Texts of pending comments

The Committee notes with deep concern that the Government’s report, due since 2013, has not been received. In light of its urgent appeals launched to the Government in 2019 and 2020, the Committee proceeds with the examination of the application of this Convention on the basis of the information at its disposal.

Following its examination of the information at its disposal, the Committee notes that it is still missing important information on measures giving effect to Articles 4 and 5 of the Convention. The Committee is therefore bound to repeat its previous comments with regard to those Articles.

Articles 4 and 5 of the Convention. While recalling that in an earlier report the Government had indicated that the exceptions provided for in this Article do not exist in principle, the Committee wishes to observe that under modern conditions there is often a real need to keep certain establishments in operation on the day of weekly rest by reason of the nature of their activities (such as hospitals, continuous processes), or in exceptional cases (for example, major accidents, force majeure or urgent repair work). It therefore requests the Government to specify how effect is given to these Articles of the Convention, including the requirement to grant, as far as possible, compensatory rest to those performing work on their weekly rest day.

The Committee notes with deep concern that the Government’s reports on Convention No. 12, due since 2014, and on Convention No. 19, due since 2012, have not been received. In light of its urgent appeal launched to the Government in 2019, the Committee proceeds with the examination of the application of Conventions Nos 12 and 19 on the basis of the information at its disposal.

In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on workers’ compensation, the Committee considers it appropriate to examine Conventions Nos 12 (agriculture) and 19 (equality of treatment) together.

Article 1 of Convention No. 19. Equality of treatment. In its previous comments, the Committee noted the Government’s indication that all employed persons, irrespective of their nationality, receive equal treatment in respect of employment injury benefits provided by the Social Security Act of 1975 (Chapter 31:01). The Committee noted however, that by virtue of section 51 of the Social Security Act, the Government may modify or adapt the provisions of the Act to give effect to international agreements providing for reciprocity in matters of social security. In this regard, the Committee recalls that, in accordance with Article 1 of the Convention, workers from countries party to Convention No. 19, as well as their dependants, need to be granted the same treatment as nationals in respect of occupational accidents, irrespective of the existence of reciprocity agreements to this effect with their country of origin. The Committee therefore requests the Government to confirm that the Social Security Act of 1975 is applied in such a way so as to ensure equality of treatment in respect of employment injury benefits for workers from countries party to Convention No. 19, as well as their dependants with a view to giving full effect to Article 1 of the Convention. The Committee further requests the Government to indicate whether the provisions of the Social Security Act of 1975 by virtue of its section 51 have been modified or adapted pursuant to international agreements providing for reciprocity in matters of employment injury benefits.

Article 1(2) of Convention No. 19. Payment of benefits abroad. In its previous comments, the Committee requested the Government to provide information on the application of the provisions of the Social Security Act of 1975 in cases where victims of industrial accidents or their dependents reside outside Dominica. The Committee observes that Dominica is a party to the Caribbean Community (CARICOM) Agreement on Social Security of 1996, which provides for the maintenance of acquired social security rights, including in respect of employment injury benefits, and of rights in the course of acquisition for the nationals of its Contracting Parties when they change the place of residence. The Committee recalls that according to Article 1(2) of the Convention, in the application of the principle of equality of treatment the payment of worker's compensation outside the Member's territory shall be regulated, if necessary, by special arrangements between the countries parties to Convention No. 19. The Committee therefore requests the Government to provide information on any special arrangements on the payment of employment injury benefits abroad which may have been made with other Member states, not party to the (CARICOM) Agreement on Social Security. In case of the absence of such special arrangements, the Committee requests the Government to indicate whether employment injury benefits may be paid to persons having suffered industrial accidents or their dependants who reside in the Member states party to Convention No. 19: (a) in the case of Dominican nationals; and (b) in the case of foreign workers.

Application of Conventions Nos 12 and 19 in practice. (i) Number of workers covered and number of benefits awarded out of total number of employment injuries. In relation to its previous comments concerning the application of Conventions Nos 12 and 19 in practice, the Committee observes from the 2017 Annual report of the Dominica Social Security (DSS) Fund that 245 foreign workers, originating mainly from Haiti, Colombia, the Dominican Republic, Cuba, Antigua and Barbuda, and Saint Lucia, were registered within the DSS in 2017. The Committee also observes from the 2017 Annual report of the DSS that in 2017, there were 2 cases of employment injury benefits awarded in the sectors of agriculture, hunting and forestry, whereas the total number of employment injury benefit awards was 113 across all types of economic activities. The Committee requests the Government to provide statistical data on the total number of workers employed in agriculture and the number of occupational accidents reported and compensated in agriculture. The Committee also requests the Government to provide statistical data on the number and nature of the accidents reported and compensated in the case of foreign workers, across all sectors of economic activity, as well as the total number of foreign workers in Dominica, their nationality and occupational distribution.

(ii) Inspection services. Concerning the organization and functioning of inspection services as regards industrial accidents, the Committee observes from the information available on the website of the DSS that by virtue of section 12 of the Social Security Act of 1975, social security inspectors may visit any place where persons are employed, and conduct appropriate investigations. The Committee requests the Government to provide information on the number of inspection visits and violations detected by social security inspectors, and to supply the extracts from the reports of the inspection service, if available. The Committee also refers the Government to its comments under the Labour Inspection Convention, 1947 (No. 81), with respect to the number and conditions of service of labour inspection staff, frequency of labour inspection visits as well as data collection and reporting.

In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on wages, the Committee considers it appropriate to examine Conventions Nos 26 (minimum wage) and 95 (protection of wages) together.

The Committee notes with deep concern that the Government’s reports on Conventions Nos 26 and 95, due since 2016, have not been received. In light of its urgent appeals launched to the Government in 2019 and 2020, the Committee proceeds with the examination of the application of Conventions Nos 26 and 95 on the basis of the information at its disposal.

Articles 1, 2 and 3 of Convention No. 26. Minimum wage-fixing machinery and its coverage. Participation of social partners. The Committee previously noted that, following the implementation in 2008 of the minimum wage recommended by an advisory board in 1998, a new Minimum Wage Advisory Board (MWAB), comprising representatives of the Ministries of Finance and Agriculture as well as three employer and three worker members, was appointed to raise the minimum wage based on information from all stakeholders and comparative data from countries within the Caribbean Community.

The Committee notes that, according to a press release published on the Government’s official website, the Minister with responsibility for labour indicates that: (i) the Cabinet of Dominica has taken the decision to increase the minimum wage, effective from 1 September 2021, set per categories of workers, seeking to cover the most vulnerable ones; (ii) this revision was carried out through consultations with all stakeholders (including within the MWAB), a market survey and technical assistance from the ILO; (iii) this minimum wage review is a first step of an annual or bilateral review undertaken to refine the minimum wage and to monitor the effects of the new minimum wage for the relevant categories. The Committee requests the Government to provide information on any development regarding the envisaged review of the minimum wage in the country, including details on consultations held within the framework of the Minimum Wage Advisory Board or on any other form of participation by employers’ and workers’ representatives in this regard.

Article 2 of Convention No. 95. Scope of application. The Committee had previously noted that the Protection of Wages Act only applies to workers performing manual labour, while clerical workers are excluded from its scope of application (section 2). It had also noted that under the Labour Contracts Act, certain categories of workers other than manual workers (except, notably, for state employees, part-time workers and agricultural workers) also enjoy wage protection, but only insofar as the method and periodicity of payment are concerned. Based on this, the Committee had requested the Government to ensure that the protection contemplated in the Convention is extended to all workers who are not currently covered by the above Acts. The Committee notes that there seems to be no information publicly available indicating that progress has been made in this regard. The Committee recalls that, in its first report, the Government did not indicate any category of persons which it proposed to exclude from the application of all or any of the provisions of the Convention, in accordance with Article 2(1) of the Convention. The Committee once again requests the Government to take the necessary measures to ensure that the protection contemplated in the Convention is extended to all workers who are not currently covered by the abovementioned Acts.

Article 4. Partial payment of wages in kind. In previous comments, the Committee noted that section 13 of the Protection of Wages Act provides that nothing in this Act shall render illegal an agreement or contract with a worker for giving to him food, a dwelling place or other allowance or privileges in addition to money wages as a remuneration for his services, but so that no employer shall give to a worker any intoxicating liquor by way of such remuneration. In this respect, the Committee recalled that only the payment of part of the wage in kind can be authorized under Article 4, and that adequate measures must be taken to ensure that: (i) such allowances are appropriate for the personal use and benefit of the worker and his or her family; and (ii) the value attributed to such allowances is fair and reasonable. The Committee notes that no available information seems to indicate that progress has been made in this regard. The Committee requests the Government to take the necessary measures to ensure that full effect is given to this Article of the Convention and to provide information on any progress made in this regard.

Article 8. Deductions from wages. The Committee notes that section 8 of the Protection of Wages Act prohibits deductions except in the case of injury to materials or other property of an employer occasioned by the wilful misconduct or neglect of a worker. It also notes that section 19 of the same Act prescribes that an employer may, with the consent of the worker, make deductions from the wages of the worker and pay to the appropriate person any contributions to provident or pension funds or schemes agreed to by the worker and approved by the Labour Commissioner. Noting that no specific limits are established in the abovementioned Act in relation to the amounts of possible deductions and that no overall limit exists in the legislation, the Committee recalls that, in addition to setting specific limits for each type of deduction, it is also important to establish an overall limit beyond which wages cannot be further reduced, in order to protect the income of workers in the case of multiple deductions. The Committee requests the Government to provide information on the measures taken or envisaged in this regard and on the application of section 8 of the Protection of Wages Act, in practice, particularly regarding the procedure in place for the determination of workers’ liability in this context.

