Written Arguments

Before the Hon’ble Chairman, National Industrial Relation Commission, Islamabad.

Case No. 18 (1)/2000 Kot Addu Power Company Vs. Al-Takbeer KAPCO Labour Union, Kot Addu Power Company and others. WRITTEN ARGUMENTS Respectfully Sheweth: 1.

That prior to privatization, WAPDA used to pay generation allowance to those employees who were directly connected with generation. The rate at which these employees were paid generation allowance was as under: -

2.

a)

Upto 7 years service

50% of pay

b)

7 to 14 years service

55% of pay

c)

14 years and above

6-% of pay

That non-generation employees were paid hardship allowance in lieu of generation allowance at the rate mentioned below: -

3.

a)

BPS 1 to 7

Rs. 75/- per month

b)

BPS 8 to 10

Rs. 100/- per month

c)

BPS 11 to 16

Rs. 150/- per month

That on execution of Staff Agreement, generation and nongeneration employees were treated at par and were given generation allowance. It is pertinent to mention here that nongeneration employees after privatization started receiving generation allowance which is more than hardship allowance. This was actually done to keep both the categories of employees at par, photo-copy of agreement attached.

4.

That on 15.5.1997, an agreement was executed in which certain monetary benefits were given to employees on the demand of CBA, copies which were endorsed to various

Govt. functionaries. In the same agreement working days and working hours were also agreed upon in para 5 of agreement which is as under: Working days and working hours: Consequent upon declaring Sunday as holiday and Friday as half working day, following office timings were agreed enabling to have 42 hours per week for day worker: Start

5.

Finish

Lunch/prayer break

Monday—Thursday

0800 1600

1300—1330

Friday

0800 1230

No break

Saturday

0800 1600

1300—1330

That another agreement was executed on 15.9.1997 between Management and CBA Union before the Conciliator and one of the demands of the CBA was: “Demand No. 2—50 per cent technical allowance to Technical employees.” STATEMENT: The

Management

is

already

paying

generation

allowance to all workers irrespective of technical or nontechnical employees, but in the present case, only technical staff will gent technical allowance from grade 1 to 10 Rs. 300/- per month, grade 11 to 15 Rs. 400/- per month and grade 16 Rs. 500/- per month. However, technical staff will be defined only those directly connected with generation and as per WAPDA previous practice. In view of the above, it is therefore, prayed that petition may kindly be accepted as the non-generation staff does not does not stand entitled for hardship allowance as they have been given generation allowance. Dated: 4.2.2002 Through: RIAZ-UL-HASSAN Advocate