Scorp Group · Policy Document

Working Hours Compliance

Process Description

Document Title

Process for Compliance with International Working Hours Standards

Document No.

SG-HR-PROC-006

Version

1.0

Effective Date

June 2025

Owner

Chief Human Resources Officer (CHRO)

Approved by

Board of Directors, Scorp Group Ltd

1.PURPOSE

This document describes Scorp Group Ltd's management approach to ensure compliance with international standards on maximum working hours, minimum breaks, and rest periods — across its own operations and its supply chain. Scorp Group publicly respects workers' right to fair working hours and actively assesses whether workers can realistically comply with these commitments given the targets and workloads set by the business.

This process is aligned with:

  • ILO Convention No. 1: Hours of Work (Industry), 1919
  • ILO Convention No. 30: Hours of Work (Commerce and Offices), 1930
  • ILO Convention No. 14: Weekly Rest (Industry), 1921
  • ILO Convention No. 106: Weekly Rest (Commerce and Offices), 1957
  • ILO Convention No. 132: Holidays with Pay (Revised), 1970
  • UN Universal Declaration of Human Rights, Article 24
  • UN International Covenant on Economic, Social and Cultural Rights (ICESCR), Article 7(d)
  • UN Guiding Principles on Business and Human Rights (UNGPs), Principles 12, 17-21
  • OECD Guidelines for Multinational Enterprises (2023), Chapter V
  • Ethical Trading Initiative (ETI) Base Code, Clause 7 (Working Hours are Not Excessive)
  • GRI Standard 401: Employment (2016)
  • SMETA 4-Pillar Audit Standard — Pillar 3 (Working Hours)
  • 2.SCOPE

    This process applies to:

  • All employees of Scorp Group Ltd (all contract types and locations)
  • Contractors and agency workers at Scorp Group sites
  • Tier 1 and, where possible, Tier 2 suppliers through contractual requirements and audits
  • 3.WORKING HOURS STANDARDS APPLIED BY SCORP GROUP LTD

    Maximum Regular Working Hours: 48 hours per week (in line with ILO C1)

    Maximum Working Hours incl. OT: 60 hours per week (only on an exceptional, voluntary basis)

    Minimum Daily Rest: 11 consecutive hours per 24-hour period

    Minimum Weekly Rest: At least 1 full day off (24 hours) per 7 days; ideally 2 days

    Minimum Meal/Rest Breaks: 30-minute break after 6 consecutive hours of work

    Annual Leave: Minimum 20 days paid leave per year (per local law where higher)

    Overtime: Voluntary; compensated at a premium rate (min. 1.25x regular pay)

    All overtime must be truly voluntary. Scorp Group prohibits any form of coercion, threat, or penalty

    for workers who decline overtime.

    4.PROCESS DESCRIPTION

    STEP 1 — POLICY COMMITMENT AND COMMUNICATION

    1.1 Scorp Group's Working Hours Policy is publicly available on the company website and communicated to all employees upon hire and at minimum annually.

    1.2 The policy sets out the maximum working hours and rest period standards referenced above, and commits to compliance with all applicable national laws where they are more stringent.

    1.3 Supplier Code of Conduct includes mandatory working hours requirements aligned with ILO C1 and the ETI Base Code Clause 7.

    Reference: ILO C1; ETI Base Code Clause 7; UNGP Principle 16.

    STEP 2 — WORKLOAD AND TARGET-SETTING ASSESSMENT

    2.1 Before allocating production volumes, setting performance targets, or assigning workloads, Scorp Group Operations and HR conduct a Workload Feasibility Assessment to determine whether targets can be met within legal working hours limits.

    2.2 The Workload Feasibility Assessment considers:

  • Average daily and weekly capacity per worker
  • Seasonal demand variations and peak periods
  • Worker skill level and machine/resource availability
  • Historical overtime data and trends
  • Worker feedback and grievance data related to workload
  • 2.3 Where targets cannot be achieved within 48 hours per week regular time, Scorp Group will:

  • Review and adjust targets to be realistic within normal hours; or
  • Increase headcount to distribute workload; or
  • Explicitly authorise limited voluntary overtime with full worker consent
  • Reference: ETI Base Code Clause 7.6; SMETA 4-Pillar Audit Standard — Pillar 3.

    STEP 3 — TIME AND ATTENDANCE MONITORING

    3.1 Scorp Group maintains a digital Time and Attendance Management System (TAMS) that records:

  • Daily start and end times for all workers
  • Break times and duration
  • Overtime hours (regular and premium)
  • Weekly and monthly working hour totals
  • 3.2 TAMS data is reviewed weekly by HR Business Partners. Any worker consistently working more than 48 regular hours or 60 total hours per week triggers an automatic alert for management review.

    3.3 Workers have access to their own time records at all times and may raise discrepancies through the grievance mechanism.

    Reference: ILO C1 Article 3; SMETA Pillar 3; GRI 401.

    STEP 4 — SUPPLIER ASSESSMENT ON WORKING HOURS

    4.1 All Tier 1 suppliers are assessed on working hours compliance through:

  • Supplier Self-Assessment Questionnaire (SAQ) — includes specific questions on working hour policies, overtime systems, and time recording
  • Third-party social audits (SMETA, BSCI, PSCI) which include working hours as a mandatory audit pillar
  • Worker interviews conducted during on-site audits
  • 4.2 Suppliers with working hour violations are issued Corrective Action Plans (CAPs):

  • Regular OT exceeding 60 hours/week: Major non-conformance — 60-day CAP
  • Falsified time records: Critical non-conformance — immediate investigation
  • Reference: ETI Base Code Clause 7; SMETA 4-Pillar Audit Standard.

    STEP 5 — MONITORING, REPORTING, AND REVIEW

    5.1 Scorp Group tracks the following KPIs:

  • % of workforce regularly exceeding 48 hours/week (target: < 2%)
  • % of workforce regularly exceeding 60 hours/week (target: 0%)
  • Average overtime hours per worker per week (target: < 4 hours)
  • Number of working hours-related grievances (target: 0 systemic issues)
  • Supplier CAP closure rate for working hours violations (target: >= 90%)
  • 5.2 KPIs are reviewed quarterly by CHRO and reported annually in the Human Rights & Sustainability Report, aligned with GRI 401.

    5.3 This process is reviewed annually and updated to reflect changes in operations, labour laws, and international standards.

    Reference: UNGP Principle 20; GRI 401; OECD DDG Step 4.

    5.INTERNATIONAL STANDARDS REFERENCED

  • ILO Conventions: C1, C14, C30, C106, C132
  • UN UDHR Article 24; ICESCR Article 7(d)
  • UN Guiding Principles on Business and Human Rights, Principles 12, 17-21
  • OECD Guidelines for Multinational Enterprises (2023), Chapter V
  • ETI Base Code, Clause 7 (Working Hours are Not Excessive)
  • GRI Standard 401: Employment (2016)
  • SMETA 4-Pillar Audit Standard, Pillar 3