Teleperformance : Special audit report on labor relations of Teleperformance in Colombia – November 24, 2022

TP Colombia

Labor Relations Special Audit

Global Audit Report

Planning Package

Background:

After concerns were raised around the content moderation practices, wage and labor practices, and poor working conditions at Teleperformance Colombia, the Global Audit team was engaged by TP Group ExCom to perform a review employee wages, shifts/breaks, and Employee Assistance Program (EAP) and wellness practices.

Scope:

• Compliance with wage and hour laws and regulations
• Wage analysis for content moderation clients
• Wellness & health program
• Workplace and workplace safety compliance - Client A
• Social environment - Client A
• Ethics & transparency - Client A

Approach:

• Interview key leaders/personnel to gain an understanding of processes/procedures (e.g., employee relations).
• Interview Wellness program leaders and operational staff regarding the current Wellness programs, access, and use by employees.
• Conduct focus group discussions with employees holding key positions. (i.e., content moderators, quality analysts, supervisors).
• Engage an internal Colombia labor law attorney to review key labor requirements and review TP Colombia compliance.
• Review corporate social responsibility & sustainability processes and controls.

Timeline:

• Planned dates November 10th through November 23rd.

• 1. Complete interviews​ & fieldwork, November 14th through 18th (onsite & virtual) o Evaluate information and identify process gaps,​ Nov 19 through21st
     o Report findings and gap closure plans, by November 23rd.
• The audit team consisted of 15 Teleperformance employees, of which ~1,522 hours of audit work was performed. In addition, ~386 audit
  tests were performed which included reviews of various TP documents (e.g., payroll, human resource, and schedule data, etc.) and client documents.

2

Executive Summary

Labor & Wage Analysis

The audit team conducted an onsite and remote review of Colombia Labor and Workplace requirements. No noncompliance/reportable findings were identified in the following categories:

• No noncompliance was identified for 49 applicable Colombia Labor and Workplace regulations.
• Wage analysis to determine pay rates, identified Teleperformance is paying at or well above minimum wage for content moderation clients.
• Reviewed scheduled and worked hours and identified that appropriate breaks and lunch periods were scheduled and taken by content moderators.
• Client requirements surrounding hours of operations, team ratios, training, schedules, etc.
• Wellness programs are in place for content moderators and being utilized.
• Content moderators are receiving additional pay for overtime and nightshifts.

Workplace and workplace safety, social environment, ethics & transparency analysis

An on-site audit and a virtual audit by the Global Health and Safety team conducted a review of 9 categories for the site where the Trust & Safety Client A is performed. The two teams conducted analysis, validation and review of files, documents, and records; Work at Home (WAH)

• on-siteinterviews; on-site inspections, and interviews with leaders and area managers. Three findings were identified:
• Health & Safety - Facility Conditions (3 Findings - of which 2 are closed) CCTV usage, inspection reports, on-site inspections, Occupational Health
• • safety compliance, facility risk assessment, accident records, and emergency procedures were reviewed.
  • 1. Conditions impacting a comfortable work environment was identified; A missing handrail for a handicap ramp, elevator out of service, missing safety signage, and minor cleanliness issues were noted. (action plan closed)
    2. Occupational Health & Safety and the environment was identified; Missing evacuation route signage, missing signage on a cleaning tank, missing lids on bathroom bins, and lack of awareness by employees on reporting accidents was made. (action plan closed)
    3. Inadequate temperature control in training rooms was identified. (I.e., the training rooms were too hot) (action plan closed)

3

Detailed Findings by Topic

Part A: Remote Labor & Wage Analysis

An on-site and remote audit was conducted to review key Labor and Wage aspects of content moderation services provided by TP Colombia. The focus was on Team Lead positions and below. Manager and above were excluded in the review.

