Employment references - lacking information issue

I’m in the process of gathering backup documentation in order to apply to the ACS Skill Assessement.

For my main 7 year work experience, which is crucial for the assessment success, the employer has issued an incomplete reference letter to me lacking:

  • description of duties
  • actual hours worked per week
  • country where employment was undertaken

They won’t issue:

  • a complete reference letter compliant with ACS standards
  • a justification on why a reference letter cannot be provided

May I still opt for the Statutory Declarations and Affidavits alternative?

Am I able to satisfy ACS requirements by providing additional documentation?

I might provide an employment contract containing number of hours worked per week.

The employer is Italian, its office is in Italy and the address, italian too, is included in the documentation. Would this be enough to compesate the explicit “country where employment was undertaken” information?

I’ve been unable so far to gather a document that contains the description of duties.

Can you please suggest which is the best course of action in this scenario?

Thanks,
Sergio