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									Bruno Periera   1
• “place of employment” means
  any place where work is carried on for an
  employer by an employee;

• “employee” means
  any person or class of persons—
(a) included in any category in the First Schedule to
    the extent specified therein; or
(b) in respect of whom the Minister makes an order
    under subsection (3) or section 2A;
                          EMPLOYMENT ACT 1955

                          Bruno Periera                 2
EMPLOYMENT SENARIO Place
       of employment


•Types of EMPLOYERS
•Types of WORKERS
•Types of CONTRACTS
           Bruno Periera   3
           Types of EMPLOYERS
• “employer” means any person who has entered
  into a contract of service to employ any other
  person as an employee and includes the agent,
  manager or factor of such first mentioned person,
  and the word “employ”, with its grammatical
  variations and cognate expressions, shall be
  construed accordingly;
 EMPLOYMENT ACT 1955


                       Bruno Periera                  4
• “Principal” means any person who in the course of
  or for the purposes of his trade or business
  contracts with a contractor for the execution by or
  under the contractor of the whole or any part of
  any work undertaken by the principal;
• “Contractor” means any person who contracts
  with a principal to carry out the whole or any part
  of any work undertaken by the principal in the
  course of or for the purposes of the principal’s
  trade or business;
EMPLOYMENT ACT 1955

                        Bruno Periera                   5
• “Sub-contractor” means any person who contracts with a
  contractor for the execution by or under the sub-contractor of
  the whole or any part of any work undertaken by the
  contractor for his principal, and includes any person who
  contracts with a sub-contractor to carry out the whole or any
  part of any work undertaken by the subcontractor for a
  contractor;
• “Sub-contractor for labour” means any person who contracts
  with a contractor or sub-contractor to supply the labour
  required for the execution of the whole or any part of any
  work which a contractor or sub-contractor has contracted to
  carry out for a principal or contractor, as the case may be;
                                            EMPLOYMENT ACT 1955




                            Bruno Periera                         6
LOCAL Workers seeking employment

                                          Local
                                         WORKERS




      Direct         Job Malaysia                     Private
   Application        MOHR JTK                      Employment
   (or walk-in)                                       Agency

                                                    PRIVATE EMPLOYMENT AGENCY ACT 1981
                                                      20% commission of 1st Month’s
                            PLACEMENT
                                                     wage charged on placement. Paid
                                                     either by employer or the worker.

                    FACTORY
                  (Principle Employer)

PROBATION                                             Temporary
 followed by                                          (FIX TERM)
PERMANENT                                               contract
  Contract
                                    Bruno Periera                                 7
                                                       Migrant
 MIGRANT Workers employment                           WORKERS




EMPLOYMENT (RESTRICTION) ACT 1968
   Non-citizen shall not be
  employed unless there has                   Contract of Service/
      been issued valid                          Temporary
                                                 (FIX TERM)
    employment permit.                             contract




                                                   FACTORY
                                                 (Principle Employer)
                              Bruno Periera                             8
                             MIGRANT Workers employment
                                                                    Migrant
                                                                   WORKERS
                             NOW….LOCAL Workers also
                               follow the same flow!
                                                               Contract of Service/
                                                               Contract for Service
                                                                  Temporary
No Law to regulate?                                               (FIX TERM)
Outsourcing License No.,                                            contract
Recruitment No. KHEDN.
                                      Labour Contractors
        TODAY                                  Company)
                                    (Outsource Labour Contractors
                                             (Outsource Company)
                                                   Labour Contractors
                                                 (Outsource Company)

                                    TOMORROW
        FACTORY
      (Principle Employer)
                                                                            FACTORY
                                                                          (Principle Employer)
                                          FACTORY
                                        (Principle Employer)
                                            Bruno Periera
                                                                        THE DAY AFTER
                                                                                    9
Workers seeking employment in Malaysia
                                                                                  Migrant
                                                     Local                       WORKERS
                                                    WORKERS


                                                                                Contract of Service/
                                                                                Contract for Service




                                                                                                       RM $ wages
                                                                                   Temporary
                    Direct           Job Malaysia          Private                 (FIX TERM)
                  application         MOHR JTR           Employment                  contract
                                                           Agency

                                     Placement
                                                                                 CONTRACTOR
     RM $ wages




                                                                              (Outsource Company)

