CMNT_TITLE

Maritime Labour Convention, 2006 (MLC, 2006) - Togo (RATIFICATION: 2012)

Other comments on C186

Direct Request

2021
2018
2014

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The Committee notes the Government’s third report on the application of the Maritime Labour Convention, 2006, as amended (MLC, 2006). The Committee notes that the amendments to the Code of the MLC, 2006, approved by the International Labour Conference in 2016 and 2018 entered into force for Togo on 8 January 2019 and 26 December 2020, respectively. The Committee draws the Government’s attention to the following issues.

Impact of the COVID-19 pandemic. The Committee takes note of the observations of the International Transport Workers’ Federation (ITF) and the International Chamber of Shipping (ICS), received by the Office on 1 and 26 October 2020 and 4 October 2021, alleging that ratifying States have failed to comply with certain provisions of the Convention during the COVID-19 pandemic. Noting with deep concern the impact of the COVID-19 pandemic on the protection of seafarers’ rights as laid out in the Convention, the Committee refers to its general observation of 2020 and its comments in the general report of 2021 on this issue, and requests the Government to provide information in its next report on any temporary measures adopted in this regard, their duration and their impact on seafarers’ rights.

Article I of the Convention. General questions on application. Implementing measures. The Committee previously noted the adoption of Act No. 2016-028 of 11 October 2016 issuing the Merchant Shipping Code (hereinafter the MSC), Book IV of which takes into account the requirements of the MLC, 2006. Emphasizing that many provisions of the MSC envisage the adoption of supplementary implementing regulations, the Committee requested the Government to provide copies of all the laws, regulations and other measures which had been adopted or were being prepared to give effect to the MLC, 2006. Noting that the Government refers to article 140 of the Constitution of Togo of 1992, which provides that treaties and agreements regularly ratified or approved, following publication, have a higher rank than laws, the Committee recalls that the MLC, 2006, contains requirements for which Member States have to take the necessary measures to bring national law and practice into conformity. The Committee also notes that the Government refers to a collective agreement for seafarers, the draft text of which is still in the process of being approved, without however providing a copy. The Committee once again requests the Government to take the necessary measures to give effect to the requirements of the MLC, 2006, and to provide copies of any new laws and/or regulations when they are adopted and of the collective agreement for seafarers that is in the process of being approved. The Committee reminds the Government that it may avail itself the technical assistance of the Office. The Committee notes that the Government refers on several occasions to Act No. 2021-012 of 18 June 2021 issuing the Labour Code (for example in relation to night work and notice of termination). However, the Committee notes that section 3 of the new Labour Code provides that, in cases where they are governed by special provisions, employment relations are not subject to the provisions of the present Code. The Committee requests the Government to indicate whether or not the new Labour Code applies to “seafarers” who are employed or engaged or work in any capacity on board a ship to which the Convention applies. The Committee notes that the Government has provided an example of a maritime medical certificate and a copy of the declaration of maritime labour compliance (DMLC, Parts I and II), which have not been completed. The Committee requests the Government to provide a completed copy, as required by Standard A5.1.3, paragraph 12, of the maritime labour certificate and of the DMLC, Part I and an example or examples of the DMLC, Part II drawn up by a shipowner and endorsed by the competent authorities for the certification of one or more ships.

Article II. Definitions and scope of application. The Committee noted previously that Book IV of the MSC respecting seafarers does not cover all seafarers within the meaning of the MLC, 2006. Section 206 of the MSC provides that any waged employee engaged by a shipowner or having embarked on a commercial, service, or motorized fishing vessel on his or her own account to take up employment relating to the operation, conduct or exploitation of the ship shall be considered as exercising the profession of a seafarer. Section 294 excludes from the application of the provisions of the Title of the MSC respecting maritime labour, which covers matters such as working time and leave, the master, the doctor and nursing personnel engaged exclusively in nursing duties, persons who are not members of the crew and who are engaged, while the ship is in port or at sea, in repair work, cleaning, loading or unloading the ship or maintenance, monitoring or guard duties. The Committee notes that the Government recognizes that these provisions are in contradiction with section 3(1)(42) of the MSC, which provides that any person who is employed or engaged or works in any capacity on board a ship shall be considered a “seafarer”. Recalling that Article II, paragraphs 1(f) and 2, of the Convention provide that it applies, without any specification as to the duties discharged, to all seafarers, meaning any person who is employed or engaged or works in any capacity on board a ship to which this Convention applies, the Committee once again requests the Government to indicate the measures taken to ensure that all seafarers within the meaning of the Convention, including the master and persons not employed in any duties relating to the operation, conduct or exploitation of the ship, benefit from the protection afforded by the MLC, 2006.