The Committee notes with deep concern that the Government’s report, due since 2014, has not been received. In light of its urgent appeal launched to the Government in 2019, the Committee proceeds with the examination of the application of the Convention on the basis of the information at its disposal.

Articles 1(1) and 2(1), (2)(a) and (d) of the Convention. National service obligations. The Committee had previously noted that under the National Service Act, 1977 persons between the ages of 18 and 21 are required to perform service with the National Service and that such service includes performing such duties as may be prescribed and, where possible, be engaged in development and self-help projects concerning housing, school, construction, agriculture and road building. Section 35(2) of the Act prescribes a penalty of a fine and imprisonment for failing to comply with this obligation. While noting the Government’s indication that section 35(2) had not been applied in practice, the Committee observed that this provision was not in conformity with the Convention and for a number of years, has been requesting the Government to formally repeal or amend it.

The Committee notes from the 2020 reply of the Government to the list of issues raised by the United Nations Human Rights Committee that the repeal of section 35(2) of the National Service Act has been included in the legislative agenda of the country (CCPR/C/DMA/RQAR/1 paragraph 59). The Committee recalls that the Convention explicitly provides for a limited number of cases in which ratifying States may exact compulsory labour from the population, particularly in the context of compulsory military service or normal civic obligations. However, the conditions under which compulsory work is exacted are strictly defined and the work or service involved must respond to specific requirements. The Committee observes that the work that could be exacted under the National Service Act does not correspond to any of the exceptions provided for under Article 2(2) of the Convention. In particular, it goes beyond the exception authorized under Article 2(2)(a) for work imposed under compulsory military service, which should be limited to work of a purely military character. Therefore, the Committee expresses the firm hope that the Government will take the necessary measures to ensure that the National Service Act is formally repealed or amended so as to bring the national legislation into conformity with the Convention, and it requests the Government to provide information in this respect. The Committee reminds the Government that it may avail itself of the technical assistance of the Office in this regard.

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

Articles 1(1), 2(1) and 25 of the Convention. Trafficking in persons. In its previous comments, the Committee noted the adoption of the Transnational Organized Crime (Prevention and Control) Act 2013, Act 13 of 2013. Section 8(1) of the Act incorporates the offence of trafficking in persons, defined as the situation in which a person, for the purpose of sexual or labour exploitation of another person, organizes or facilitates the entry, exit from or receipt into Dominica of another person, through means including threats or use of force or other forms of coercion, abduction, deception or fraud, the abuse of power or the position of vulnerability, or the giving or receiving of payments or of a benefit to obtain the consent of a person who has control over another person. In addition, under section 8(5) of the Act, the person who, for the purpose of exploitation, recruits, transports, transfers, harbours or receives another person by any of the above-mentioned means also commits the offence of trafficking in person. The Committee observes that, according to section 13 of the Act, the penalty for trafficking in person consists of a fine or imprisonment for 15 years or both (increased penalty when the victim is a child). In addition, the Court may order the offender to pay to the victim a restitution that covers the costs of medical and rehabilitation treatment, the necessary transportation and housing, lost income, legal costs and compensation for emotional distress, pain and suffering. The Committee wishes to recall that according to Article 25 of the Convention, penalties imposed by the law for the illegal exaction of forced or compulsory labour must be adequate and strictly enforced. The Committee has considered in that respect that a fine does not constitute an effective sanction in light of the seriousness of the violation and the fact that the sanctions needs to be dissuasive (2012 General Survey on the fundamental Conventions, paragraph 319). The Committee therefore requests the Government to provide information on the application in practice of sections 8(1) and (5) of the Transnational Organized Crime (Prevention and Control) Act of 2013, including information on the number of investigations, prosecutions and convictions handed down under such provisions, as well as on the nature of the penalties imposed on perpetrators. The Committee also requests the Government to provide information on the number of cases in which a Court has ordered the payment of a restitution to a victim of trafficking in persons. Finally, the Committee requests the Government to provide information on the measures taken or envisaged to prevent trafficking in persons, to ensure proper identification by law enforcement bodies of cases of trafficking for both sexual and labour exploitation, and to provide protection to the victims.

Idle persons. The Committee previously noted that according to section 49(1) of the Small Charges Act, Chapter 10:39 any person being able wholly or in part to maintain himself by work or by other means, and wilfully refusing or neglecting to do so, is deemed an idle and disorderly person and liable to imprisonment for one month. For a number of years, the Committee has been requesting the Government to take the necessary measures to bring this provision into conformity with the Convention. The Committee notes from the 2020 Reply of the Government to the list of issues raised by the United Nations Human Rights Committee that section 49(1) of the Small Charges Act will be dealt with in the next law review and that it has not been used to imprison anyone (CCPR/C/DMA/RQAR/1 para. 63). The Committee wishes to recall that provisions concerning vagrancy and similar offences, if defined in an unduly extensive manner, are liable to become a means of compulsion to work and may even result in a situation similar to that where the law imposes a general obligation to work (General Survey on the eradication of forced labour, 2007, paragraph 88). The Committee once again requests the Government to take the necessary measures to amend or repeal section 49(1) of the Small Charges Act in order to bring the legislation into conformity with the Convention, and to provide information on any progress made in this regard.

Article 2(2)(c). Prison labour. In its previous comments, the Committee noted that under section 61(2) of the Prison Rules, Chapter 12:70 of the Revised Laws of Dominica 1990, work by prisoners for the private benefit of any person is prohibited except when authorized by the Superintendent of Prisons. The Committee notes that according to the website of the Ministry of National Security & Home Affairs, a Prisons Services Division was established under the Prisons Act, Chapter 12:70. The Committee also notes from the information available on the website of the Dominica Prison Service that programmes for inmates have been put in place in the area of carpentry and woodwork, as well as farming and animal husbandry. The Committee further notes that under sections 59 and 60 of the Prison Rules, prisoners shall be required to engage in useful work for not more than 10 hours a day and may receive payment for such work. According to section 20 of the Prisons Act, prisoners employed outside the walls of a prison shall be subject to the prison regulations and shall be deemed to be in custody of the Superintendent in like manner as they were within the prison. The Committee requests the Government to indicate whether the Superintendent of Prisons has authorized that prisoners be hired to or placed at the disposal of private entities.

The Committee notes with deep concern that the Government’s reports on Convention No. 81, due since 2014, and on Convention No. 150, due since 2015, have not been received. In light of its urgent appeal launched to the Government in 2020, the Committee proceeds with the examination of the application of the Conventions on the basis of the information at its disposal.

In order to provide a comprehensive view of the issues relating to the application of the ratified Conventions on labour administration and labour inspection, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and 150 (labour administration) together.

A. Labour inspection

Labour Inspection Convention, 1947 (No. 81)

Article 3 of the Convention. Functions of labour inspection. The Committee notes that inspectors, as defined under the Labour Standards Act, ensure the enforcement of provisions relating to wages, working hours and employment conditions (section 28(2)), while safety officers, as defined under the Employment Safety Act (section 8) are responsible for the inspection of working conditions that affect occupational safety and health. The Committee requests the Government to indicate through what measures or activities inspectors and safety officers: (i) provide technical information and advice to employers and workers concerning the most effective means of complying with the legal provisions; and (ii) bring to the notice of the competent authority defects or abuses not specifically covered by existing legal provisions, as required by Article 3(1)(b) and (c) of the Convention.

Articles 4, 6, 7, 8, 10 and 16. Central authority. Number and conditions of service of labour inspection staff. Frequency of inspection visits. The Committee notes that, according to the information available on the official website of the Government, the Division of Labour is now under the Ministry of National Security and Home Affairs. The Committee notes that the Government Directory of officials in the Division of Labour includes the Labour Commissioner, the Deputy Labour Commissioner and labour officers. It is not clear which of these officials perform the functions of inspectors and safety officers, and there is no information on how the inspection activities are performed. The Committee requests the Government to indicate which officials in the Division of Labour perform the functions of inspectors and safety officers. It also requests the Government to provide information on the employment status of the inspectors and safety officers, as well as the recruitment procedures, qualification requirements and trainings available to them. The Committee finally requests the Government to provide information on the frequency of inspection visits carried out by both inspectors and safety officers, with a view to ensuring that all workplaces are inspected as often and as thoroughly as necessary.

Article 11. Necessary equipment and material resources available to labour inspectors. The Committee requests the Government to provide information on the provision of necessary equipment and material resources to inspectors and safety officers for the performance of their duties, including suitably equipped offices, transport facilities and reimbursement of expenses.

Articles 14, 20 and 21. Data collection and reporting. Publication and content of annual report. The Committee observes that there does not seem to be any information regarding the notification of industrial accidents and cases of occupational diseases to the Division of Labour. The Committee further notes that no recent annual reports on inspection services have been published or submitted. The Committee requests the Government to provide information on the arrangements for the notification of industrial accidents and occupational diseases in practice. The Committee also requests the Government to take the necessary measures to ensure that an annual report on the work of the labour inspection services is prepared and published, and that it contains information on all the items listed under Article 21 of the Convention, notably, statistics of inspection visits, violations and penalties imposed, as well as industrial accidents and cases of occupational disease.