                                  FACTORY
                                (Principle Employer)
                                                                                                       TODAY
                                                                                           FACTORY
                                                                                         (Principle Employer)
                                                                                          TOMORROW
    PROBATION                               Temporary
     followed by                            (FIX TERM)
    PERMANENT                                 contract                                  FACTORY
      Contract                                                                        (Principle Employer)
                                                                        FACTORY
                                                                      (Principle Employer) THE DAY AFTER
                                   Types of WORKERS
     Employed directly by Employer or Principal :
              1. Permanent workers
              2. Local contract workers (Fix-term)
              3. Foreign contract workers (Fix-term)
------------------------------------------------------------------------------------------------------------------------------

      Supplied by Labour Contractors but work for Principal
       employer PAID BY Labour Contractor:

              4. Local contract workers (Fix-term)
              5. Foreign contract workers (Fix-term)
                                                                Bruno Periera                                                    11
        Types of CONTRACTS
1. Employment Contract is a CONTRACT OF
                SERVICE
        (Kontrak Perkhidmatan)

          2. Service Contract is a
         CONTRACT FOR SERVICE
      (Kontrak untuk Perkhidmatan)
      (not an employment contract)
                 Bruno Periera            12
             Contract OF Service
                 (Kontrak Perkhidmatan)
• Any agreement between two parties – an employer and
  an employee, where by:

• The employer agrees to employ another as an
  employee; and the employee

  – agrees to undertake certain duties under the
    direction and control of the employer.

  – agrees, in return for a specified wage or salary and
    benefits under a terms & conditions of employment
    from employer.         Bruno Periera                   13
  Terms and Conditions of Employment
• The employer cannot change the terms and
  conditions of employment unless employee agrees
  to it.
• Any terms and conditions, in a contract of service,
  that is less favourable than the relevant provision
  under the Employment Act (1955) is illegal, null and
  void.
• Provision in the Act will take precedence over a
  particular contractual term that is less favourable.
                        Bruno Periera                    14
• An apprenticeship contract or agreement is also
  considered a contract of service

• Agreement, whether oral or in writing and
  whether express or implied.

                                      Oral contract in writing? How?




                      Bruno Periera                               15
              Employment Act in 1955
• With the introduction of the EA, the then British Administration
  effectively abolished the indenture labour, bonded labour and the
  “kanggani” system in Malaya, as it was known then.
• The totality of the Employment Act 1955 established two very
  important principles of law.
• They are:
   – Security of tenure – ensuring permanence of job and

   – Proprietary right to the job – where termination of worker, shall
     be with just cause and excuse & by due process.

• These principles are trite law and are considered sacrosanct.
• MUST be protected at all cost!

                                Bruno Periera                         16
                        Types of
            Contract OF Service
            (Kontrak Perkhidmatan)
• Permanent Contract (permanent workers)
  Direct hire (Company workers)
                                         - local workers
• Fixed Term Contract -
 (temporary or contract workers)
  Direct hire (Company workers)
                              -  Locals & Foreign workers
                         Bruno Periera                 17
            contract FOR service
           (not an employment contract)
           (Kontrak untuk Perkhidmatan)
• engaged as an independent contractor
(such as a self-employed person or vendor) .
• engaged for a fee to carry out an assignment, duty or a
  project for the company.

• there is no employer- employee relationship, therefore,

NOT covered by the Employment Act

                          Bruno Periera                     18
          TERMS & CONDITIONS of work
             for CONTRACT workers
• Hours of Work: 1 Shift – 12Hours
• Wages: basic RM 400 – RM 450
• Overtime: fixed amount, does not follow rates for
  normal days, rest days & public holidays OR none.
• Annual leave, Public holidays pay, Sick leave, Maternity
  leave - Not mandatory.
• No payment for legally mandated breaks.
• Pay cut for absent or late for work or on sick leave or on
  annual leave.
• Toilet breaks monitored – 2x for 12 hour shift
• Accommodation & Transport provided FoC.
                           Bruno Periera                       19
                   Types of
             contract FOR service
          (Kontrak untuk Perkhidmatan)
• Fixed Term Contract -
  (temporary or contract workers)

 workers hired by Outsourced Company to work in
 the principle company.
                                   - Locals & Foreign workers


                         Bruno Periera                      20
    There is no single conclusive test to distinguish a contract of employment from a contract
     for services. Some of the factors to be considered in identifying a contract of
     employment include:
     i) Control
•    Who decides on the recruitment and dismissal of employees?
•    Who pays for the employees' wages and in what ways?
•    Who determines the production process, timing and method of production?
•    Who is responsible for the provision of work?

