
Regarding freedom of movement, all QDVC workers hold a Qatari residence permit, which is required to move freely within the country. They also have access to a safe in which they can store their personal documents (passports, employment contracts, etc.). If any worker chooses to leave employment, QDVC systematically issues a “no objection certificate” (NOC) enabling them to work for a different employer. Workers wishing to leave the country for a holiday, an emergency, or any other reason have always been able to do so with no barriers. These were already QDVC’s practices long before the Qatar government’s 2020 reform of the kafala (sponsorship) system.
QDVC carries out human rights audits of subcontractors and temporary employment agencies, during which it inspects sites, verifies records and documents and interviews workers. For example, in 2023, the last year in which QDVC still had a significant volume of work, it conducted audits of its 144 Tier 1 and Tier 2 subcontractors and six temporary employment agencies on site. Of these, 50 examined working conditions and 85 looked at living conditions. In addition to these audits, QDVC conducted spot checks, during which its teams made unannounced site visits to verify that workers were in possession of their passport and a valid work permit, that they received their salary in full in their bank account, that they had health insurance, that working hours were complied with, that their housing was satisfactory and that they had not paid a recruitment fee to come work in Qatar. These spot checks covered 150 workers employed by subcontractors in 2023.
Some non-compliance was identified through these audits and spot checks, and QDVC demanded the infringements be resolved by the subcontractors. For example, observed non-compliance involved the number of days of paid leave granted (including seniority entitlements), the calculation of termination benefits, differences between the salary announced in the employment offer and the pay actually received by the worker, and the return air fare to be paid by the employer, regardless of the reason for the worker’s departure (end of trial period, resignation or dismissal). QDVC monitored all non-compliance until it was resolved.
Lastly, during its years of activity, QDVC worked to continuously deepen and widen its due diligence. For example, it expanded auditing procedures to include sales development and contract acquisition activities and tightened its CSR criteria for selecting partners, customers and projects.
QDVC also provided employee representation and grievance procedures to encourage and strengthen social dialogue in the company. A workers’ committee was formed as of 2011. Its powers and scope were expanded in 2014 to cover issues such as working conditions, wages, living conditions and health and safety. Starting in 2016, QDVC held regular elections for employee representatives. That year, QDVC’s election was the first of its kind in Qatar. The company provided candidates with resources to help them campaign and, if elected, fulfil their role as an employee representative. In accordance with the terms of the 2017 framework agreement, Building and Wood Workers’ International (BWI) trained employee representatives in Doha, with support from QDVC and VINCI.
QDVC is the first Qatari company to sign an agreement with a labour union and hold free elections of workers’ committees
Since 2016, QDVC has formally requested that all its subcontractors and temporary employment agencies facilitate the free election of workers’ committees. QDVC offers assistance to its partners in establishing these elections and verifies compliance during audits of human rights performance and living conditions. In 2023, 15 subcontractors set up workers’ committees and grievance mechanisms, as a result of the regular auditing and continuous improvement process implemented by QDVC and its subcontractors. In addition, QDVC developed internal systems to enable workers to report concerns in their own language to Corporate Social Responsibility (CSR) or Quality, Safety and Environment (QSE) officers, including one full-time social worker. Since 2017, an independent grievance procedure has been available to enable employees of QDVC or its partners to approach BWI.