B. Labour administration

Labour Administration Convention, 1978 (No. 150)

Articles 1 and 4 of the Convention. Organization and operation of the labour administration system. The Committee notes that the Division of Labour is now under the Ministry of National Security and Home Affairs, consisting of a Labour Commissioner, Deputy Labour Commissioner, labour officers, a senior clerk, a senior executive officer and a tribunal officer. The Committee requests the Government to provide information on the functions and responsibilities of each of those positions, and on how those functions and responsibilities are coordinated within the labour administration system.

Articles 5, 6 and 8. Consultations within the system of labour administration. Formulation and monitoring of national labour policy. Participation in the preparation of a national policy concerning international labour affairs. The Committee previously noted that, according to the Government, the Industrial Relations Advisory Committee (IRAC), which is tripartite, is involved in the formulation of the national policy and the preparation of policy concerning international labour affairs, through the submission of draft legislation to Parliament. However, the Committee also recalls that, according to the observations submitted by the Waterfront and Allied Workers Union in 2010 the IRAC was inactive. The Committee also notes that, according to section 7 of the Employment Safety Act, consultative and advisory committees, consisting of the Ministers responsible for planning and health and representatives of employers and workers, may be established to advise on any matters in relation to the administration of the Act, to assist in the establishment of reasonable standards of safety, and to recommend regulations respecting safe employment practices, procedures and techniques. The Committee requests the Government to provide information on the activities carried out by the IRAC, including specifically all activities carried out since 2018, and to provide information on the scope of the IRAC’s proposals, together with any relevant documents on its meetings. It also requests the Government to indicate whether any consultative and advisory committees, as provided for under section 7 of the Employment Safety Act, have been established, and if so, to provide further information on their functioning in practice. Regarding the preparation of policy concerning international labour affairs, the Committee also refers to its comments under the Tripartite Consultation (International Labour Standards) Convention, 1976 (No. 144).

Article 7. Extension of the functions of the system of labour administration. The Committee notes that, according to the information provided by the Government in its first report, the national labour legislative system does not cover workers who are not employees, and the Division of Labour does not have the mandate to consider this extension. The Committee requests the Government to indicate whether it has any plans to extend the functions of labour administration to include activities relating to the conditions of work and working life of categories of workers who are not, in law, employed persons, as set forth in Article 7(a)–(d) of the Convention.

Article 10. Human resources and material means for the labour administration system. The Committee notes that, according to the information in the Government’s first report, the recruitment of officials in the labour administration falls under the purview of the Public Service Commission and is regulated by the Public Services Act. The Government also indicated that the status of staff of the labour administration and the conditions of services are negotiated between the Establishment, Personnel and Training Department and public personnel unions, such as the Dominica Public Service Union, and reflected in memorandum agreements and general orders. Moreover, specialized technical trainings are available both internally and with external collaboration. The Government further stated that financial resources for the performance of labour administration duties are allocated and budgeted for in the annual estimates of the Government, and are subject to the annual budget change. The Committee requests the Government to provide further information on the recruitment procedure and qualifications required for labour administration personnel. It also requests the Government to provide detailed information on the status and conditions of service of those personnel, including copies of related memorandum agreements and general orders, as well as on the content of initial and in-service trainings. The Committee finally requests the Government to provide information, as far as possible, on the elements taken as a basis to determine the annual budgetary allocation for the material means and financial resources available to the labour administration.

The Committee notes with deep concern that the Government’s report, due since 2013, has not been received. In light of its urgent appeal launched to the Government in 2020, the Committee proceeds with the examination of the application of the Convention on the basis of whatever information is at its disposal. The Committee recalls that it has been raising issues concerning the observance of the Convention in relation to certain sections of the Industrial Relations Act (Act No. 18 of 1986) concerning compulsory arbitration and which unduly restrict the right of workers’ organizations to organize their activities in full freedom and to formulate their programmes. The Government has been requested to make the following amendments to the Act: (i) exclude the banana, citrus and coconut industries as well as the port authority, from the schedule of essential services annexed to the Act, which makes it possible to stop a strike in these sectors by compulsory arbitration, and (ii) amend sections 59(1)(b) and 61(1)(c) of the Act, which empower the Minister to refer disputes to compulsory arbitration if they concerned serious issues in his or her opinion. Not having received any additional observations from the social partners, nor having at its disposal any indication of progress on these pending matters, the Committee refers to its previous observation adopted in 2011 and urges the Government to provide a full reply thereto. To this end, the Committee recalls that the Government may avail itself of the ILO’s technical assistance.

[The Government is asked to reply in full to the present comments in 2022.]

The Committee notes with deep concern that the Government’s report has not been received. It expects that the next report will contain full information on the matters raised in its previous comments. The Committee informs the Government that, if it has not supplied replies to the points raised by 1 September 2022, then it may proceed with the examination of the application of the Convention on the basis of the information at its disposal at its next session.

Repetition

Article 6 of the Convention. Implementing legislation. The Committee notes that the Government has never supplied any information of a practical nature concerning the application of the Convention. It would therefore be grateful if the Government would collect and transmit together with its next report up-to-date information on the average number of public contracts granted annually and the approximate number of workers engaged in their execution, extracts from inspection reports showing cases where payments have been retained, contracts have been cancelled or contractors have been excluded from public tendering for breach of the Fair Wages Rules, as well as any other particulars which would enable the Committee to have a clear understanding of the manner in which the Convention is applied in practice.

Moreover, the Committee understands that the Government has entered into a World Bank-financed technical assistance project for growth and social protection with a view to improving, among other things, the transparent operation and the efficient management of public procurement. In this connection, the Committee would appreciate receiving additional information on the implementation of this project and the results obtained, in particular as regards any amendments introduced or envisaged to public procurement laws and regulations which might affect the application of the Convention.

The Committee notes with deep concern that the Government’s report has not been received. It is therefore bound to repeat its previous comments. The Committee informs the Government that, if it has not supplied replies to the points raised by 1 September 2022, then it may proceed with the examination of the application of the Convention on the basis of the information at its disposal at its next session.

Repetition

Article 6 of the Convention. Legislation giving effect to the Convention. The Committee notes that the Government has never supplied any information of a practical nature concerning the application of the Convention. It would therefore be grateful if the Government would collect and transmit together with its next report up-to-date information on the average number of public contracts granted annually and the approximate number of workers engaged in their execution, extracts from inspection reports showing cases where payments have been retained, contracts have been cancelled or contractors have been excluded from public tendering for breach of the Fair Wages Rules, as well as any other particulars which would enable the Committee to have a clear understanding of the manner in which the Convention is applied in practice.

Moreover, the Committee understands that the Government has entered into a World Bank-financed technical assistance project for growth and social protection with a view to improving, among other things, the transparent operation and the efficient management of public procurement. In this connection, the Committee would appreciate receiving additional information on the implementation of this project and the results obtained, in particular as regards any amendments introduced or envisaged to public procurement laws and regulations which might affect the application of the Convention.

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

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

The Committee notes with deep concern that the Government’s report, due since 2012, has not been received. In light of its urgent appeal launched to the Government in 2019, the Committee proceeds with the examination of the application of the Convention on the basis of the information at its disposal.

Article 1 of the Convention. Obligation to provide information. In its previous comments the Committee requested the government to provide information on the practical application of relevant laws and national policies, as well as updated statistical information on migrant workers. The Committee notes that in its 2019 national report to the United Nations Universal Periodic Review (UPR), the Government indicated that Dominica has a large influx of migrants particularly from Haitian and Dominican Republic, and that migrant workers actively contribute to sectors such as building and construction, agriculture, hairdressing and barber shop, and clothing and textiles. In addition, the Report of the Office of the United Nations High Commissioner for Human Rights to the in the framework of the UPR drew attention to data indicating that in 2015 there were 6,720 migrants living in Dominica permanently as residents but that after Hurricane Maria, migrants had largely remained undocumented and in an irregular situation (See A/HRC/WG.6/33/DMA/1, paragraphs 24 and 25, and A/HRC/WG.6/33/DMA/2, paragraph 63).

The Committee also notes that the National Resilience Development Strategy 2018–2030 foresees the development of a Population Policy and Action Plan that includes the integration of migrant workers in society and the formal labour market including through initiatives such as language training and integration courses with an orientation focus on the standards of the state, particularly around business and labour. The Committee once again requests the Government to provide information on:

(i) the practical application of relevant laws and national policies regarding migrant workers, in particular in light of the consequences of Hurricane Maria;
(ii) information on the measures taken to implement the Population Policy and Action Plan as regards migrant workers; and
(iii) statistics on the number, places of origin and sectors of activity of migrant workers in Dominica, disaggregated by sex.

In addition, the Committee requests the Government to provide information on the adverse impact of the Covid-19 pandemic on migrant workers’ situation, and on any measures taken in this regard.