• ii) Ownership of Factors of Production
• Who provides the tools and equipment?
• Who provides the working place and materials?

•    iii) Economic Considerations
•    Does he carry on business on his own account or carry on the business for the employer?
•    Does he involve in any prospect of profit or is he liable to any risk of loss?
•    How are his earnings calculated and profits derived?



                                            Bruno Periera                                21
Essential Clauses of Contract of Service :

• Commencement of employment;
• Appointment – job title and job scope;
• Hours of work;
• Probation period, if any;
• Remuneration;
• Employee's benefits (e.g. sick leave, annual leave,
  maternity leave);
• Termination of contract – notice period; and
• Code of conduct (e.g. punctuality, no fighting at work).
                            Bruno Periera                    22
                     LAWS ON PROTECTION OF
                       RIGHTS OF WORKERS
    STATUTE
•   Employment Act 1955
•   Industrial Relations Act 1969
•   Trade Unions Act 1959
•   Workmen’s Compensation Act 1952
•   Occupational Safety and Health Act 1994
•   Social Security Act 1969
•   Immigration Act 1959/63

     Contract of Employment
    The contract of employment stipulates terms and conditions on duration,
     wages, work shift, days off, sick leave, medical fees, payment of levy, visa,
     medical and travel.


                                      Bruno Periera                              23
             Modus operandi
  in getting permit for foreign workers.

1. Companies advertise job vacancies in front of their
   factory gates.
2. Company’s own Human Resource officer – interviews
   and identify potential candidates.
3. Identified candidates - sent to sign a contract with an
   outsource company, usually without receiving a copy.
                        • Is the contract a contract for service or
                                              contract of service?

                            Bruno Periera                         24
The “successful” candidate –
4.      Handed over to company Human
        Resource officer.
5. Provided with the company badge with a
   unique Number to denote “contract workers”.
6.     One week orientation and work
       process training.
7. Successful candidates sent to the Assembly
   line supervisor to start work as contract
   labour.
Workers not aware of the type of contract!
                      Bruno Periera              25
Not wanting to be exploited..
Locals QUIT…in PROTEST!
                                                 (albeit SILENTLY !)
Applying for PERMIT
• Due to the high attrition of contract labour.
  company applies to the government agencies (MOHR &
   KDN) for permit to bring in foreign workers.

The reasons often cited
    –   local workers are not keen on menial jobs,
    –   that they are pampered and like to “lepak”.
•   TREATEN to relocate operation to third country

                                 Bruno Periera                   26
          Sikap Pekerja Tempatan
• Tidak berminat berkerja lebih masa dan syif
• Terlalu memilih kerja
• Minat ganjaran yang tidak setimpal dengan produktiviti
• Tidak bersedia belajar kemahiran baru dan kerja pelbagai
  tugas
• Sukar menerima sistem kerja baru
• Mementingkan masa untuk riadah dan keluarga

                          Bruno Periera              27
  Facts not mentioned are:

• that the wages and benefits are intentional made
  unattractive,

• with unfair and archaic terms and conditions of
  service (Pre-Employment Act era).

• The silent protest.

                        Bruno Periera               28
  Breakdown of types of Employment contract in an American Semiconductor Assembly
  Breakdown of types of Employment contract in an American Semiconductor Assembly
         Plant of semi-skilled workers and Production Operators in Dec 2007
         Plant of semi-skilled workers and Production Operators in Dec 2007


             Permanent Contract of Service
                                                            1028        48 %
             for local workers


             Temporary Contract of Service
             for local workers                               110         5%
Company
             (3 to 6 months renewable)


             Temporary Contract of Service
             for foreign workers                            810         38 %
             (2 years renewable)

Employment
             Local contract workers                         210         10 %
Agency
TOTAL                                                       2158        100 %
                                      Bruno Periera                                 29
Cost Comparison - Local vs Migrant worker/ per month (RM)

  Cost Components                      Local worker    Migrant worker
 Basic Salary (as at end-2007)                   503        503
                         SRA                     47         47
   Contractual Bonus (1 mth)                     42         42
Performance Incentive (1 mth)                    42         42
              Shift Allowance                    76         76
               Life Insurance                     3          3
            Medical coverage                     64         64
              Transportation                     215        193
                          EPF                    89         nil
                   Levy & Visa                   nil        110
             Recruitment Fee                     nil        30
           Medical (Fomema)                      nil        16
       Hostel accommodation                      nil        230
     Workman Compensation                        nil         6
                      Air fare                   nil        40
      Total (RM)                            1,081          1,402
                                 Bruno Periera                          30
      Percentage                            100%           130%
          PURPOSE OF COMPANY
•   to make profit.