The Committee notes the Government’s indication that no cases of doubt have arisen as to whether a vessel or a particular category of vessels are to be regarded as “ships”, within the meaning of Article II, paragraphs 4 and 5, of the MLC, 2006. The Committee notes that the annual statistics published by UNCTAD, as confirmed by the statistics provided by the Government, show that the merchant fleet registered under the Togolese flag has increased substantially in recent years. The Committee requests the Government to provide detailed information on the number, date of construction and type of ships flying the Togolese flag to which the MLC, 2006, applies and on any issues of application or any different determinations respecting application within the meaning of Article II, paragraph 6, and Article VI, paragraphs 3 and 4, of the Convention. The Committee requests the Government to indicate the number of seafarers working on ships flying the Togolese flag and to specify the number of seafarers who are nationals or residents or otherwise domiciled in the national territory.

Regulation 1.1 and Standard A1.1, paragraph 4. Minimum age. Hazardous work. The Committee previously noted that, while the MSC provides that a minor may only be employed on board ship in work and services which correspond to his or her physical capacities and to the performance of his or her duties (section 300), it does not prohibit types of work that are hazardous for young persons under 18 years of age or provide for the adoption of a list of prohibited types of work, as required by Standard A1.1, paragraph 4. The Committee notes that Order No. 1556/MFPTRAPS, of 22 May 2020, determines in sections 7 to 11 the types of hazardous work that are prohibited for children and contains a list of hazardous types of work, which refers to the prohibition of the employment of persons under 18 years of age as stokers on ships. The Committee observes that the work of stokers has disappeared from the maritime industry and recalls that Standard A1.1, paragraph 4, provides that the employment, engagement or work of seafarers under the age of 18 shall be prohibited where the work is likely to jeopardize their health or safety, and that the types of such work shall be determined by national laws or regulations or by the competent authority, after consultation with the shipowners’ and seafarers’ organizations concerned, in accordance with the relevant international standards. The Committee once again requests the Government to adopt effective measures without delay to prohibit any type of work that is likely to jeopardize the health or safety of seafarers under 18 years of age and to determine the various types of work that are prohibited (Standard A1.1, paragraph 4).

Regulation 1.4 and the Code. Recruitment and placement. In its previous comment, the Committee noted that the MSC, in sections 226 to 230, gives effect to certain of the requirements of Regulation 1.4 and Standard A1.4 of the Convention, but that these provisions are still very general and require more detailed implementing measures. The Committee notes that the supplementary regulations envisaged in sections 226 to 230 of the MSC have not been provided. The Committee requests the Government to adopt the necessary implementing regulations to give effect to Regulation 1.4 and Standard A1.4. It also requests the Government to provide detailed information on: (1) the conditions for the implementation in practice of the requirements of the Convention in relation to private seafarer recruitment and placement services operating in the territory of Togo (Standard A1.4, paragraphs 2, 5, 6 and 7); (2) the information provided to nationals of Togo on the possible problems of signing on a ship that flies the flag of a State which has not ratified the Convention (Standard A1.4, paragraph 8); and (3) the requirements to be met by shipowners of ships that fly the Togolese flag who use seafarer recruitment and placement services based in countries or territories in which the Convention does not apply (Standard A1.4, paragraph 9).