Articles 2 and 3. Accurate information and misleading propaganda relating to emigration and immigration. In its last comments, the Committee noted that Dominica was used as a staging ground to smuggle persons to neighbouring territories. Recalling that unscrupulous agents who profit from migration flows may have interest in disseminating erroneous information on migration processes, it requested the Government to indicate any measures taken to combat such activities. In this regard, the Committee notes the adoption of the Transnational Organized Crime (Prevention and Control) Act 13 of 2013, which criminalizes the act of “trafficking in persons” and “smuggling of persons”. The Committee also notes that, in the Government’s website, there is information available on the requirements for temporary and permanent residency permits, and that the Diaspora Unit published, in 2012, the Returning Nationals Information Manual. The Committee requests the Government to provide details on the application of Act 13 of 2013 in practice. It also requests the Government to communicate on any measures taken to: (i) raise awareness regarding human trafficking in the country and protect migrant workers from misleading propaganda leading to unscrupulous intermediaries; and (ii) further provide information about migration processes to migrant workers or returning migrants.

Article 6. Equal treatment. The Committee recalls that the principle of equality and non-discrimination is at the heart of this Convention and notes that while there is considerable awareness and acceptance among member States of the principle in its general application, there is less certainty about its application to migrant workers. It further notes that the multiple forms of discrimination and inequalities to which migrant workers are subject in countries of employment, in particular woman migrant workers, has been recognized as a persistent challenge. The Committee therefore requests the Government, once again, to provide information on the specific legal provisions adopted and practical measures taken to ensure that all men and women migrant workers enjoy equal treatment concerning all the areas covered in Article 6(1) of the Convention, including information on relevant judicial decisions or cases addressed by the competent authorities.

Articles 1, 7 and 10. Cooperation between States. The Committee notes that Dominica is a member of the Caribbean Community and Common Market (CARICOM), as well as the Organization of Eastern Caribbean States (OECS). The Committee further notes that CARICOM has developed various bodies and schemes which include the CARICOM Single Market and Economy (CSME). The Committee also takes note that both the CARICOM and the OECS have developed freedom of movement regimes which includes freedom of labour among member states. In this regard, the Committee observes that in February 2019 Dominica signed the CARICOM’s Protocol of Contingent Rights, which permits nationals of participating Member States as well as their spouses and immediate dependent family members to access social services, and to move under the CSME. In addition, the Committee also notes that the 2015 OECS Policy on Rights Contingent to the Right of Freedom of Movement Within the Economic Union permits OECS citizens as well as their spouses and dependants, to access residency and social rights.

Finally, the Committee notes that the regional review for Latin America and the Caribbean on the implementation of the Global Compact for Safe, Orderly and Regular Migration was held on April 2021, with the objective to provide a common platform where Member States and all other stakeholders can contribute to the debate on the challenges, progress and needs in the implementation of the Global Compact in the region. In light of these regional integration policies, the Committee requests the Government to provide updated information on:

(i) the implementation of freedom of movement agreements in the CSME and the OECS in the country, particularly as regards the implementation of the provisions of the Convention, as well as on any other agreements of this sort; and
(ii) the measures taken or envisaged within the framework of the Global Compact regarding migrants leaving or entering the country seeking employment.

In addition to the above, the Committee further requests the Government to continue providing information concerning the participation of Dominicans in the Canada/Caribbean Seasonal Agricultural Workers Programme and other schemes of this type.

The Committee notes with deep concern that the Government’s report, due since 2015, has not been received. In light of its urgent appeal launched to the Government in 2019, the Committee proceeds with the examination of the application of the Convention on the basis of the information at its disposal.

Articles 1 and 2 of the Convention. Equal remuneration for men and women for work of equal value. Definition of remuneration. Legislation. In its last comments, the Committee asked the Government to provide information on the status of the recommendations forwarded to the Minister of Labour in the framework of the amendment process to align its legislation with the proposed Caribbean Community (CARICOM) Model legislation on equal remuneration for work of equal value. Over the years, the Committee has indicated on various occasions that section 24 of the Labour Standards Act is more restrictive than the principle enshrined in the Convention. The Committee observes that section 24 refers to equal wages for men and women in the same business who are performing, under the same working conditions, the same or similar work or jobs requiring similar skill, effort and responsibility. Likewise, the Committee notes that the term “wages” used in the Labour Standards Act is not defined, while the Public Service Management Act defines “remuneration” as “salary and any allowance which is payable in money and which ranks as pensionable emolument”. In this regard, the Committee recalls that “remuneration” as defined in Article 1(a) of the Convention includes emoluments paid whether in cash or in kind, and that the concept of “work of equal value” under the Convention encompasses not only the same work, or work in the same occupation or activity, performed by men and women under the same conditions and specifications, but should also allow for the comparison of work traditionally performed by men (for example, construction work) and women (for example, nursing) that is of an entirely different nature, but which may or may not be of equal value. The Committee also points out that the application of the principle of equal remuneration for work of equal value is not limited to comparisons between men and women in the same establishment or with the same employer (see General Survey on fundamental Conventions, 2012, paragraphs 673–697). While acknowledging the difficult situation prevailing in the country following the passage of Hurricane Maria, the Committee asks the Government to provide information on measures taken to ensure that legislation gives full expression to the principle of equal remuneration for men and women for work of equal value and includes a definition of remuneration in line with the Convention.

Gender pay gap and occupational segregation. The Committee takes note of the indication, in the country’s Resilience Development Strategy 2030, that participation in skills and training programs is significantly larger by women than by men, but that female participation in the labour force continues to be aligned to stereotypical female fields. It also notes that one of the measures foreseen in the Strategy is to strengthen capacity-building opportunities for women, girls and vulnerable groups to scale up their participation in decision making and in the labour market (National Resilience Development Strategy Dominica 2030, pp. 126–128). The Draft National Gender Policy 2018–2028 also includes measures to increase women’s representation in politics. The Committee recalls that occupational gender stereotyping results in certain jobs being held almost exclusively by women, resulting in “female jobs” being undervalued for purposes of wage rate determination (see General Survey, 2012, paragraph 713). The Committee asks the Government to provide detailed information on the measures taken or envisaged to: (1) scale up the presence of women in all sectors of the economy; and (2) strengthen capacity-building opportunities for women and girls, including on the types of trainings offered, the sectors they concern and how women’s access is ensured.

Article 3. Objective job evaluation. The Committee asks the Government, once again, to provide information on the outcome of the job evaluation process in the public sector and the measures taken to ensure that it was free from gender bias, as well as on any measures taken to promote objective job evaluation in the private sector.

Article 4. Awareness-raising and cooperation with employers’ and workers’ organizations. The Committee notes that the country’s Resilience Development Strategy 2030 includes measures to promote gender sensitivity education and training to build a society that champions gender issues (p. 128). It also notes the Government’s indication, in its reply to the United Nations Human Rights Committee, that the Bureau of Gender Affairs has embarked on gender sensitization and mainstreaming trainings and public awareness action and adds that the Government is currently working towards the adoption of a Draft National Gender Policy 2018–2028 (CCPR/C/DMA/RQAR/1, 21 April 2020, paragraphs 34 and 37). The Committee also notes that the Labour Standards Act requires that an advisory board for the establishment of minimum wages shall be equally representative of employees and employers. The Committee asks the Government to provide information on awareness-raising and cooperation undertaken with employers’ and workers’ organizations to give effect to the principle of equal remuneration for men and women for work of equal value, including in the framework of the Resilience Strategy and the Draft National Gender Policy 2018–2028.

The Committee notes with deep concern that the Government’s report, due since 2014, has not been received. In light of its urgent appeal launched to the Government in 2019, the Committee proceeds with the examination of the application of the Convention on the basis of the information at its disposal.

Article 1(a) of the Convention. Sanctions involving compulsory labour as a punishment for holding or expressing political views or views ideologically opposed to the established political, social or economic system. In its previous comments, the Committee noted that under section 5 of the Seditious and Undesirable Publications Act, Chapter 10:03 of 1968 a person who engages in seditious acts, make seditious pronouncements, or produces, publishes, sells or distributes seditious publications is liable to imprisonment. Section 3(1) defines seditious intention as including, among others, a false statement or wilful misrepresentation of facts or of the motives of intentions of the Government or any Officer or minister of the Government to excite dislike or discontent with the Government. The Committee also noted that section 6(4) of the Act, read together with section 12, provides for a penalty of imprisonment for the production, reproduction, possession and distribution of publications prohibited by an Order or notice. The Committee observed that the above-mentioned provisions of the Seditious and Undesirable Publications Act were broadly defined. Noting that according to section 59 of the Prison Rules, Chapter 12:70, as amended as of 1990, persons convicted to a sentence of imprisonment can be required to undertake compulsory labour, the Committee requested the Government to provide information on the application in practice of the above-mentioned provisions of the Seditious and Undesirable Publications Act.

The Committee notes that in its 2020 concluding observations for Dominica, the United Nations Human Rights Committee referred to the Libel and Slander Act, chapter 7:04, as amended as of 1979 expressing its concern about the disproportionate sanctions in relation to defamation established therein and its impact on the exercise of freedom of expression (CCPR/C/DMA/COA/R/1, paragraph 41). According to section 6 of this Act, any person, who maliciously publishes any defamatory libel, is liable to imprisonment of up to one year. The Committee also notes that the Government indicates in its 2020 reply to the issues raised by the UN Human Rights Committee that a number of journalists in Dominica have been found guilty of defamation of individuals serving in Government, as well as in the opposition and the general public (CCPR/C/DMA/RQAR/1, para. 86).