•   Corporate headquarters sets target – that
    labour cost should not exceed 6% of the
    manufacturing cost.
•   Hiring foreign workers will escalate cost of
    labour by 30%.


                        Bruno Periera              31
Local Management to achieve the target –

Wages & benefits are controlled :

• to subsidise the 30% additional labour cost in
  hiring foreign labour.

• maintain the 6% labour cost.
• without affecting the company’s bottom line
  profit.

                       Bruno Periera               32
Leading to current reality…..

 wages & benefits of the local workers are depressed
  artificially.

 type of employment contracts have deteriorated
  progressively
                                       replace local permanent contract
                                            with foreign contract labour.
                                     substitute with local contract labour

 Standard of living deteriorates while cost of living
  escalates.

         Race to the Bottom…unabated
                                Bruno Periera                           33
              Company achieves:
   Low wage cost.
   Disposable labour - hire & fire.
   Flexi-labour – Multi-skilling/Multi-tasking.
   Plug & play workers. (minimal training)
   No union (No negotiation powers)
   Subservient workforce.
   Convert workers wages into profits.
   Huge wages & bonus payout- Top Mgmt
        Perlumbaan menuju ke dasar …….
                         Bruno Periera             34
• High contract labour % improves NAV
  (Net Asset Value) of company.
 – by transferring labour cost to overhead /
  operation cost putting Company’s stock
  price looking good to shareholders.
 –Creative accounting.



                  Bruno Periera          35
Bruno Periera   36
      Problem solving technique.
                 INVESTIGATE (Past):
           How did the problem start?
            Who started the problem?
          When did the problem start?
           Why did the problem start?
          Where did the problem start?
-------------------------------------------------------------
             PLAN OF ACTION (Future):
        How to overcome the problem?
          Who overcome the problem?
       When to overcome the problem?
   Why should we overcome the problem?
           Where to begin the change?

                         Bruno Periera                          37
HOW IT ALL STARTED?
   It always starts small…….

 and grows ….. and grows………
 finally accepted as NORMAL


             Bruno Periera     38
                   PEKERJA ASING (PA)
LATAR BELAKANG

1992 -    Kerajaan meluluskan PA daripada
         ASEAN, Bangladesh, India dan Sri Lanka
         untuk sektor pembinaan dan perladangan.

• 2000 - Diperluaskan kepada sektor perkilangan
          dan perkhidmatan (hotel dan restoran).

• 2002 -   Meliputi semua sector

                      Sumber: Laporan Pesidangan Meja Bulat Mengenai
                       Penggajian PA Di M’sia - 5-Apr 2007 ISMK - KSM
                          Bruno Periera                             39
               OUTSOURCING
           (MEMBEKAL & MENGURUS)
• 2005 –
Mesyuarat Jawatankuasa Kabinet mengenai
Pekerja Asing (JKK-PA) ke-33 Bil. 2/2005 pada
5 Julai 2005 telah BERSETUJU untuk
menggaji PA melalui konsep
 OUTSOURCING.

                 Sumber: Laporan Pesidangan Meja Bulat Mengenai
                  Penggajian PA Di M’sia - 5-Apr 2007 ISMK - KSM
                     Bruno Periera                             40
• Outsourcing concept:
Outsourcing is a concept where the management and supply services are
  undertaken by companies selected by the government. The government
  shall select and supervise these companies who are reliable to be
  responsible to recruit, supervise and manage foreign workers and present
  the workers to customers who need them under the outsourcing concept.
• Aim:
The implementation of outsourcing aims to assist to overcome the problems of
  shortage of workers and small companies who do not have the resources to
  manage foreign workers full time will save cost. It will also help
  companies/management who needs large workforce from time to time
  especially to fulfill additional increase in contractual obligations, for peak
  seasonal collection of harvest and so on.
• Management:
The management of foreign workers shall be managed in an orderly and
  systematic manner. Accommodation, transportation, payment of wages of
  RM400, medical examination including insurance coverage shall be under
  the outsourcing company.


