Human Rights Risk Assessment
GC has conducted Human Rights Risk Assessment (HRRA) within GC group since 2015 to identify, prevent and mitigate any human rights risks throughout the value chain due to the business operations. These risk assessments cover the different activities at country level, industries 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 supplier.
Moreover, GC conducts HRRA annually 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 which may occur as well as assessed the residual risks after established preventive and correction actions regarding human rights for its business operation. This is to ensure that the human rights management approach is effective for controlling the impacts throughout the value chain.
Risk Assessment Evaluation Criteria: Impacts
The human rights impact depends on its scale, scope, and limits on the ability to restore those affected to a situation at least the same as their situation before the adverse impact.
Impact Level
4 Extreme
Description of Impacts
- Human rights impacts affect a larger scale or targeted at particular population groups beyond the scope of the operational areas
- Operation is unable to control or remediate human rights impacts to restore the ability of an individual on human rights
- Impacts/situations of human rights abuses require the involvement of independent and trusted organizations to rectify the issues
Impact Level
3 High
Description of Impacts
- Operation is knowingly providing practical assistance or encouragement that has a substantial effect on the commission of human rights violation (Legal Complicity)
- Human rights are violated at the individual level by the operation and value chains
- Operation has disputes over human rights related concerns with vulnerable groups
Impact Level
2 Medium
Description of Impacts
- Operation is seen to benefit from abuses committed by other (Non-legal Complicity)
- Business fails to provide response to or communication on the human rights related concerns raised by internal or external groups
Impact Level
1 Low
Description of Impacts
- Potential impacts of human rights related concerns raised by internal or external groups are prevented by the operational level and our grievance mechanism.
Risk Rating Scale: Likelihood
| Likelihood Level | Description of Likelihood |
|---|---|
| 4 Likely (>25%) | The event has occurred in the operation several times per year |
| 3 Possible (10-25%) | The event occurred in the operation several times |
| 2 Unlikely (1-10%) | The event rarely occurs in the operation, but possible to occur |
| 1 Rare (<1%) | The event occurred several times in the industry of the operation but unlikely to happen in the operation |
Results from Human Rights Risk Assessment
GC’s operating areas (including Joint Ventures)
Tier 1 Feedstock Suppliers
Tier 1 Non-Feedstock Suppliers
Relevant Risks
| Labor Rights | Community Rights | Supply Chain | Security Management | Environment | Consumer Rights |
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Percentage of operational sites with human rights risk and controlling approach
| Percentage of total operational sites where have been assessed human rights risks | Percentage of total operational sites where risks have been identified | Percentage of operational sites where have human rights risks with mitigation actions taken | |
|---|---|---|---|
| GC’s operational sites (including all Joint Ventures*) | 100 (25 sites) | 88 | 100** |
| Tier 1 feedstock and non-feedstock suppliers | 100 (1,898 companies) | 99.68 | 100*** |
* GC has management control of all Joint Ventures
** 100% of operational sites where risks have been identified (accounts for 22 sites) has controlling approaches to prevent and mitigate human rights risks.
*** 100% of Tier 1 suppliers which risks have been identified (accounts for 1,892 companies) has controlling approaches to prevent and mitigate human rights risks.
The key Human Rights issues related associated to GC’s operations
The results of human rights risk assessment in operational sites (including all joint ventures) indicated that the residual risk level of the operational sites are at a medium to high level. The company thus set up a controlling approach and remedy the issues with residual human rights risk as follows:
Vehicle Accident in the Operational Areas
Description:
- Impacts on health & safety of employees and contractors from vehicle accident in the operation area.
Mitigation Measures:
- Assess traffic risk points and apply preventive measures for all operation sites.
