Immigration Act , Cap 172; the Price Control (Essential Goods) Act , Cap 113; all ensure regulation of the employment sector in a human rights based approach. 127. The Courts have on several instances reaffirmed the right to form trade unions as was in the Nurses Union case High Court at Nairobi (Nairobi Law Courts) Seth Panyako vs Kenya Union of Domestic, Hotels, Educational Institutions, Hospitals and Allied Workers (2013) eKLR. 128. Courts have also intervened to protect the right to work, for example in the case of a police officer who was retired ‘on medical grounds’ when he got a physical disability. The High Court ruled that the employer should have reassigned the petitioner and instituted reasonable accommodation measures to enable him continue working as a police officer in Paul Pkiach Anupa & Another vs Attorney General & Another (2012)eKLR . In the case Aviation Services Workers Union v Kenya Airways Ltd (2012) eKLR – the industrial court reinstated 447 workers who Kenya Airways had declared redundant. 129. Some of the administrative measures that the Government has put in place include the establishment of a National Poverty Centre that among other things undertakes mapping and provides policy advice on how to deal with poverty. There is the National Integrated Framework for Employment Creation and Social Protection. The Government has constructed four multi-purpose dams for sustainable utilization and management of basin based resources. Further, there is the Youth Enterprise Development Fund which seeks to establish a Youth Bank. There are plans to enhance entrepreneurial training. Women are being trained on the formation of co-operatives and financial management ran by the Women Enterprise Development Fund as a way of empowering them. 130. The Government has established State agencies with a mandate to ensure that minimum work standards apply within the informal sector. This is geared towards ensuring that the situation of workers in informal employment is gradually improved through their inclusion in social protection schemes and health schemes. For example, workers with minimal earnings can now join the National Hospital Insurance Fund (NHIF). 131. The Employment Act Cap 226, as well as the Occupational Health and Safety Act Cap 514, Laws of Kenya apply in export processing zones as much as they apply to employers outside such zones. The Government has set a minimum wage which is responsive to the high cost of living. The State undertakes on an annual basis a review of the minimum wage applicable to different cadre of workers. Under the Labour Institutions Act, Cap 234, Laws of Kenya the Government constitutes Wages Councils to deal with emerging sectors of the economy. These include: the Protective Security Services Wages Council which was reconstituted in August 2012 to take care of the workers in the private security sector. In addition the Floricultural Wages Council continues to address issues affecting workers in the flower industry. The State has taken concerted actions to ensure that domestic workers who tend to be particularly vulnerable do get a minimum wage. 132. Kenya also has the Labour Office whose duties include the administration, co-ordination, implementation and enforcement of the Country’s Labour Policy, laws and Regulations. The Central Organization of Trade Unions (COTU) is the umbrella body for trade unions in Kenya and the Confederation of Public Service Trade Unions of Kenya who negotiate tripartite agreements on behalf of their members that have led to improved terms for workers, increased awareness on labour rights, career advancement through various training programs, and merit based employment. 31