The Committee recalls that under Article 1(a) of the Convention, persons who have expressed certain political views or views ideologically opposed to the established political, social or economic system should not be punished with sanctions involving compulsory labour. The Committee wishes to emphasize that laws against defamation, sedition or subversion, when defined in wide or general terms, may lead to the imposition of penalties involving compulsory labour as a means of political coercion or as a punishment for the expression of political or ideological views (2012 General Survey on the fundamental Conventions, paragraph 304). The Committee therefore requests the Government to ensure that no penalties involving compulsory labour, including compulsory prison labour, may be imposed for the peaceful expression of political views or views opposed to the established political, social or economic system, both in law and in practice. In this regard, the Committee requests the Government to provide information on the application in practice of sections 5 and 6, read together with section 12, of the Seditious and Undesirable Publications Act; as well as of section 5 of the Libel and Slander Act, including court decisions. The Committee also requests the Government to include information on the number of prosecutions made under each provision, the grounds for prosecution, as well as on the number of convictions and the nature of the penalties imposed.

Article 1(c). Sanctions involving compulsory labour for breaches of labour discipline. Seafarers. The Committee notes that according to section 194(c) of the International Maritime Act, (Act No. 9) of 2000, a crew member of a vessel who solicits or incites any other member of the crew to disobey or resist the lawful orders of the Master or other officers of such vessel is liable to imprisonment for up to ten years. The Committee recalls that Article 1(c) of the Convention prohibits the use of compulsory labour as a means of labour discipline. The Committee stresses in this regard that provisions establishing prison sanctions, involving compulsory labour, for breaches of labour discipline that do not tend to endanger the ship or the life or health of persons, are not in conformity with the Convention (2012 General Survey on the fundamental Conventions, paragraph 312). The Committee therefore requests the Government to provide information on the application in practice of section 194(c) of the International Maritime Act, including on relevant court decisions, indicating the nature of the sanctions imposed and the facts giving rise to the conviction, in order to enable the Committee to assess whether this provision is applied in a manner compatible with the Convention.

Article 1(d). Penalties involving compulsory labour as a punishment for having participated in strikes. The Committee notes that section 67 of the Industrial Relations Act, Chapter 89:01 of 1986 provides for financial sanctions for employees who participate in strikes that are contrary to this Act and that failure to pay the imposed sanctions is punishable by imprisonment for six months. The Committee observes that section 61(1) of the Act establishes that no trade union shall declare a strike unless the Minister responsible for industrial relations has not referred the trade dispute to an arbitration tribunal within fourteen days after the dispute is reported to the Minister. In this regard, the Committee also refers to its comments under the Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87). The Committee recalls that according to Article 1(d) of the Convention, no sanctions involving compulsory labour, including compulsory prison labour, may be imposed on workers for the mere fact of peacefully participating in a strike. The Committee requests the Government to ensure that, in both law and practice, persons who participate peacefully in a strike cannot be liable to sanctions of imprisonment, which involve compulsory labour. The Committee also requests the Government to provide information on the application in practice of section 67 of the Industrial Relations Act, indicating in particular whether, prison sentences have been imposed on persons who failed to pay the financial penalties imposed as a consequence of their participation in strikes.

The Committee reminds the Government that it can avail itself of the technical assistance of the Office in relation to the issues raised above.

The Committee notes with deep concern that the Government’s report, due since 2012, has not been received. In light of its urgent appeal launched to the Government in 2019, the Committee proceeds with the examination of the application of the Convention on the basis of the information at its disposal.

Article 1(1)(a) of the Convention. Grounds of discrimination. Legislation. In its previous comments, the Committee requested information on the progress made with regard to the adoption of legislation in conformity with the CARICOM model law, including with respect to sexual harassment. The Committee notes that no legislative amendments have been adopted since. It notes that section 13 of the Constitution contains a general prohibition of discrimination on the grounds of “sex, race, place of origin, political opinions, colour or creed” and that section 10 of the Protection of Employment Act Chap 89:02 prohibits employment termination based on all grounds provided for in Article 1(1)(a) of the Convention, as well as marital status. The Committee observes that: (1) section 13(2) of the Constitution does not cover the ground of discrimination of “social origin”, and that it mentions discrimination based on the “place of origin” but not on “national extraction”; and (2) legislation does not contain a specific reference to sexual harassment. The Committee would like to bring to the attention of the Government that the concept of national extraction covers distinctions made on the basis of a person’s place of birth, ancestry or foreign origin (see 2012 General Survey on the fundamental Conventions, paragraph 764). The Committee also notes that a number of legislative provisions, including in the Protection of Employment Act and the Labour Standards Act, refer to employees in masculine by using terms such as “his employment” or “he is entitled”. The Committee wishes to draw the Government’s attention to the importance of using gender-neutral terminology to avoid perpetuating stereotypes. While acknowledging the difficult situation prevailing in the country following the passage of Hurricane Maria, the Committee asks the government to provide information on the measures taken to amend its legislation, including in the process of CARICOM, to implement the principle of the Convention, in particular by covering all grounds of discrimination provided for in Article 1(1)(a) of the Convention, including with respect to sexual harassment. The Committee also asks the Government to provide information on the application, in practice, of the principle of non-discrimination, including on: (i) whether it covers all the aspects of employment and occupation, that is access to vocational training, access to employment and to particular occupations, and terms and conditions of employment; and (ii) whether discrimination based on the “place of origin” includes a person’s place of birth, ancestry or foreign origin. The Committee also asks information on measures taken to ensure that legislation uses gender-neutral language.

Article 2. Gender Equality. In its previous comments, the Committee requested information on the steps taken to follow-up on the 2006 National Policy and Action Plan for Gender Equity and Equality, to improve women’s access to decision-making positions and to collect sex-disaggregated data on participation in employment and training. The Committee notes that, in its report to the United Nations Universal Periodic Review (UPR) in 2019, the Government indicated that gender equality policies needed to be updated in light of the consequences of tropical storm Erika in 2015 and hurricane Maria in 2017, and that a draft National Gender Policy 2018-2028 is being prepared and seeks to promote political and social participation, women’s representation in cabinet, parliament and local government (A/HRC/WB.6/33/DMA/1, 18 February 2019, paragraphs 7 and 11). The Committee asks the Government to provide information on the adoption and implementation of the National Gender Policy 2018-2028, including in relation to the promotion of women’s participation in employment and training and the corresponding collection of sex-disaggregated data.

Ethnic minorities. In its previous comments, the Committee requested information on the implementation of the Integrated Development Plan for Caribs (currently referred to as “Kalinago”) and on the collection of statistical information on their participation in employment and training. The Committee notes that, in its report to the UPR, the Government highlights the creation of a Ministry of Kalinago Affairs in 2005, which in 2019 was transferred to the Ministry of Environment, Rural Modernisation and Kalinago Upliftment, under the Office of the Prime Minister. The Government also refers to the adoption of measures to improve the livelihood of Kalinago people, particularly after the passage of Hurricane Maria, including by providing support to the crafts industry and small businesses (A/HRC/WB.6/33/DMA/1, paragraphs 18–23). The Committee also notes that the 2030 National Resilience Development Strategy includes specific strategies to support the successful implementation of a Kalinago Development Plan and improve data collection. The Committee further refers to its comments regarding the Indigenous and Tribal Peoples Convention, 1989 (No. 169). The Committee asks the Government to provide information on the impact of the implementation of the Kalinago Development plan, the 2030 National Resilience Development Strategy, and other measures as regards the promotion of equality and non-discrimination of ethnic minorities in employment and occupation, including their participation in employment and training.

General observation of 2018. The Committee would like to draw the Government’s attention to its general observation on discrimination based on race, colour and national extraction which was adopted in 2018. In the general observation, the Committee notes with concern that discriminatory attitudes and stereotypes based on the race, colour or national extraction of men and women workers continue to hinder their participation in education, vocational training programmes and access to a wider range of employment opportunities, resulting in persisting occupational segregation and lower remuneration received for work of equal value. Furthermore, the Committee considers that it is necessary to adopt a comprehensive and coordinated approach to tackling the obstacles and barriers faced by persons in employment and occupation because of their race, colour or national extraction, and to promote equality of opportunity and treatment for all. Such an approach should include the adoption of interlocking measures aimed at addressing gaps in education, training and skills, providing unbiased vocational guidance, recognizing and validating the qualifications obtained abroad, and valuing and recognizing traditional knowledge and skills that may be relevant both to accessing and advancing in employment and to engaging in an occupation. The Committee also recalls that, in order to be effective, these measures must include concrete steps, such as laws, policies, programmes, mechanisms and participatory processes, remedies designed to address prejudices and stereotypes and to promote mutual understanding and tolerance among all sections of the population.

The Committee draws the Government’s attention to its general observation of 2018 and requests the Government to provide information in response to the questions raised in that observation.

Article 3. Cooperation with employers’ and workers’ organizations. The Committee asks the Government to indicate the role of workers’ and employers’ organizations in the development and implementation of the National Gender Policy 2018–2028, the Kalinago Development Plan and other policies relevant to promote equality and non-discrimination in employment and occupation. The Committee asks the Government to provide information regarding awareness-raising activities on the principles of the Convention undertaken in cooperation between the Government and employers’ and workers’ organizations.

