Section 31 of the Employment Act provides that an employer shall at all times, at his own expense, provide reasonable housing accommodation for each of his employees either at or near to the place of employment, or shall pay to the employee such sufficient sum, as rent, in addition to the wages or salary of the employee, as will enable the employee to obtain reasonable accommodation. Kenya National Private Security Workers Union v Kenya Kazi Security Services Limited. The parties had failed to enter into a collective bargaining agreement as earlier ordered by the court. The court held that it was the duty of the Respondent to provide its guards with free housing accommodation at or near the US Embassy or in the alternatively, to provide sufficient rent to enable the employee obtain such accommodation. http://kenyalaw.org/caselaw/cases/view/87413