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Memorandum of Settlement between Apex Holdings Ltd. and Bangladesh Garment, Textile, & Leather Workers’ Federation (BGTLWF), 24^th September 2017

Memorandum of Settlement

This Memorandum is Executed on the 24^th day of September, 2017.

BETWEEN

Apex Holdings Ltd. (hereafter referred to as the Apex) Address at Rupayan Golden Age (5^th & 6^th Floor), 99, Gulshan Avenue, Gulshan, Dhaka- 1212, represented by its General Manager (Admin & HR) Mr. Minarul Akbar

_______1^st PARTY

AND

Bangladesh Garment, Textile, & Leather Workers’ Federation (hereinafter referred to as “BGTLWF”), 85, Naya Palton (2^nd floor), Dhaka-1000, represented by its President Kutubuddin Ahmed, on behalf of GOLAM MOSTAFA & OTHERS

_______2^nd PARTY

That a dispute aroused following the termination of nineteen workers including Mr. Golam Mostofa Sr. operator of Apex lingerie Ltd, who was also arrested by police in a case under ICT Act, other eighteen workers are namely: i.Suzon Mia, ii.Mokammel Haque, iii.Rashed Ali, iv.Hannan Mia, v.Monir Hossain, vi.Nuruzzaman, vii.Shofiul Islam, viii.Ataur Rahman, ix.Mahmuda Aktar, x.Shompa Begum, xi.Ishrafil, xii.Laza Mia, xiii.Babli Begum, xiv.Forid Hossain, xv.Arzina Aktar, xvi.Reshmi Begum, xvii.Mamunur Rashid, xviii.Mamun Mia, discharged from service on different dates in 2016.

That the said Nineteen workers, thereafter, approached BGTLWF and sought its assistance for their reinstatement in their services at Apex. MR. Kutubuddin Ahmed, President, Bangladesh Garment, Textile & Leather Workers’ Federation (hereinafter referred to as “BGTLWF”), play the role as a mediator between the parties.

That several meetings were held between the parties on different dates, wherein both parties agreed to settle the issue through bipartite discussion Following fruitful discussions, the parties have now agreed to resolve the dispute on the following terms and conditions:

To formalize the reinstatement, the above-mentioned workers shall formally apply to the management to reinstatement them in their services.

2. The Management and Md. Golam Mostafa will take necessary steps to withdraw their respective cases (Complaint Case No.406/2017 filed by Md. Golam Mostafa and Case No. 32(1)17 file by Apex) from the respective courts within September 30, 2017.

4. After the implementation of the above terms and conditions, BGTLWF shall write to the buyers/brands and other international organizations declaring that the dispute has been settled amicably and with entire satisfaction of the parties.

We do hereby solemnly declare after reading this Memorandum of Settlement paper, we are both parties including witnesses and acknowledgement signature holders willingly give consent and agree with each and every condition of this Memorandum of Settlement paper. Now we sign below in prescribed manner on the 24^th day of September, 2017 with full satisfaction.

Witnesses:                                                      For Apex Holdings Ltd.

1.

HABIBUR RAHMAN SARKAR                  Md. Minarul Akbar

2.                                                                     _____________________

Kabirul Hasan                                                 (1^st party)

BGTLWF                                                                                                                   

3.                                                                     For Bangladesh Garment, Textile & Leather

(A.K.M. Nasum)                                             Workers’ Federation (BGTLWF)

Advocate                                                         ___________________

4.                                                                     (KUTUBUDDIN AHMED)

(Md. Morshed Alam)                                     _______________________

Advocate                                                         (2^nd party)