The Committee notes with deep concern that the Government’s report, due since 2014, has not been received. In light of its urgent appeal launched to the Government in 2020, the Committee proceeds with the examination of the application of the Convention on the basis of the information at its disposal. The Committee recalls that since ratifying the Convention in 2004, the Government has not provided information concerning the practical application of the Convention. In 2009, the Committee took note of the Government’s first report and requested the Government to supply examples of facilities provided for in existing collective agreements. The Committee emphasizes the importance of receiving this type of information in order to be able to assess the effective application of the Convention in the country. Not having received any observations from the social partners, nor having at its disposal any information on the practical application of the Convention, the Committee refers to its previous direct request adopted in 2009 and urges the Government to provide a full reply in this respect. To this end, the Committee recalls that the Government may avail itself of the ILO’s technical assistance.

The Committee notes with deep concern that the Government’s report, due since 2014, has not been received. In light of its urgent appeal launched to the Government in 2019, the Committee proceeds with the examination of the application of the Convention on the basis of the information at its disposal.

Article 2(2) and (3) of the Convention. Minimum age for admission to employment and age of completion of compulsory schooling. In its previous comments, the Committee noted that the Government had specified a minimum age of 15 years upon ratification of the Convention. The Committee also noted that, according to section 2 of the Education Act (No. 11 of 1997), school is compulsory for all children from the age of 5 to 16 years, and that section 46(1) of the Act prohibits employing a child of school age during the school year. However, the Committee notes that pursuant to the Employment of Women, Young Persons and Children Act, Chapter 90:06, no children under the age of 14 years can be employed in industrial undertakings, other than family undertakings (section 4); or on ships, other than those in which only members of the same family are employed (section 5). In this regard, the Committee requests the Government to clarify the relationship between sections 4 and 5 of the Employment of Women, Young Persons and Children Act and sections 2 and 46(1) of the Education Act. The Committee also wishes to recall that Article 2(2) of the Convention provides that a ratifying country may subsequently notify the Director General of the International Labour Office, by further declarations, that it specifies a minimum age higher than that previously specified. Thus, the Committee would be grateful if the Government would consider sending a declaration of this nature to the Office, taking into consideration sections 2 and 46(1) of the Education Act, so that the minimum age for admission to employment fixed by the national legislation is harmonized with that provided for at the international level.

Article 3(1) and (2). Minimum age for admission to and determination of hazardous work. In its previous comments, the Committee noted the absence of a legislative provision setting a minimum age for admission to hazardous work. The Committee also noted the Government’s indication that consultations were envisaged with the social partners with a view to determining a list of types of hazardous work prohibited for children under the age of 18 years. Noting the absence of information on progress made in this respect, the Committee once again requests the Government to take the necessary measures to ensure that children can only undertake hazardous work from the age of 18 years, as required by Article 3(1) of the Convention. The Committee also requests the Government to take measures to ensure that a list of hazardous types of work prohibited for children under 18 years of age, as required by Article 3(2) of the Convention, is adopted after consultation with the organizations of employers and workers concerned.

Article 7(1). Minimum age for admission to light work. In its previous comments, the Committee noted that, according to section 3 of the Employment of Children (Prohibition) Act, Chapter 90:05, children above 12 years of age may be employed in domestic work or agricultural work of a light nature at home by the parents or guardian of the child. In this regard, the Committee recalls that Article 7(1) of the Convention only permits the employment or work of children, who have reached the age of 13 and under the condition that such work is not likely to be harmful to their health or development; and not such as to prejudice their attendance at school, their participation in vocational orientation or training programmes or their capacity to benefit from the instruction received. The Committee therefore requests the Government to take the necessary measures to bring section 3 of the Employment of Children (Prohibition) Act in line with the Convention by permitting employment in light work only by children who have reached the age of 13 years.

Article 7(3). Determination of types of light work activities. Light work during school vacations. The Committee previously noted that section 46(3) of the Education Act permits the employment of children above 14 years of age during school vacations but observed that the Act does not indicate the types of light work permitted for these children. The Committee recalls that pursuant to Article 7(3) of the Convention, the competent authority shall determine the types of light work permitted to children and shall prescribe the number of hours during which and the conditions in which, such employment or work may be undertaken. The Committee, therefore, once again requests the Government to provide information on any measures taken or envisaged to determine the types of light work that children above the age of 14 years can undertake during school vacations, as well as the hours during which and the conditions in which such work can be performed.

Article 9(3). Keeping of registers by employers. The Committee previously noted that section 8(1) of the Employment of Women, Young Persons and Children Act requires every employer in an industrial undertaking and every shipmaster to keep a register of all persons employed under the age of 16 years. In this regard, the Committee had recalled that Article 9(3) of the Convention requires the keeping of such registers for all persons employed who are less than 18 years of age. In this respect, the Committee requests the Government to take the necessary measures to review section 8(1) of the Employment of Women, Young Persons and Children Act, so as to bring its legislation into conformity with Article 9(3) of the Convention with a view to ensuring that registers be kept and made available by the employer in respect of all working children under 18 years of age. The Committee requests the Government to provide information on any progress made in this regard.

Labour inspection and application of the Convention in practice. In its previous comments, the Committee noted the Government’s indication that measures would be taken to broaden the mandate of the national inspectorate to cover child labour issues, in consultation with the social partners. In this regard, the Committee requests the Government to indicate whether the mandate of the national inspectorate has been expanded to cover child labour issues and, if so, to provide information on the activities undertaken by the national inspectorate in the area of child labour, including the number of labour inspections conducted and the number and nature of violations detected. The Committee also requests the Government to provide updated statistical data on the employment of children and young persons.

The Committee encourages the Government to take into consideration the Committee’s comments on discrepancies between national legislation and the Convention. The Committee invites the Government to consider technical assistance from the ILO to bring its legislation into conformity with the Convention.

The Committee notes with deep concern that the Government’s report has not been received. It expects that the next report will contain full information on the matters raised in its previous comments. The Committee informs the Government that, if it has not supplied replies to the points raised by 1 September 2022, then it may proceed with the examination of the application of the Convention on the basis of the information at its disposal at its next session.

Repetition

Consultation procedures. The Government indicates that matters related to consultation procedures under the Convention have been included within the scope of the Decent Work Country Programme. The Government further asserts that it has been understood through the Industrial Relations Advisory Committee (IRAC) that employers and workers must be represented on equal footing during consultations. The Committee refers to Article 2 of the Convention and reiterates its previous request inviting the Government to provide detailed information in its report on the measures taken to ensure the conduct of effective consultations on matters relating to international labour standards. The Committee also invites the Government to provide detailed information in its report on the content and outcome of the tripartite consultations held on each of the other matters relating to international labour standards covered by Article 5(1).

Consultations required by the Convention. The Government reports that every effort is being made to forward the instruments adopted by the Conference to the House of Assembly. The Committee reiterates its previous request and asks the Government to submit the instruments adopted by the Conference to the House of Assembly. The Committee hopes that the Government’s next report will contain relevant information on the prior tripartite consultations held on this subject (Article 5(1)(b)).

Administrative support. Financing of training. The Government reports that the consultative procedures will be funded primarily by the Government with the assistance from the private sector, NGOs and international organizations. The Committee invites the Government to provide in its next report detailed information on the manner in which it intends to assume responsibility for the administrative support of the consultation procedures covered by the Convention (Article 4(1)), as well as detailed information on the arrangements made for the financing of any necessary training of participants in consultation procedures (Article 4(2)).

The Committee notes with deep concern that the Government’s report has not been received. It is therefore bound to repeat its previous comments. The Committee informs the Government that, if it has not supplied replies to the points raised by 1 September 2022, then it may proceed with the examination of the application of the Convention on the basis of the information at its disposal at its next session.

Repetition
Article 2 of the Convention. Implementing legislation. The Committee notes the Government’s indication that a special Tripartite Committee has been appointed to advise the Government on all matters relating to legislation and institutional changes necessary for the ratification of the Maritime Labour Convention, 2006 (MLC, 2006). It also notes that a National Action Plan has been prepared in order to formulate recommendations to the Government on matters of maritime laws and administration. While welcoming the Government’s active steps towards the ratification of the MLC, 2006, the Committee is bound to observe that the Government’s first report on the application of Convention No. 147 does not contain any information on the laws or regulations and other measures giving effect to the specific requirements of the latter Convention. The Committee therefore requests the Government to indicate in detail how each of the Articles of the Convention is applied in national law and practice, and explain in particular in what manner the provisions of the International Maritime Act, 2002, and of the Dominica Maritime Regulations, 2002, are substantially equivalent to the Conventions mentioned in the Appendix of the Convention relating to safety standards, social security measures and shipboard conditions of employment and shipboard living arrangements, as required under Article 2 of the Convention.

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

The Committee notes with deep concern that the Government’s report has not been received. In light of its urgent appeal launched to the Government in 2019, the Committee proceeds with the examination of the application of the Convention on the basis of the information at its disposal.