Regulation 2.1 and Standard A2.1, paragraph 1(b). Seafarers’ employment agreement. Examination and advice before signing. Noting that the MSC does not address this matter, the Committee previously requested the Government to indicate the manner in which it is ensured that seafarers signing a seafarers’ employment agreement are given an opportunity to examine and seek advice on the agreement before signing, as well as such other facilities as are necessary to ensure that they have freely entered into an agreement with sufficient understanding of their rights and responsibilities (Standard A2.1, paragraph 1(b)). The Committee notes the Government’s indication in this regard that the Department of Maritime Affairs has issued a document entitled “Statement of honour signed by seafarers”, which was not provided with the report. The Committee recalls that Standard A2.1, paragraph 1, requires legislation to be adopted on this point. The Committee once again requests the Government to adopt the necessary measures to give effect to Standard A2.1, paragraph 1(b), and to provide a copy of the document entitled “Statement of honour signed by seafarers”.

Regulation 2.1 and Standard A2.1, paragraphs 1(e) and 3. Seafarers’ employment agreement. Record of employment. With reference to the requirement for seafarers to be given a document containing a record of their employment on board the ship, in accordance with Standard A2.1, paragraphs 1(e) and 3, the Committee notes that the Government refers to the provisions of section 304 of the MSC, which however covers records of daily hours of work. The Committee requests the Government to adopt the necessary measures to give effect to Standard A2.1, paragraphs 1(e) and 3.

Regulations 2.1 and 2.2 and Standards A2.1, paragraph 7 and A2.2, paragraph 7. Seafarers’ employment agreements and wages. Captivity as a result of acts of piracy or armed robbery against ships. The Committee notes that the MSC does not establish the conditions under which the protection required by the Convention shall be afforded to seafarers held captive as a result of acts of piracy or armed robbery against ships. In relation to the 2018 amendments, the Committee draws the Government’s attention to the following questions included in the revised report form for the Convention: (a) do laws or regulations provide that a seafarer’s employment agreement shall continue to have effect while the seafarer is held captive on or off the ship as a result of acts of piracy or armed robbery against ships?; (b) how are the terms piracy and armed robbery against ships defined under the national legislation? (Standard A2.1, paragraph 7); and (c) do laws or regulations provide that wages and other entitlements under the seafarers’ employment agreement, relevant collective bargaining agreement or applicable national laws, including the remittance of any allotments, shall continue to be paid during the entire period of captivity and until the seafarer is released and duly repatriated or, where the seafarer dies while in captivity, until the date of death in accordance with national legislation? (Standard A2.2, paragraph 7). The Committee requests the Government to reply to the above questions, indicating in each case the applicable national provisions.

Regulation 2.3 and Standard A2.3, paragraphs 2, 5 and 6. Hours of work and rest. Limits. Division of hours of rest. The Committee previously noted that the MSC deals with normal hours of work, but does not address maximum hours of work or minimum hours of rest, as required by Standard A2.3, paragraphs 2 and 5. The Committee also noted that the new MSC does not provide that hours of rest shall be divided into no more than two periods, one of which shall be at least six hours in length, or that the interval between consecutive periods of rest shall not exceed 14 hours (Standard A2.3, paragraph 6). The Committee notes that the Government refers in its report to sections 300 and 301 of the MSC, which only relate to seafarers under 18 years of age. The Committee once again requests the Government to adopt without delay the necessary measures to ensure that either the maximum hours of work or the minimum hours of rest are determined in accordance with the requirements of the Convention. It requests the Government to indicate the measures that give full effect to Standard A2.3, paragraph 6.

Regulation 2.5, paragraph 2, and Standard A2.5.2. Repatriation. Financial security. Abandonment. The Committee previously noted that section 290 of the MSC provides that any owner of a ship flying the Togolese flag shall arrange financial security to ensure the due repatriation of seafarers. The Committee also noted that the conditions for the implementation of this financial security are not specified in the provisions of the MSC. The Committee notes the Government’s indication that the provision respecting financial security has not been adopted, but that in practice shipowners take out an insurance policy or join P&I clubs. The Committee recalls, with reference to the 2014 amendments, that in accordance with Standard A2.5.2, the Government is required to ensure the provision of an expeditious and effective financial security system to assist seafarers in the event of their abandonment. The Committee also recalls that the financial security for repatriation is one of the general areas that are subject to a detailed inspection by an authorized officer in port of a Member carrying out a port State inspection pursuant to Standard A5.2.1 (Appendix A5-III). The Committee once again requests the Government to adopt the necessary measures to give full effect to Regulation 2.5, paragraph 2, and Standard A2.5.2. The Committee also once again requests the Government to provide a copy of a model certificate or other documentary evidence of financial security containing the information required in Appendix A2-I of the Convention (Standard A2.5.2, paragraph 7).