                                           Bruno Penggajian PA Di M’sia - 5-Apr 2007 ISMK - KSM
 Sumber: Laporan Pesidangan Meja Bulat MengenaiPeriera                                    41
• 2006 – Terdapat jumlah 1,800,000 PA

Negara sumber utama:
                   • Indonesia 1,174,000 (63%)
                    • Nepal      214,000 (11%)
                     • India     138,000 ( 7%)
                   • Myanmar 109,000 ( 6%)
                    • Vietnam    106,000 ( 6%)
                    • Bangladesh 63,000 ( 3%)
                    • Lain-lain   64,000 ( 4%)

                      Bruno Periera              42
Pembahagian PA mengikut sektor

  • Pembuatan      - 646,000     (35%)
  • Perladangan    - 354,000     (19%)
 • Pembantu Rumah - 311,000      (17%)
   • Pembinaan   - 268,000       (14%)
  • Perkhidmatan   - 167,000      ( 9%)
  • Pertanian     - 123,000       ( 7%)

           Jumlah PA = 1,800,000 (100%)

            Bruno Periera           43
                 IMPAK Pekeja Asing
• Dari Segi Ekonomi:

Kesan Positif:

• Menyumbang RM 17b (5.1%) kepada KDNK
• RM 8.3b (5.2%) kepada perbelanjaan persendirian
• RM 1.2b levi kepada hasil kerajaan (2004)


                       Sumber: Laporan Pesidangan Meja Bulat Mengenai
                        Penggajian PA Di M’sia - 5-Apr 2007 ISMK - KSM
                           Bruno Periera                             44
Kesan Negatif:
• Remit RM 5-7b setahun ke negara asal
• Kos perkhidmatan kesihatan RM117j
• Kemunculan semula penyakit tibi, malaria dan
  untut serta membawa penyakit baru seperti kala
  azar (Leishmaniasis).
• Mengurangkan tekanan kepada majikan bagi
  memperkenalkan automasi dan mekanisasi
• Mengurangkan tekanan ke atas kenaikan gaji
                   Sumber: Laporan Pesidangan Meja Bulat Mengenai
                    Penggajian PA Di M’sia - 5-Apr 2007 ISMK - KSM

                        Bruno Periera                          45
• Dari Segi Sosial:

• Kesatuan sekerja terancam

• Mengekang kadar upah dan jejas peningkatan
  taraf hidup rakyat

• Menjejaskan kerukunan sosial


                      Sumber: Laporan Pesidangan Meja Bulat Mengenai
                       Penggajian PA Di M’sia - 5-Apr 2007 ISMK - KSM
                          Bruno Periera                             46
Keselamatan Negara:

• Peningkatan kes jenayah dari 1333 (1992) kepada
  3113 (2002) – 133%

• Kos menjaga PA di penjara dan pusat tahanan

• Kos menghantar pulang PA


                   Sumber: Laporan Pesidangan Meja Bulat Mengenai
                    Penggajian PA Di M’sia - 5-Apr 2007 ISMK - KSM

                       Bruno Periera                          47
           Demographics (Dept. of Statistics, 2006)
• POPULATION                  26.63m
   - Women            13.07m
   - Men              13.56m
• EMPLOYMENT                  10.9m
   - Private sector     5.2m
   - Public sector      1.1m
  - Informal sector      4.6m
• Labour Participation rate:
     - Women              46% 4.0m
     - Men                86% 6.9m
• UNEMPLOYMENT                 3.5%
                           Bruno Periera              48
• Percentage of Foreign Workers against
  Private sector employees:



 1.8m/5.2m = 34.6%


                  Sumber: Laporan Pesidangan Meja Bulat Mengenai
                   Penggajian PA Di M’sia - 5-Apr 2007 ISMK - KSM

                      Bruno Periera                          49
NOW it grows… to
  take over…
employment from
     locals!
      Bruno Periera   50
 Malaysian Trades Union Congress
 LABOUR BULLETIN July 2008                        New Straits Time - July 20, 2008
                                             interview with Datuk Ishak Mohamed,
                                   Enforcement Director Immigration Department
Q:    Should foreign labour outsourcing be banned?
A:    Outsourcing is the best solution for the government
      to manage foreign workers.
Q:    Why?
A:    There are two scenarios
   • One is that as companies get bigger, they will need more
   manpower and with outsourcing they can get workers in a
   more organized way.
   •Two, outsourcing is good as it will attract foreign direct
   investment. Investors will not want unions to be formed in
   their establishments.
Through outsourcing, it would be difficult for unions to be
formed as outsourcing company, and not the factory, would be
the employer.
                                   Bruno Periera                              51
                 Monday, September 21, 2009, 02.03 PM

           Labour director-general Datuk Ismail Abdul Rahim
                            said yesterday.