Article 1 of the Convention. Scope of application. The Committee previously noted that the Convention applies to the Kalinago (Carib) people living in the Carib Reserve on the north-eastern coast of Dominica, and requested the Government to provide information on their socio-economic situation. The Committee notes the adoption of the Carib Reserve Act (Amendment) (Act No. 2 of 2015), which changes the term “Carib” for “Kalinago” to refer to the indigenous peoples of the country, and renames the Carib Reserve Act as Kalinago Territory Act. The Committee also notes that the 2011 National Population and Housing Census shows that the Kalinago people accounts for 3.7 per cent of the population (2,576 people). According to information of the Central Statistics Office, a national census is planned for 2021, covering areas such as employment, education, health and income distribution. The Committee further notes that one of the specific strategies contained in the National Resilience Development Strategy 2030 is to encourage improved data collection, disaggregation, and analysis to ensure the availability of adequate and useful data to address the issues confronting the Kalinago people. The Committee requests the Government to provide information on the results of the latest National Population and Housing Census (indicating whether the criterion of self-identification has been applied in the identification of indigenous peoples). Recalling the importance of having reliable statistical data on the socio-economic conditions of indigenous peoples as an essential tool for effectively guiding and defining policies relating to indigenous peoples, the Committee hopes that the Government will be able to provide information in this respect.

Articles 2 and 33. Coordinated and systematic action. Elimination of socio-economic gaps. In its previous comments, the Committee noted that the Ministry of Carib Affairs was the main Government institution in charge of issues concerning the peoples covered by the Convention. The Committee notes that this competence was transferred to the Ministry of Environment, Rural Modernisation and Kalinago Upliftment. The mission of the Ministry is, according to information available on its website, to improve the quality of life and opportunities for the Kalinago people by contributing to a relationship of mutual understanding, trust and respect between this people and the Government. In this regard, the Ministry aims at promoting collaboration and coordination across ministries on indigenous policies and programmes, and enhancing awareness of the Kalinago people’s issues and best practices for consulting and engaging with them. The Committee further notes that, according to the National Resilience Development Strategy 2030, approximately 50 per cent of the Kalinago population was considered poor after a poverty assessment conducted in 2009. The Committee requests the Government to indicate the measures taken by the Ministry of Environment, Rural Modernisation and Kalinago Upliftment to ensure coordinated and systematic action to protect the rights of the Kalinago people. Please, provide examples of coordination and collaboration between the Ministry and other government agencies dealing with issues concerning the Kalinago people. In this regard, the Committee requests the Government to indicate how the participation of the Kalinago people is ensured in the design and implementation of measures for the protection of their rights, including in programmes aimed at eliminating the socio-economic gaps that exist between indigenous peoples and other members of the national community.

Articles 4 and 7.1. Special measures. Development. The Committee previously noted that, pursuant to section 48 of the Kalinago Territory Act (previously Carib Reserve Act), the Government retains responsibility for the overall development and planning in the Reserve and that each hamlet in the Kalinago territory has a development committee. The Committee notes that, with the financial support of the World Bank, the Government has implemented the Indigenous Peoples Plan Housing Recovery Project to rehabilitate homes in the Kalinago Territory that were affected by the Hurricane Maria in 2017. The Committee also notes that the National Resilience Development Strategy 2030 provides for specific recovery strategies concerning the Kalinago people, including the implementation of a Kalinago Development Plan and the promotion of the participation of persons who identify themselves as Kalinago in development planning bodies as means of building their capacity to represent their interests. The Committee requests the Government to provide information on the results of the measures taken or envisaged to safeguard the persons, properties and environment of the peoples covered by the Convention, indicating the manner in which they participate in the formulation, evaluation and implementation of such measures, including through the development committees in the different hamlets. The Committee also requests the Government to indicate if the Kalinago Development Plan has been adopted as envisaged in the National Resilience Development Strategy 2030.

Articles 6 and 7.3. Consultation and participation. The Committee previously noted that the Kalinago people are consulted through community organizations and the Carib (Kalinago) Reserve Council. The Committee notes that the 2018 Climate Resilience Act (No. 16), under section 9, establishes a Climate Resilience Execution Agency for Dominica (CREAD) tasked with coordinating recovery action following climate related disaster, including the construction, reconstruction or restoration of physical or other infrastructure. The Committee takes due note that according to section 11 (3) of the Act, the CREAD shall ensure community engagement, including of representatives of indigenous peoples, in the design, implementation and evaluation of all projects managed by the agency; and that public consultations are held for communities affected by large scale infrastructure projects. The Committee further notes that in its 2020 reply to issues raised by the United Nations Human Rights Committee, the Government indicated that it consulted the Kalinago Council prior to carrying out any infrastructure project in the Kalinago territory (CCPR/C/DMA/RQAR/1 paragraph 126). The Committee takes due note of the above-mentioned legislative measures and requests the Government to provide information explaining the manner in which the Kalinago Reserve Council is consulted prior to the adoption of legislative and administrative measures affecting the Kalinago people directly, including examples of measures that have been consulted. The Committee also requests the Government to indicate how the Kalinago people cooperate with the Climate Resilience Execution Agency for Dominica (CREAD) in the designing and implementation of recovery actions in the Kalinago territory, including in relation to the assessment of the social, spiritual, cultural and environmental impact of such measures.

Articles 14, 17 and 19. Land. The Committee previously noted that according to section 47 of the Kalinago Territory Act, the Kalinago Reserve Council has the custody and control over the lands in the Kalinago Reserve. Furthermore, pursuant to section 45 of the Act, no lands in the Reserve could be sold, exchanged, mortgaged, encumbered or disposed of without the written permission of the Prime Minister. The Committee also notes that according to the Dominica National Land Use Policy issued in 2014, the Kalinago territory shall be treated as a special policy area and be planned to support the culture and lifestyle of the Kalinago people. The Committee requests the Government to provide information on the application in practice of the Kalinago Territory Act, including information on procedures established for the transmission of land rights to persons within and outside the Kalinago Reserve. The Committee also requests the Government to provide information on measures taken under the 2014 Dominica National Land Use Policy, to facilitate indigenous peoples’ access to the means required to promote the development of their lands.

Article 15. Natural resources. Consultation. The Committee notes that according to section 2 of the Mines and Minerals Act (Act No. 5 of 1996), the State has the entire property and control over all minerals in any land in the State and under the territorial sea. Pursuant to section 101 of the Act, the holder of a mining licence shall not exercise any activity authorized by the licence in respect of land comprising a reserve, except with the consent of the Minister responsible for Mining and Natural Resources or other authority having control thereof. The Committee requests the Government to indicate if any activity relating to the use of natural resources in the Kalinago territory, including any program for the exploration and exploitation of mineral resources, has been authorized and, if so, to indicate how the indigenous peoples concerned have been consulted before undertaking or permitting any such programmes.

Articles 20 and 22. Employment and vocational training. The Committee notes that in its 2020 reply to issues raised by the Human Rights Committee, the Government indicated that it had established a Small Business Fund to facilitate access to funding for business to the Kalinago people, which is not otherwise available through financial institutions (CCPR/C/DMA/RQAR/1 paragraph 125). The Committee notes that the UN sub-regional team for Barbados and the Organisation of Eastern Caribbean States, in their 2019 joint submission for the examination of Dominica under the UN Universal Periodic Review, underlined that unemployment among the Kalinago people was a chronic issue, especially as a result of a significant drop in banana exportation. The Committee requests the Government to indicate the measures taken to facilitate access to training and employment opportunities to indigenous peoples, including skilled employment. The Committee also requests the Government to provide information on the number of persons pertaining to the Kalinago people who have benefited from the Small Business Fund to develop their own business initiatives.

Article 24. Social security. The Committee requests the Government to provide information on the percentage of employed Kalinago people covered by social security schemes or other social protection measures targeting the Kalinago people.

Article 25. Health. The Committee once again requests the Government to provide information on the measures taken in relation to the provision of health services in the Kalinago territory, in cooperation with the Kalinago people.

The Committee notes with deep concern that the Government’s report, due since 2014, has not been received. In light of its urgent appeal launched to the Government in 2019, the Committee proceeds with the examination of the application of the Convention on the basis of the information at its disposal.

Article 3 of the Convention. Worst forms of child labour. Clause (a). All forms of slavery or practices similar to slavery. Sale and trafficking of children In its previous comments, the Committee noted that section 51 of the Offence against the Person Act, Chapter 10:31 criminalizes the abduction of girls under the age of 18 years for sexual purposes. The Committee, however, noted the absence of legislative provisions specifically prohibiting the trafficking of children (boys and girls) for sexual and labour exploitation and urged the Government to take the necessary measures in this respect.

While reiterating its concern at the absence of a Government report, the Committee takes due note of the adoption of the Transnational Organized Crime (Prevention and Control) Act (Act No. 13 of 2013), which under section 8 introduces the offence of trafficking in persons for sexual and labour exploitation and under section 13 provides for a penalty of life imprisonment for the commission of trafficking in persons when the victim is a child. Section 2 of the Act defines “child” as a person under 18 years of age. The Committee requests the Government to provide information on the number of investigations, prosecutions, convictions and penalties imposed on perpetrators of trafficking of children under sections 8 and 13 of the Transnational Organized Crime (Prevention and Control) Act.