Regulation 2.5 and Standard A2.5.1, paragraph 2(b). Repatriation. Maximum period of service on board. The Committee notes that the MSC does not specify the maximum duration of service periods on board. The Committee recalls that pursuant to Standard A2.5.1, paragraph 2(b), the maximum duration of service periods on board shall be “less than 12 months”. In this regard, it observes that, further to a combined reading of Standard A2.4, paragraph 3, on annual leave, and Standard A2.5.1, paragraph 2(b), on repatriation, the maximum continuous period of service on a ship without any leave is in principle 11 months. The Committee therefore requests the Government to indicate the maximum duration of service periods on board applicable to ships flying the Togolese flag and to specify the measures adopted to ensure compliance with Standard A2.5.1, paragraph 2(b).

Regulation 2.5 and Standard A2.5.1, paragraph 2(c). Repatriation. Entitlements. The Committee notes that section 285 of the MSC provides that repatriation shall be considered to have been ensured when suitable employment is found for the seafarer on board a ship destined for the port of embarkation referred to in section 281(1) (a port of embarkation in Togo). In cases where a seafarer is repatriated as a member of a crew, she or he shall be entitled to remuneration for the services provided during the voyage. The Committee recalls that Regulation 2.5, paragraph 1, provides that seafarers have a right to be repatriated at no cost to themselves in the circumstances and under the conditions specified in the Code, and that nothing in the Code provides that the shipowner may fulfil the obligation of repatriation by securing employment, even if it is suitable and paid, for a seafarer on board a ship sailing to the destination of repatriation. The Committee requests the Government to amend section 285 of the MSC to ensure its conformity with the Convention.

Regulation 2.5 and Standard 2.5.1, paragraph 3. Repatriation. Prohibition of advance payment and to recover costs from seafarers. The Committee notes that section 284 of the MSC provides, in accordance with Standard 2.5.1, paragraph 3, that it is prohibited for the shipowner to require seafarers to make an advance payment towards the cost of repatriation at the beginning of their employment. It is also prohibited to recover the cost of repatriation from the seafarer’s wages or other entitlements, except where the seafarer has been found, in accordance with national laws or regulations or other relevant provisions or applicable collective bargaining agreements, to be in serous default of her or his employment obligations. The Committee requests the Government to provide the provisions setting out the procedure to be followed and the standard of proof applicable for a seafarer to be found to be in serious default of her or his employment obligations.

Regulation 3.1 and the Code. Accommodation and recreational facilities. The Committee notes that section 276 of the MSC provides that all ships flying the Togolese flag shall be in compliance with the minimum standards set out in the present Code and the regulations adopted for its implementation with respect to the conditions of accommodation and the recreational facilities to be provided to seafarers …. The Committee notes that section 278 of the MSC provides for the adoption of decrees in the Council of Ministers to determine the conditions for the application of section 276 of the MSC. The Committee requests the Government to provide copies of all the measures adopted or under preparation to give effect to the detailed requirements of the MLC, 2006, respecting accommodation and recreational facilities on board ships (Regulation 3.1 and Standard A3.1) and to indicate the measures that are applicable to ships constructed prior to the date of the entry into force of the MLC, 2006, for Togo, which ensure decent accommodation and recreational facilities for seafarers working or living on board these ships (Regulation 3.1, paragraph 1).

