Introduction: expensive penalties for minor oversights
A visit from the Ministry of Labor can arrive unannounced and expose seemingly minor shortcomings: unapproved internal regulations, outdated workplace conduct policies, a lack of supporting documentation for the Occupational Health and Safety Management System (OHSMS), and unformed committees. The result is usually the same: requirements, official notices, and fines that impact both finances and reputation. In my experience, preparing teams before the visit and responding methodically afterward drastically reduces the risks.
1) What do inspection, surveillance and control visits consist of?
The visits aim to verify full compliance with labor regulations. The inspector may:
- Identify yourself and explain the purpose of the procedure.
- Request documents and evidence (physical or digital) and conduct interviews.
- Prepare a report with findings, requirements, and deadlines.
Key points:
- You cannot refuse the visit. It must be handled by authorized personnel in a cooperative manner.
- The scope can be general (global compliance) or thematic (e.g., RIT, harassment, working hours, SG-SST).
- The process can continue with written requirements, a statement of charges, and a resolution (with appeals).
In my support work, I prepare inspection handling manuals and train receptionists, human resources staff, and leaders so they know who is handling the inspection, what they are delivering, and how they are documenting it.
2) Document checklist: what they usually ask for (and you should have ready)
Internal Work Regulations (RIT)
- Approved and in force; with signatures/adoption record and evidence of socialization to staff.
- Annexes: disciplinary regime, schedules, breaks, scales of offenses and sanctions.
Key internal policies
- Coexistence and prevention of workplace harassment (committee, minutes, training).
- Personal data protection applicable to the employment relationship.
- Confidentiality and non-competition (where applicable).
- Teleworking/Remote work: written agreements, staffing and risks.
- Use of reporting channels and internal investigation protocol.
SG-SST
- Hazard matrix, annual plan, induction/training, COPASST formed, inspections, incident reports.
- Occupational medical assessments and PPE deliveries.
Linkage and payroll
- Contracts and addenda, social security affiliations, payrolls, payments and pay slips.
- Manual of functions and delivery records (staffing, equipment, policies).
Government and evidence
- Organizational charts/roles, powers, log of documents requested and delivered during the visit.
When I detect that RITs or policies are missing, I prioritize an express adoption with legal validity and documented socialization before the deadline of the requirement expires.
3) What happens if you don’t have clear RIT or policies?
Immediate risks
- Fines that the authority determines based on company size, severity, damage, recidivism, or obstruction.
- Corrective orders (adopt RIT/policies, form committees, train).
- In severe cases, suspension of activities or temporary closures.
Side effects
- Internal sanctions can be challenged if the disciplinary regime is not in the RIT or was not socialized.
- Higher likelihood of successful complaints regarding harassment, unfair dismissals, or enhanced job security.
How the penalty is graduated (in practice)
- Nature and magnitude of the non-compliance.
- Company size and responsiveness.
- Employer conduct: cooperation vs. obstruction.
- Recidivism and demonstrable remediation measures.
In defenses, I usually present verifiable corrective measures (adoption of RIT, training done, committees in order) to seek reductions or even dismissal.
4) Visitor handling manual: roles, spokesperson and minutes
Before
- Define single spokesperson (HR or advisor), alternate and escalation chain.
- Have a data room with all critical documents and their supporting evidence.
- Train receptionists and managers: how to receive the inspector and who to call.
During
- Verify identification, purpose and scope of the visit.
- Request that every request be recorded in the minutes; keep your own log of what has been delivered.
- If a document is not ready, commit to a reasonable timeframe and record the commitment.
After
- Gather the team and create an action plan with responsibilities and deadlines.
- Prepare responses to requirements and the evidentiary package (RIT/policies, minutes, socialization supports).
- Evaluate the need for corrective measures and internal communication.
I accompany these phases with model minutes and a list of “do nots”: improvising answers, submitting incomplete documents, or arguing unnecessarily.
5) Sanctioning process and defense: from the request to the appeal
- Requirement: to rectify and demonstrate correctness.
- Statement of charges: present reasoned defenses and evidence.
- Resolution: if there is a sanction, file appeals (reconsideration and, if applicable, appeal).
- Compliance: execute orders within the deadline and document everything.
Good practices:
- Evidentiary order: socialization policies/minutes/records first; then application evidence.
- Technical and collaborative tone: reduces perceptions of risk.
- Align defense with labor, disciplinary, and health and safety fronts to avoid contradictions.
In complex proceedings, in addition to defending, I design and implement corrective measures so that the file shows a credible compliance curve.
6) Frequently Asked Questions
Can they arrive without prior notice? Yes. That’s why it’s advisable to have a manual of inspections and defined roles.
What documents do they look at first? Internal work regulations, coexistence/harassment policies, occupational health and safety management system, committees, contracts, and social security.
Will I be fined if I don’t have a RIT (Registry of Adoption and Early Socialization)? It’s a common violation. Submitting proof of adoption and rapid socialization helps mitigate the risk.
How do I reduce a fine? With solid arguments and proof of effective correction (not promises).
What should I do if the minutes contain errors? Request corrections or leave written comments at the meeting itself.
7) How we support you (applied experience)
- We structure and update RIT, internal policies, disciplinary protocols and coexistence manuals with legal validity.
- We prepare and accompany Ministry visits: diagnosis, corrective measures and defense against administrative or judicial actions.
- We manage disciplinary processes and dismissals with criteria of proportionality and legality.
- We design contingency prevention programs (harassment, reinforced stability) with a human and strategic approach.
Our purpose is to protect your assets and organizational climate: real compliance, healthy labor relations, and evidence ready for when the State comes knocking.
Conclusion and call to action
Having an approved Internal Regulations Manual (RIT) and clear policies isn’t just paperwork: it’s your best defense against an inspection. If you’ve already been notified of a visit—or want to protect yourself—let’s schedule an express review and get your inspection manual, document checklist, and response plan ready. Prevention is better than paying an avoidable penalty.