Clause (b). Use, procuring or offering of a child for prostitution, for the production of pornography or pornographic performances. In its previous comments, the Committee noted that under section 18 (a) of the Sexual Offences Act (Act No. 1 of 1998), a person who procures or induces a minor to have sexual intercourse with any person is liable to imprisonment for twenty five years. The Committee also noted that no legislative provision existed prohibiting child pornography. The Committee requests the Government to take the necessary measures to ensure that the use, procuring or offering of a child under 18 years for the production of pornography or for pornographic performances is prohibited and subject to dissuasive sanctions. The Committee also requests the Government to provide information on the application in practice of section 18 (a) of the Sexual Offences Act, including information on the number of investigations, prosecutions, convictions and penalties imposed on persons for procuring children under 18 years of age for prostitution.

Clause (c). Use, procuring or offering of a child for illicit activities, in particular for the production and trafficking of drugs. The Committee previously noted that the Children and Young Persons Act, Chapter 37:50 prohibits the use of persons under 18 years of age for begging, however it also noted the absence of information on legislation prohibiting the use of children in other illicit activities. The Committee once again requests the Government to take measures to ensure that the use, offering or procuring of children under 18 years of age for illicit activities, including the production and trafficking of drugs is prohibited and punishable by dissuasive sanctions. The Committee requests the Government to provide information on any developments made in this respect.

Clause (d) and Article 4(1). Hazardous work. With regard to the prohibition and determination of hazardous types of work for children under the age of 18 years, the Committee refers to its comments under the Minimum Age Convention, 1973 (No. 138).

Article 6. Programmes of action to eliminate the worst forms of child labour. The Committee previously noted the Government’s intention to devise a national campaign for the elimination of the worst forms of child labour, in consultation with social partners. The Committee once again requests the Government to provide information on the progress made towards the development and adoption of national programmes of action for the elimination of the worst forms of child labour, in consultation with the social partners.

Article 7(2). Effective and time-bound measures. Clause (a). Preventing the engagement of children in the worst forms of child labour. Access to free basic education. In previous comments, the Committee noted that the Education Act (No. 11 of 1997) guarantees free and compulsory education of all children aged 6 to 16 years (section 16 read together with section 27 of the Act). The Committee notes that, according to UNESCO statistics, the net enrolment rate in primary education (children aged 6 to 11 years) slightly dropped from 95.6 per cent in 2011 to 92.4 in 2019; whereas the net enrolment rate in secondary education (children aged 12 to 16 years) increased from 72.7 per cent in 2011 to 87 per cent in 2019. The Committee notes that, according to the 2017 UNICEF Situation analysis of children in the Commonwealth of Dominica, pregnant teenagers face stigma and often choose to discontinue school, and that young mothers who wish to continue their education through alternative course work are discouraged due to fees, childcare requirements and lack of support (page 51). Recalling that education is key in preventing the engagement of children in the worst forms of child labour, the Committee encourages the Government to continue promoting access to free basic education for all children, including pregnant teenagers and teenage mothers. In this regard, the Committee requests the Government to provide information on effective and time-bound measures taken or envisaged to that effect.

Clause (d). Children at special risk. Kalinago (Carib) children. In its previous comments, the Committee noted that the indigenous Kalinago children (previously referred to as Carib children) faced limitations in the enjoyment of their rights and requested the Government to provide information on measures taken to promote their access to education. The Committee notes that according to the National Resilience Development Strategy 2030 adopted by the Government in 2018, members of the Kalinago people suffer from low educational attainment, unemployment and poverty (page 128). Moreover, the 2017 UNICEF Situation analysis of children in the Commonwealth of Dominica indicates that a large proportion of the Kalinago population are children and youth, and 49.9 per cent of such population lives in poverty compared to a national average of 28.8 per cent (page 26). In this regard, the Committee requests the Government to provide information on effective and time-bound measures taken or envisaged to improve the educational attainment of Kalinago children, so as to prevent their engagement in the worst forms of child labour, and the results achieved.

Application of the Convention in practice. The Committee requests the Government to intensify its efforts to provide updated statistical information on the nature, extent and trends of the worst forms of child labour in the country, as well as on the number of children covered by the measures taken to give effect to the Convention.

The Committee notes with deep concern that the Government’s report has not been received. It expects that the next report will contain full information on the matters raised in its previous comments. The Committee informs the Government that, if it has not supplied replies to the points raised by 1 September 2021, then it may proceed with the examination of the application of the Convention on the basis of the information at its disposal at its next session.

Repetition

In reply to the Committee’s previous direct request, the Government indicated in its report received in November 2012 that there have been no organized labour inspection services carried out in the agricultural industry as agriculture in Dominica is carried out by private individuals on small-scale farms. For the same reason, statistical information on the number of occupational accidents and claims to compensation is difficult to obtain. The Committee notes, however, that the Government undertook to collaborate with the social security institutions to collect the information available on claims made by individuals for injuries sustained in agricultural work. The Committee would welcome such information with the Government’s next detailed report. Please indicate also the total number of workers employed in agriculture in the country.

The Committee notes with deep concern that the Government’s report has not been received. It expects that the next report will contain full information on the matters raised in its previous comments. The Committee informs the Government that, if it has not supplied replies to the points raised by 1 September 2021, then it may proceed with the examination of the application of the Convention on the basis of the information at its disposal at its next session.

Repetition

Articles 2, 4, 8, 10 and 12 of the Convention. Scope of application, partial payment of wages in kind, wage deductions, attachment and assignment of wages, and payment of wages at regular intervals. The Committee has been drawing the Government’s attention for a number of years to certain inconsistencies of the Protection of Wages Act (Chapter 89:07) and has been suggesting that appropriate steps be taken to give full effect to the requirements of Articles 2, 4, 8, 10 and 12 of the Convention. In a previous report, the Government states that regrettably there has been no change to national legislation but adds that the amendment of the labour legislation has been included in its Decent Work Agenda with a view to bringing national law in full compliance with the provisions of the Convention. The Committee once again requests the Government to take the necessary measures in the very near future in order to give full effect to the above-referenced provisions of the Convention.

The Committee notes with deep concern that the Government’s report has not been received. It expects that the next report will contain full information on the matters raised in its previous comments. The Committee informs the Government that, if it has not supplied replies to the points raised by 1 September 2021, then it may proceed with the examination of the application of the Convention on the basis of the information at its disposal at its next session.

Repetition

The Committee notes the observations of the Waterfront and Allied Workers Union (WAWU), received on 8 February 2010, concerning the functioning of the Industrial Relations Advisory Committee. The Committee requests the Government to provide its comments in this respect.

Articles 1, 4 and 6 of the Convention. Technical assistance for a better operation of labour administration. The Committee takes note of the general information in the organizational chart regarding the bodies that make up the labour administration system and the summary information sent by the Government about the functions of the Industrial Relations Advisory Committee (IRAC), and the functions of the Industrial Relations Board. The Committee would be grateful if the Government would describe more precisely the functions of each of the bodies making up the labour administration system and to provide copies of the texts that provide the basis in law for their operation.

The Committee would be grateful if the Government would explain how effect is given in law and in practice to the national labour policy, and would provide information on the measures taken or envisaged following the recommendations made by the ILO Subregional Office for the Caribbean in the context of technical assistance, to ensure that the labour administration system operates efficiently.

Articles 5 and 8. Consultations within the system of labour administration and participation in the preparation of a national policy concerning international labour affairs. According to the Government, the IRAC, which is tripartite, is involved in the formulation of the national policy and the preparation of policy concerning international labour affairs through the submission of draft legislation to Parliament. The Government is asked to provide details of the practical scope of the IRAC’s proposals together with copies of extracts from reports of its proceedings, and any other relevant documents.

Article 7. Extension of the functions of the system of labour administration. The Committee asks the Government to indicate whether national conditions require the gradual extension of certain functions of the labour administration system to persons who are not, in law, employed persons and belong to the categories set forth in indents (a)–(d) of this provision of the Convention.

Article 10. Human resources and material means for the labour administration system. The Committee requests the Government to describe the composition, status and conditions of service of the staff of the labour administration system, giving particulars of their recruitment, the content of initial and in-service training, and the pay structure, providing details of the material and financial resources made available for the labour administration to carry out its functions. It would be grateful if the Government would also indicate, as far as possible, the elements taken as a basis to determine the annual budgetary allocation for these resources and to provide a copy of the Public Service Commission Act, Chapter 1:01.

Application in practice. According to the Government, the request for information and documents in this part of the report form does not apply to Dominica. The Committee would nonetheless point out to the Government that reports or extracts of reports of the labour administration services, and the information submitted to the Ministry by the bodies engaged in labour administration activities, including those referred to in the report and the organizational chart (Industrial Relations Advisory Committee, Consultative Advisory Committee, Industrial Relations Board, Industrial Relations Tribunal and the Labour Commissioner) are useful and indeed essential to an assessment of the extent to which the Convention is applied in practice. The Committee would be grateful if the Government would send such documents and information on a regular basis and to report on any action taken on the opinions, recommendations, proposals or decisions of the main labour administration services such as those referred to in Paragraph 20 of the Labour Administration Recommendation, 1978 (No. 158).

Comments adopted by the CEACR: Dominica

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Labour Inspection Convention, 1947 (No. 81)

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Comments adopted by the CEACR: Dominica

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ADOPTED_BY_THE_CEACR_IN 2021

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Labour Inspection Convention, 1947 (No. 81)

B. Labour administration

Labour Administration Convention, 1978 (No. 150)

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