Human Rights Risk Assessment
GC has conducted Human Rights Risk Assessment (HRRA) within the GC group since 2015 to identify, prevent and mitigate any human rights risks throughout the value chain due to business operations. These risk assessments cover different activities at the country level, industry sectors, and operational sites in which the company operates, joint ventures where GC has management control, as well as Tier 1 feedstock and non-feedstock suppliers and services. These assessments are conducted every three years.
Moreover, GC conducts HRRA to establish effective management practices for the operational areas at risk, identify human rights related issues and assess impact on risky groups and vulnerable groups which covers women, children, minorities, indigenous people, migrant workers, third-party contracted labor, person with disabilities, LGBTQI+, senior citizens and pregnant women. The HRRA also includes any impacts at a national, operation and individual level. Criteria for risk assessment regarding the human rights are considered based on two factors; the likelihood and the impact. The assessment covers six human rights aspects include labor rights, community rights, supply chain, safety, environment and customer’s rights.
According to the HRRA results, GC has established measures to control and mitigate impacts that may occur, as well as assessed the residual risks after establishing preventive and corrective actions regarding human rights for its business operations. This is to ensure that the human rights management approach is effective in controlling the impacts throughout the value chain.
GC Human Rights Risk Assessment Matrix
GC assesses human rights risks by considering the severity of potential impacts and the likelihood of human rights violations that may arise from its operations. The risks are classified into four levels: Critical, Significant, Low, and Very Low.
Risk Level
GC Human Rights Risk Assessment Matrix and Criteria
| Human Rights Issue | |
|---|---|
| Employee |
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| Supplier / Contractor |
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| Community |
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| Customer |
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| All Rights Holder |
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Risk Assessment Evaluation Criteria: Impacts
Human rights impacts depend on factors such as scale, scope, and the limitations of the ability to remediate negative effects, at a minimum restoring the situation to its original state.
Severity Level
Severe (5)
Impact on physical and mental health
Severe impact on health: serious illness or injury resulting in disability or fatality of >1 person
Impact on other factors (e.g., asset, data privacy, restriction of rights)
Unable to live a normal life, including restrictions on the rights of those affected (forced resettlement, loss of jobs, impact to their jobs to the extent that evacuation is necessary)
Scope (how many people are or will be affected)
Impact affecting all rights holders in the group (e.g., all people in the community, all employees, all suppliers, all customers) (100%)
Remediability (difficulty to restore the people impacted to a situation before impact)
Impossible to restore or will take longer than 3 years to restore the impact (>3 years)
Severity Level
Major (4)
Impact on physical and mental health
Major impact on health: serious illness or injury resulting in disability or fatality
Impact on other factors (e.g., asset, data privacy, restriction of rights)
Affect livelihood to the extent that a major change in lifestyle is necessary (loss of opportunity or increased cost due to relocation, any lifestyle changes that cause debt or restrict the normal quality of life)
Scope (how many people are or will be affected)
Impact on the majority of rights holders within a specific group (50% ~ <100%)
Remediability (difficulty to restore the people impacted to a situation before impact)
Take more than 1 to 3 years to restore the impact (>1 – 3 years)
Severity Level
Moderate (3)
Impact on physical and mental health
Moderate impact on health and long-term mental impact: illness or injury that requires medical treatment with rehabilitation (loss-time injury)
Impact on other factors (e.g., asset, data privacy, restriction of rights)
May require minor long-term adjustments or affect livelihood by moderately altering the lifestyle from the original (loss opportunity or increased cost due to relocation, change of jobs, any lifestyle changes that restrict the normal quality of life)
Scope (how many people are or will be affected)
Impact on a portion, but less than half, of the rights holders within a specific group (25% ~ <50%)
Remediability (difficulty to restore the people impacted to a situation before impact)
Take more than 6 months to 1 year to restore the impact (>6 months – 1 year)
Severity Level
Minor (2)
Impact on physical and mental health
Minor impact on health and short-term mental impact: illness or injury that requires medical treatment or an order to perform other duties (no lost time)
Impact on other factors (e.g., asset, data privacy, restriction of rights)
May require short-term adjustments or affect livelihood by altering some lifestyle from the original condition (relocation, change of jobs, or any lifestyle changes with no impact on costs, economic status, or quality of life)
Scope (how many people are or will be affected)
Impact on a portion of rights holders within a specific group (<25%)
Remediability (difficulty to restore the people impacted to a situation before impact)
Take 3 to 6 months to restore the impact (3 – 6 months)
Severity Level
Insignificant (1)
Impact on physical and mental health
Minimal or no physical and mental health impact: no illness or injury, or recoverable through first aid.
Impact on other factors (e.g., asset, data privacy, restriction of rights)
Minimal or no impact on livelihood (no impact on relocation, change of jobs, or lifestyle, or some lifestyle changes but no adjustments or reduction of quality of life)
Scope (how many people are or will be affected)
No impact on the relevant rights holders (0%)
Remediability (difficulty to restore the people impacted to a situation before impact)
Able to immediately restore or take less than 3 months to restore the impact (<3 months)
Risk Rating Scale: Likelihood
| Likelihood levels | Characteristics of the likelihood |
|---|---|
| 5 Most Likely (>50%) | Events occur more than once per year |
| 4 Likely (25%) | Events occur once per year |
| 3 Occasional (10-25%) | Events have occurred more than once in the past two years |
| 2 Unlikely (5-10%) | Events have occurred once in the past three years |
| 1 Rarely (<5%) | Events have occurred once or have not occurred for more than three years |
Results from Human Rights Assessment
Percentage of operational sites with human rights risk and controlling approach)
| Percentage of operational sites assessed for human rights risks | Percentage of operational sites identified with human rights risks | Percentage of operational sites with human rights risks that have prevention, mitigation, and remediation processes in place | |
|---|---|---|---|
| GC’s Own Operations | 100 (18 sites) | 16.67 | 100* |
| Tier 1 Suppliers and Contractors | 100 (1,805 companies) | 0.33 | 100** |
| Joint Ventures Without Management Controls*** | 100 (9 sites) | 0 | 0 |
Remark: human rights risk assessment results in 2024.
