Komentar Sindikata na odgovor Vlade Crne Gore na Direktni zahtev ILO CEACR iz 2021. godine u vezi primene MLC-a 2006

Dear Members of the CEACR,

IUWMST Montenegro, as the sole representative trade union for seafarers and dock workers in Montenegro, is affiliated with both the International Transport Workers’ Federation (ITF) and the Confederation of Trade Unions of Montenegro. Therefore, the effective implementation of the Maritime Labour Convention, 2006 (MLC, 2006), as amended, is of critical importance to our organization and its members.

We wish to submit the following comments in response to the Government of Montenegro’s reply to the CEACR’s Direct Request of 2021.

Issue 1: Article VII of the Convention – Consultations

Representatives from IUWMST Montenegro have not been included in any working group concerning the implementation of the MLC, 2006, in Montenegro. This exclusion is of significant concern to our union, as we represent the primary group of workers impacted by the provisions of the Convention.

Issue 2: Branch Collective Agreement for Seafarers on Ships in the International Shipping Trade (CBA)

We wish to draw attention to the Branch Collective Agreement for Seafarers on Ships in the International Shipping Trade (Official Gazette of Montenegro, No. 88/2023, dated 29 September 2023), hereinafter referred to as “the CBA” which we have attached for your reference.

In the government’s response to the CEACR, the CBA was overlooked, despite its relevance to the issues raised. The CBA applies to seafarers working aboard Montenegrin-flagged vessels engaged in international trade, which constitutes the vast majority of Montenegrin seafarers. The CBA represents a pragmatic solution to the challenges posed by the prolonged political instability in Montenegro, which has hindered progress on amending the Maritime Navigation Safety Law.

The following table outlines the provisions of the CBA that directly address the issues raised by the CEACR:

CEACR Request

Provision of the CBA

Comments

Regulation 1.1 and Standard A1.1, paragraph 4

Article 4, paragraph 9

 

Regulation 1.3, paragraph 2

Article 6, paragraph 3

The Government has misunderstood the training in question.

Regulation 2.1 and Standard A2.1, paragraph 1(b)

Article 4, paragraph 3

 

Regulation 2.4 , paragraph 2

Article 15, paragraph 3

 

Regulations 2.1 and 2.2, Standard A2.1, paragraph 7 and Standard A2.2, paragraph 7

Article 18, paragraphs 5, 6 and 7

 

We respectfully request that the CEACR give due consideration to the provisions of the CBA, which address the compliance issues raised in the context of the MLC, 2006.

We remain committed to working with the government and the CEACR to ensure the proper implementation of the Convention and the protection of the rights of seafarers in Montenegro.

Sincerely,

Agim Mila, M.Sc.

President, IUWMST Montenegro

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