Regulation 4.1 and the Code. Medical care on board and ashore. The Committee previously noted that sections 354 to 357 of the MSC cover the organization and objectives of medical care for seafarers, which is the responsibility of emergency medical assistance on board ships and on drilling platforms. The Committee noted that the organization and operation of health services for seafarers shall be determined by decree in the Council of Ministers and requested the Government to provide information on all the measures prepared or adopted for this purpose. The Committee notes that these measures have not yet been adopted and that the Government refers to sections 327 et seq. of the MSC, which concern the responsibilities of the shipowner in the event of illness, accidents and death while at sea. The Committee recalls that Regulation 4.1, paragraph 2, provides for all seafarers to be covered by adequate measures for the protection of their health and to have access to prompt and adequate medical care whilst working on board. The Committee also recalls that Standard A4.1, paragraphs 3 and 4, provide that each Member shall adopt laws and regulations establishing requirements for on-board hospital and medical care facilities and equipment and training on ships that fly its flag. The Committee requests the Government to adopt the necessary measures without delay to give full effect to Regulation 4.1 and Standard A4.1.

Regulation 4.2, Standard A4.2.1, paragraphs 8 to 14, and Standard A4.2.2. Shipowners’ liability. Financial security. The Committee noted previously that the MSC does not take into account the 2014 amendments concerning shipowners’ liability (Standards A4.2.1 and A4.2.2) and that the requirements are not set out in the provisions of the MSC for the implementation of this financial security to assure compensation in the event of the death or long-term disability of seafarers due to an occupational injury, illness or hazard. The Committee noted the Government’s indication that the provisions respecting the financial security had not been adopted, but that in practice shipowners take out an insurance policy or join P&I clubs. The Committee notes the Government’s indication that the financial security referred to above is assured through the welfare and social insurance scheme applicable in Togo and possibly through private insurance policies (sections 323 to 326 and 347 of the MSC). However, the Committee notes that these provisions of the MSC do not set out the minimum requirements for the financial security envisaged in Standards A4.2.1 and A4.2.2 and that the Government admits that the current scheme does not give effect to certain of these minimum requirements (requirement to carry on board a certificate or other documentary evidence of financial security issued by the financial security provider; prior notification). Recalling that the financial security relating to shipowners’ liability is one of the general areas that are subject to a detailed inspection by a Member carrying out a port State inspection pursuant to Standard A5.2.1 (Appendix A5-III), the Committee once again requests the Government to adopt the necessary measures to give full effect to Standards A4.2.1 and A4.2.2 and to provide detailed information on the implementation of these provisions. The Committee once again requests the Government to provide a copy of a model certificate or other documentary evidence of the financial security containing the information required in Appendix A4-I of the Convention (Standard A4.2.1, paragraph 14).

Regulation 4.3 and the Code. Health and safety protection and accident prevention. The Committee previously noted that the provisions of the MSC respecting health and safety protection and accident prevention (sections 276 and 310) require the adoption of implementing regulations to give full effect to Regulation 4.3 and Standard A4.3. The Committee requested the Government to provide information on all the measures adopted for this purpose. The Committee notes that these measures have not been adopted. The Committee further notes that section 358 of the MSC provides that on each ship with more than ten seafarers, titular and substitute crew delegates shall be elected in accordance with the requirements set out in the laws and regulations that are in force. The Committee recalls that Standard A4.3, paragraph 2(d), provides for the establishment of a safety committee on board ships on which there are five or more seafarers and that the authority shall be specified of the ship’s seafarers who have been appointed or elected as safety representatives to participate in meetings of the ship’s safety committee. Finally, the Committee notes the Government’s indication that no provision sets out the requirement for shipowners to conduct risk evaluations in relation to occupational safety and health on board ship (Standard A4.3, paragraph 8), but that in practice, in order to be in compliance with ILO standards, the maritime authority ensures that shipowners conduct risk evaluations in relation to occupational safety and health on board ship. The Committee once again requests the Government to adopt all the necessary measures to give full effect to Regulation 4.3 and Standard A4.3.