* 100% of operational sites where risks have been identified (accounts for 18 sites) has controlling approaches to prevent and mitigate human rights risks.
** 100% of Tier 1 suppliers and contractors which risks have been identified (accounts for 0.33 of a total of 1,805 companies) has controlling approaches to prevent and mitigate human rights risks.
*** GC does not have management control of all Joint Ventures
Mitigation Measures
Own Operations and Joint Ventures
Based on the human rights risk assessments conducted at the GC’s operational sites (including all joint venture sites), the company has established the following control and remediation guidelines for human rights risk issues:
Key human rights issues related to GC own’s operations.
Description:
- Impacts on employee health and safety resulting from workplace accidents in the manufacturing.
Mitigation Measures:
- Human rights and safety management mechanisms and grievance channels are in place, such as GCMS, ISO 45001, and IMS.
- Safety culture is promoted through training and initiatives such as Safety Talks, SWO, Zero ICU, and the B-CAREs programme.
- Compensation is provided through life and accident insurance, provident funds, financial support in the event of death or work-related injury, and funeral expense coverage.
Description:
- Health and safety impacts on contractors resulting from workplace accidents in the manufacturing sector.
Mitigation Measures:
- Implement and complied with the Human Rights Policy, Corporate Governance & Business Code of Conduct Handbook, Whistleblowing Policy, and safety management systems such as GCMS, IMS, and BCM.
- Conduct safety training, pre-job inspections, safety talks, and empowered workers with the authority to stop work when unsafe conditions are identified.
- Enhance system separation standards, such as installing backup equipment in case of primary system failure, to improve overall system safety.
Description:
- Improper working conditions that may lead to operational accidents
Mitigation Measures:
- Implement and comply with Environmental Management Systems (ISO 14001) and Occupational Health and Safety Management Systems (TIS 18001 and OHSAS 18001).
- Organize programmes for personal safety risk prevention, field risk assessments, safety walk-throughs, and safety training.
- Ensure the right to effective remedy, fair working conditions, adequate living standards, and the right to health.
- Conduct lighting inspections in accordance with standards, annual light measurements, and maintenance or repair reporting in case of irregularities.
Description:
- Impacts from chemical spills caused by accidents involving chemical transport trucks.
Mitigation Measures:
- Implement and complied with relevant policies and management systems, including the Human Rights Policy, Business Code of Conduct, Environmental Management System (ISO 14001), and Occupational Health and Safety Management Systems (TIS 18001 and OHSAS 18001).
- Conduct safety training for transport service providers, random driver behaviour checks, drug and alcohol testing prior to duty, and install GPS tracking in transport vehicles.
- Ensure effective access to remediation and the right to an adequate standard of living.
- Define clear responsibilities and contractual requirements with transport service providers, including speed control, insurance coverage, safe driving training, and monthly emergency response drills.
Description:
- Chemical truck accidents cause traffic congestion due to road closures, pose hazardous material risks, and require safety response measures. Cleanup and restoration efforts may prolong the impact on infrastructure and the environment.
Mitigation Measures:
- Implement and comply with Incident Management System (IMS), business continuity Business Continuity Management System, and certifications for Environmental Management (ISO 14001) and Occupational Health and Safety (TIS 18001 and OHSAS 18001).
- Adhere to community and environmental responsibility measures, conduct community satisfaction surveys, and manage social responsibility and sustainable development initiatives.
- Ensure effective access to remediation and the right to an adequate standard of living.
- Define responsibilities in contracts with transport service providers, provide safe driving training, perform random behaviour checks on drivers, and install GPS tracking in transport vehicles.
Tier-1 Suppliers and Contractors
GC assesses human rights risks of direct business partners and contractors (Tier-1 Suppliers and Contractors) and establishes control and remediation measures to address identified human rights risks. The controlling approach and mitigation measures include the Safety Network and Sharing Program, Health Check-up and Public Health Surveillance Program, Sustainability Procurement Management Program, the Code of Conduct, and other measures. However, GC also has a Vendor Management Procedure for supplier management and has set measures to prevent and remediate human rights risks arising from suppliers as mentioned in the Supplier Code of Conduct. All suppliers are required to sign the supplier’s acknowledgement of the Supplier Code of Conduct and strictly adhere to it.
Vendor Management Procedure
Mitigation measures:
- Establish human rights and labour practices covering respect for rights, compliance with laws, prohibition of forced and child labour, non-discrimination and harassment, provision of a suitable working environment, and respect for freedom of association and collective bargaining.
- Promote efficient resource use, compliance with environmental laws, waste management, air and water pollution control, biodiversity conservation, and workplace health and safety.
- Collect and communicat the Company’s policies, standards, and business principles for suppliers and contractors to acknowledge and comply with.
- Systematically select and evaluat suppliers by assessing risks and performance, while encouraging responsible business practices aligned with ESG principles under the Supplier Code of Conduct.
- Cover operations both inside and outside the organisation, including suppliers and contractors, focusing on risk management, accident prevention, occupational disease control, asset protection, and environmental contingency planning.
- Strictly govern supplier management processes with registration criteria, human rights risk assessments, and continuous monitoring to prevent and mitigate potential risks arising from suppliers.