30 for companies cannot be contracted out. The Supreme Court, in Universal Robina Sugar Milling Corporation v. Acibo,32 even expounded this further: "Article 280 of the Labor Code provides for three kinds of employment arrangements, namely: regular, project/seasonal and casual. Regular employment refers to that arrangement whereby the employee "has been engaged to perform activities which are usually necessary or desirable in the usual business or trade of the employer." Under the definition, the primary standard that determines regular employment is the reasonable connection between the particular activity performed by the employee and the usual business or trade of the employer; the emphasis is on the necessity or desirability of the employee's activity. Thus, when the employee performs activities considered necessary and desirable to the overall business scheme of the employer, the law regards the employee as regular."33 Social security was also not universal. While social protection schemes covered most respondents, a sizable proportion of the participants were not. Most also did not have access to sick or vacation leaves. 42.9% were not informed about the process of applying for SSS benefits. Consistency of Labor and OSH Standards Compliance Another recurring theme across the survey answers is the variation in the consistency of company/employer compliance with labor and OSH standards. In many instances, most respondents reported compliance with labor and OSH standards, but there remained sizable minorities whose labor rights were not upheld. For example, while the majority (68.8%) of respondents said that their workplaces were safe and that they received PPEs and OSH orientations, 35.3% reported that their workplace posed risks or hazards to their safety. Furthermore, while most respondents stated that they or their company had undergone OSH orientations, the frequency of such activities differed—some had regular, scheduled sessions, others had one-off seminars, and even more rarely/unpredictably, or none at all. Regarding workplace labor standards, 54% stated that they were paid at or above the minimum wage, with most respondents at the minimum wage level. Most received benefits and had decent facilities, but only 48% enjoyed 24-hour day-offs. Most respondents reported working beyond the regular eight hours, with five 32 33 Universal Robina Sugar Milling Corporation v. Acibo, G.R. No. 186439, 713 SCRA 596 (2014) Id.