Regulation 4.5 and the Code. Social security. The Committee noted in its previous comments the Government’s indication that the branches of social security from which seafarers benefit are covered by affiliation to the general social security scheme. The Committee noted that sections 347 to 353 of the MSC provide that all seafarers ordinarily resident in Togo shall benefit from the protection set out in the regulations, without prejudice to the protection established in relation to on-board medical care and sickness and injury occurring on board ship, for the following branches of social security: old-age benefit; employment injury benefit; family benefit; maternity benefit; invalidity benefit; and survivors’ benefit (section 348). Recalling that the Government indicated previously that the affiliation of seafarers to the National Social Security Fund is not operational in practice, even though it is provided for by the national legislation, the Committee requested the Government to provide detailed information on the application of section 348 of the MSC in respect of seafarers who are ordinarily resident in Togo. The Committee notes that the Government has not provided the information requested on this matter. It also notes the Government’s indication that the draft collective agreement that is in the process of being adopted could provide for an improvement in the benefits currently available to seafarers or an extension of the social security protection of seafarers to branches in which they do not yet benefit from such protection (Standard A4.5, paragraph 11). The Committee further notes the Government’s indication that no measures have been adopted for the provision of social benefits to seafarers who are not resident on the national territory, who work on ships that fly its flag and who do not have adequate social coverage (Standard A4.5, paragraphs 5 and 6). Finally, the Committee notes the Government’s indication that fair and effective procedures for the settlement of disputes in relation to the social security of seafarers (Standard A4.5, paragraph 9) have not yet been determined, but that they are envisaged in section 349(4) of the MSC. The Committee once again requests the Government to provide detailed information on the manner in which the social security coverage envisaged in section 348 of the MSC is provided in practice for seafarers who are ordinarily resident in Togo. It requests the Government to provide detailed statistics on the number of seafarers who are in practice affiliated to the general social security scheme. It further requests the Government to indicate any measures that are being prepared or have been adopted to give full effect to Standard A4.5, paragraphs 5, 6, 9 and 11.

Regulation 5.1 and the Code. Flag State responsibilities. Noting the absence of specific regulations, the Committee previously requested the Government to adopt the necessary measures as soon as possible to give full effect to Regulation 5.1 and the related provisions of the Code. The Committee notes the Government’s indication that in practice inspections are undertaken frequently to enforce scrupulously the requirements set out in the MLC, 2006. The Committee notes that the implementing measures necessary to give full effect to the requirements of Regulation 5.1 and the related provisions of the Code have still not been adopted. The Committee also notes the Government’s indication that section 361 of the MSC provides that the competent maritime authority shall determine the public institutions or other organizations that it recognizes as competent and independent to undertake inspections and issue certificates and that, under the terms of this provision, organizations can be authorized and procedures have been established to ensure their competence and independence. The Committee however notes that the Government has not provided a list of the recognized organizations authorized to act on its behalf, with an indication of the functions that they are authorized to carry out (Standard A5.1.2, paragraph 4). The Committee notes that section 188 of MSC provides for the creation of an independent maritime safety investigation bureau with responsibility for investigating and determining the causes of maritime casualties and incidents at sea. However, the Committee notes that the MSC does not provide that an official inquiry shall be held into any serious maritime casualty leading to injury or loss of life that involves a ship that flies the Togolese flag, nor that the final report of the inquiry shall normally be made public (Regulation 5.1.6, paragraph 1). The Committee once again requests the Government to adopt the necessary provisions as soon as possible to give full effect to Regulation 5.1 and the related provisions of the Code. It requests the Government to provide it with the list of recognized organizations authorized to act on its behalf, with an indication of the functions that they are authorized to carry out (Standard A5.1.2, paragraph 4). It requests the Government to indicate the measures that require an official inquiry to be held into any serious maritime casualty leading to injury or loss of life that involves a ship flying the Togolese flag and that the final report of the inquiry shall normally be made public (Regulation 5.1.6, paragraph 1).