We have introduced a quota system, where for

• the manufacturing sector dealing in exports it is two
  foreigners to one local and

• one local to one foreigner for all other
  sectors," he said.

                              Bruno Periera                   52
 Cabinet Committee on Foreign Workers
          and Illegal Workers.
Deputy PM: Tan Sri Muhyiddin Yassin.
• “The Laboratory*, had been directed to put
  outsourcing companies under the microscope to
  ensure that they stick to their role as providers of
  workers and NOT as EMPLOYERS”.
• 277 registered outsourcing companies.
• Laboratory – 8 ministries and 15 agencies.
                                          The Star Tue 23-Feb 2010


                          Bruno Periera                          53
                Malaysian Labour Markets
Labour Market :
•   Regulated by Employment laws.
•   Employer to submit returns (S62 EA) – statistics
•   Do not include outsource / contract workers
•   Transparent.

Labour Black Market :
•   Not sanctioned by law.
•   Statistics not available.
•   Involves outsource / contract workers.
•   Existing parallel to Labour Market
•   Underground – illegal?
                             Bruno Periera             54
                                      Statement by
              THE HONOURABLE DATUK DR.S.SUBRAMANIAM
               MINISTER OF HUMAN RESOURCES, MALAYSIA
                             AT THE 98TH SESSION OF
           THE INTERNATIONAL LABOUR CONFERENCE GENEVA.
                             THURSDAY, 11 JUNE 2009.
   ------------------------------------------------------------------------------
It is imperative that we take this crisis (Global Economic Crisis) as an
 opportunity to reaffirm our commitment to the principles of Decent
 Work and through such commitment the dignity and the rights of
 workers, as enshrined in the principles of Decent Work should continue
 to form the basis of the national agenda for our respective
 governments.
In Malaysia, we have instituted high ranking tripartite monitoring
mechanisms very much early in the crisis to ensure that the economic
consequences of this crisis does not step on the rights of our workers
as prescribed in the Constitution and in the laws of the country.

                                   Bruno Periera                             55
             Principles of Decent Work
Decent work is captured in four strategic objectives:

 fundamental principles and rights at work and
  international labour standards;
 employment and income opportunities;
 social protection and social security; and
 social dialogue and tripartism.

• Decent work is central to efforts to reduce poverty, and is
  a means for achieving equitable, inclusive and sustainable
  development.

                           Bruno Periera                    56
              Principles of Decent Work
• Decent work sums up the aspirations of people in their
  working lives. It involves
 opportunities for work that is productive and delivers a
  fair income,
 security in the workplace and social protection for
  families,
 better prospects for personal development and social
  integration,
 freedom for people to express their concerns, organize
  and participate in the decisions that affect their lives and
 equality of opportunity and treatment for all women and
  men.

                            Bruno Periera                        57
          CONTRACT LABOUR SYSTEM
       is AGAINST Decent work agenda.

DOES NOT provide opportunities for
 work that is productive.
DOES NOT deliver a fair income.
NO security in the workplace and social
 protection for families.
NO prospects for personal development
 and social integration.
                   Bruno Periera        58
              Employment Act in 1955
• With the introduction of the EA, the then British Administration
  effectively abolished the indenture labour, bonded labour and the
  “kanggani” system in Malaya, as it was known then.
• The totality of the Employment Act 1955 established two very
  important principles of law.
• They are:
   – Security of tenure – ensuring permanence of job and

   – Proprietary right to the job – where termination of worker, shall
     be with just cause and excuse & by due process.

• These principles are trite law and are considered sacrosanct.
• MUST be protected at all cost!

                                Bruno Periera                         59
Selamat berjuang


                      Bruno Periera

      Bruno Periera                   60

								
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