- Organize traffic by arranging warning points on the turn and intersection, and allocate security personnel to provide signal at the risk areas
- Provide Safety Training and activities to build Safety culture (B-CAREs)
Turnaround Issue
Description:
- Noise, odors, smoke, dust, light and vibration impacts as a result of turnaround activities in GC’s operating sites
Mitigation Measures:
- Comply with environmental mitigation and monitoring measures in Environmental Impact Assessment (EIA) report
- Operate Turnaround/Shutdown activities under Quality, Security, Safety, Occupational Health, Environment, and Business Continuity Policy (QSHEB Policy)
- Implement Environmental Management System (EMS) across supply chain
- Communicate turnaround/shutdown plan and communication channels to communities
- Prepare emergency management center for 24 hours
- Investigate all received cases through whistleblower and communication channels
Wastewater Pollution at Map ta Phut Area
Description:
- Accusation from Local communities at Map Ta Put area on wastewater pollution.
Mitigation Measures:
- Deploy and comply with environmental policies and plans, namely QSHEB policy and sustainable water management policy, to ensure the environmental performance
- Monitor water discharges covering 100% of operations daily through online monitoring to maintain water quality based on requirements of local regulations and law enforcement, such as National Environmental Quality Act and IEAT’s Wastewater Discharge Requirement
- Develop robust spill management procedures (applicable across all our plants)
- Investigate all received cases through whistleblower channel
- Conduct community satisfaction survey
Direct or Indirect Way of Illegal Forms of Labor
Description:
- Direct or indirect complicity if suppliers use child labor, forced labor, illegal migrant labor and other forms of illegal labor
Mitigation Measures:
- Deployment and acknowledgement of Supplier Code of Conduct to all 1st tier critical suppliers and contractors
- Conduct the ESG supplier audit on a regular basis
- monitors supplier performance through self-assessment
- Conduct supply chain management system which covers supplier selection and monitoring, and suppliers’ performance evaluation.
- Communicate with suppliers at the operational level about expected performance that meet the company’s standard, for example, compliance good governance guidelines, ILO convention on labor rights, etc.
- Communicate the potential impacts from human rights implementation, in order to promote understanding among business partners through the annual Supplier Conference
- Evaluate problems with a supplier's products or services and find precaution through Vendor Criticism
- Investigate all received cases through whistleblower channel
Supplier Discrimination in Non-Feedstock Suppliers
Description:
- Potential on discrimination against suppliers in screening and retaining processes due to business scale, nationality, political issues, etc.
Mitigation Measures:
- Corporate Governance and Business Code of Conduct
- Conduct Supplier survey
- Investigate all received cases through whistleblower channel
Oil Spill Issue
Description:
- On July 27th, 2013, about 50,000 liters of crude oil leaked in to the sea and subsequently led to environmental impact on biodiversity and degradation.
Mitigation Measures:
Immediate-term solution
- Collecting the oil slick within 7 days after the incident
- Remedy for affecting groups
Long-Term Solution
- Established a long-term economic, social and environmental recovery
- Review all related procedures and practices, including oil unloading procedure, e.g. do not execute oil unload when the wave is higher than 2.5 meters.
- Inspect all equipment prior to use at more rigorous manner
- Consider more appropriate technology, and procure equipment, chemicals and tug boats suitable for oil slick removal in case of emergency
Customer’s Data Leakage
Description:
- Customer data leakage violates customer rights to privacy and harmful impact
Mitigation Measures:
- Aligned with ISO 27001 and National Institute of standards and Technology (NIST)
- Data management and cyber security
- Cybersecurity protection measure
- Customer satisfaction survey
- Customer complaint management
- Customer relationship management system
- Investigate all received cases through whistleblower channel
Moreover, the result of human rights risks assessment in the Tier 1 feedstock and non-feedstock suppliers shows that suppliers have human rights risk issues, including working condition, employee’s health and safety, community’s health and safety, and impacts of pollution and waste management. The suppliers have controlling approach and mitigation measures such as 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 Vendor Management Procedure for supplier management and set measures to prevent and remediate human rights risks that happen from suppliers which mentioned in the Supplier Code of Conduct. All suppliers are required to sign the supplier’s acknowledgement of Supplier Code of Conduct and strictly adhere to it.
Vendor Management Procedure
Mitigation measures:
- SCoC Acknowledgement signing
- Supplier Performance Monitoring and Evaluation through Vendor Criticism Form, Yearly Vendor’s Performance Evaluation Form and Supplier Environmental, Social and Governance (ESG) Audit
- Supplier self-assessment