1. Colombia Labor and Workplace Regulations (No Findings)
2. 1. TP Colombia Legal/HR identified 49 applicable Colombia Labor and Workplace Regulations.
   2. Legal and Human Resources indicated that TP Colombia is compliant and supporting evidence is available.
3. Wage Analysis - (No Findings)
4. 1. All content moderators assigned to Client A had an average monthly wage is well above $1,000,000 Colombia Pesos (COP).
   2. 1. Additional income is also paid for night shifts, holidays and Sunday work.
      2. For content moderators, Spanish is the lowest wage while Trilingual is the highest wage, which are all above minimum wage.
   3. After a review of 6 content moderation clients, the average monthly wage per position is at or above $1,000,000 (COP).
   4. 1. The average wage for all 6 content moderation clients in this analysis is $2,293,353 (COP), or 229% of minimum monthly wage.
5. Scheduled Hours - Client A (No Findings)
6. 1. As is common practice in Colombia service industry, Client A content moderators are typically scheduled to work 6 days per week, 48 hours per week including a one-hour lunch break.
   2. Operating hours for Client A are 7 days per week; 24 hours per day; 365 days per year.
   3. Content moderator schedules include one hour lunch breaks which is compliant with local regulations. In addition, multiple breaks are also scheduled, where ~6 hours is utilized for production time and ~2 hours are for various breaks and wellness time. Wellness breaks are scheduled for 30 minutes per day. (see below)
7. Break and Wellness Time - Client A (No Findings)
8. 1. Productive time for a content moderators is estimated at 72%, while lunch time is 11%, and the balance or 17% is spent on wellness, coaching, and training.
   2. Break time reporting from August 2022 to October 2022 was available and included Break, Wellness, Lunch, Training, and Meeting time.
   3. Excluding lunch, wellness time was the highest break category over the 3-month period reviewed, at 14 hours per employee, per month.

4

Detailed Findings by Topic

Part A: Remote Labor & Wage Analysis - (Continued)

1. Worked Time - Client A (No Findings)
2. 1. A sampling of employee's worked time from November 2021 through September 2022 did not find employees working excessive hours.
   2. Worked Time is in line with Client A - Workforce Client Requirements.
3. Payroll - Client A (No Findings)
4. 1. There are two pay periods in TP Colombia. (1 - 15; 16 - 31)
   2. Surcharges are paid for working on Sunday, Holidays, Night shift, etc.
   3. Overtime is paid and authorization was granted by the Ministry of Labor by Resolution 2678 of August 11, 2021.
   4. The average salary per hour for January to September 2022 for Client A is well above the Colombia hourly minimum wage for 2022 regulation.
5. Workforce Client Requirements - Client A (No Findings)
6. 1. Client A MSA and SOW are signed. Client stipulations include hours of operation, language requirements, agent/management ratios, breakdown shift example, training cost requirements, and operational service charge requirements.
   2. 98% of Client A assigned employees are working from home. The plan is to move back to brick & mortar over time.

Part B: Workplace and workplace safety, social environment, ethics & transparency

An on-site audit and the Global Health and Safety team conducted a review of 9 categories. They conducted analysis, validation and review of files, documents, and records; Work at Home (WAH) & on-site interviews; on-site inspections, and interviews with leaders and area managers. Overall, the site was well lit, had good ventilation, and overall, was in great condition. Three findings were reported, and overviews of the review categories are below:

Health & Safety - Facility Conditions (3 Findings)

CCTV usage, inspection reports, on-site inspections, Occupational Health & safety compliance, facility risk assessment, accident records, and emergency procedures were reviewed.

1. Conditions impacting a comfortable work environment was identified; A missing handrail for a handicap ramp, elevator out of service, missing safety signage, and minor cleanliness issues were noted. (action plan closed)
2. Occupational Health & Safety and the environment was identified; Missing evacuation route signage, missing signage on a cleaning tank, missing lids on bathroom bins, and lack of awareness by employees on reporting accidents was made. (action plan closed)
3. Inadequate temperature control in training rooms was identified. (I.e., the training rooms were too hot) (action plan closed)

5