Regulation 5.2.1 and the Code. Port State responsibilities. Inspections in port. In its previous comments, the Committee noted that Togo has adhered since 12 September 2007 to the Abuja Memorandum of Understanding (MoU). While recognizing the value of the coordinated implementation of inspections under port State control at the level of this regional organization, the Committee recalled that the national authorities are under the obligation to give full effect to the provisions of the MLC, 2006, in their own legislation and requested the Government to adopt the necessary measures as soon as possible to give full effect to Regulation 5.2.1 and Standard A5.2.1, as such measures are envisaged in the form of decrees in the Council of Ministers by section 363 of the MSC. Noting that the Government has not provided information on any measures that are being prepared for this purpose, the Committee once again requests it to adopt the necessary measures as soon as possible to give full effect to Regulation 5.2.1 and Standard A5.2.1.

Regulation 5.2.2 and the Code. Port State responsibilities. Onshore seafarer complaint-handling procedures. The Committee noted previously that the MSC does not address onshore seafarer complaint-handling procedures. The Committee notes the Government’s indication that there are no formally established procedures, but that in practice seafarers have recourse to the ITF or maritime labour inspectors, and that around ten complaints have been dealt with internally since the last report, in full confidentiality. Recalling that Regulation 5.2.2 and Standard A5.2.2 set out the framework for onshore seafarer complaint-handling procedures and call for their articulation with other procedures envisaged by the MLC, 2006, such as on-board complaint procedures and inspections by the port State, the Committee requests the Government to adopt the necessary measures to give full effect to these provisions of the Convention.

Additional documents and information requested. The Committee requests the Government to provide the following documents and information: an example of the approved document for the seafarer’s record of employment (Standard A2.1, paragraphs 1 and 3); an example of a seafarers’ employment agreement (Standard A2.1, paragraph 2(a)); a copy in English of the approved standardized table for shipboard working arrangements (Standard A2.3, paragraphs 10 and 11); a copy of the standard form established by the competent authority for the recording of seafarers’ daily hours of work or their daily hours of rest (Standard A2.3, paragraph 12); for each type of ship, a typical example of a safe manning document or equivalent issued by the competent authority (Standard A2.7, paragraph 1); an example of the standard medical report form for seafarers (Standard A4.1, paragraph 2; see also Guideline B4.1.2, paragraph 1); a copy of the requirements for the medicine chest and medical equipment and for the medical guide (Standard A4.1, paragraph 4(a); see also Guideline B4.1.1, paragraphs 4 and 5); an example of a document (for example, Part II of the DMLC) outlining a shipowner’s practices or on-board programmes (including risk evaluation) for preventing occupational accidents, injuries and diseases (Standard A4.3, paragraphs 1(c), 2(b) and 8); a copy of the document(s) used for reporting unsafe conditions or occupational accidents on board ship (Standard A4.3, paragraph 1(d)); a report or other document containing information on the objectives and standards established for your country’s inspection and certification system, including the procedures for its assessment (Regulation 5.1.1, paragraph 5); an example or examples of authorizations given to recognized organizations (Regulation 5.1.1, paragraph 5; Regulation 5.1.2, paragraph 2); a copy in English of the interim maritime labour certificate if your country issues such a document (Regulation 5.1.3); a copy of the annual reports on inspection activities, issued in accordance with Standard A5.1.4, paragraph 13, during the period covered by this report; a standard document issued to or signed by inspectors setting out their functions and powers (Standard A5.1.4, paragraph 7; see also Guideline B5.1.4, paragraphs 7 and 8); a copy of any national guidelines issued to inspectors in implementation of Standard A5.1.4, paragraph 7; a copy of the form used for an inspector’s report (Standard A5.1.4, paragraph 12); a copy of any documentation that is available informing seafarers and other parties concerned about the procedures for making a complaint (in confidence) regarding a breach of the requirements of the Convention (including seafarers’ rights) (Standard A5.1.4, paragraph 5; see also Guideline B5.1.4, paragraph 3); a copy of your country’s model for on-board complaint procedures, if developed, or of typical procedures that are followed on ships that fly its flag (Regulation 5.1.5); a copy of any national guidelines issued to inspectors in implementation of Standard A5.2.1, paragraph 7; and a copy of any document that describes the onshore complaint-handling procedures (Regulation 5.2.2).