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 at 12 operational sites in eight countries
operational sites
countries
which are Thailand, Malaysia, New Zealand, Australia, United States, Germany, France, England and Poland, in which the company operates.
Moreover, GC has conducted HRRA for business partners and joint ventures that the company does not have management control to establish effective management practices for the operational areas at risk. Additionally, GC has identified human rights related issues and assessed impact on risky groups or vulnerable groups such as children, indigenous groups, foreign labor or 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 where GC has management control)
- Health, safety and welfare of employees and contractors in operating areas.
- Impact of environmental pollution
- Health and safety of communities
- Living standard and quality of life for local communities
Critical Tier 1 Feedstock Suppliers
- Employment in the supply chain, such as consideration of human rights issues
- Environmental, Health and Safety Management
- Stakeholder engagement
Critical Tier 1 Non-Feedstock Suppliers
- Employment in the supply chain, such as consideration of human rights issues
- Environmental, health and safety management
- Stakeholder engagement
Joint Ventures where GC does not have management control
- Employment guidelines
- Environmental, health and safety management
Percentage of operating areas with human rights risk and controlling approach
| Percentage of operation areas which have been assessed human rights risks | Percentage of operation areas which found human rights related risks | Percentage of operation areas which have human rights risks and have controlling approach | Controlling Approach | |
|---|---|---|---|---|
| GC’s operating areas (including joint ventures where GC has management control) | 100 | 95 | 100 | Operate according to GC’s management approach e.g Environmental, Occupational Health and Safety Manual for joint ventures, and corporate governance guidelines, etc. |
| Critical Tier 1 Feedstock Suppliers | 100 | 100 | 100 | Operate according to GC’s management approach e.g. Environmental, Health and Safety Management System and Sustainability Management Framework, etc. |
| Critical Tier 1 Non-feedstock Suppliers | 100 | 80 | 100 | Operate according to GC’s supplier management approach e.g. Environmental, Health and Safety Management System |
| Joint Ventures where GC does not have management control | - | - | - | No joint venture in GC management control |
The key Human Rights issues related associated to GC’s operations
The results of human rights risk assessment indicated that the residual risk level of the communities’ rights are at a low to moderate level whilst minority and indigenous groups were not affected by the company’s operations. The company thus set up a controlling approach and remedy the issues with residual human rights risk as follows
Description:
- Noise, smell, pollution, dust, light and vibrations that may occur from turnaround activities.
- Turnaround of GC’s 18 factories located in the Mabtaput Industrial Estate
Controlling Approach:
- Turnaround Optimization (Periodic activities).
- Establish communication channels to inform local communities about the turnaround activities.
Description:
- Impacts on health and way of life of people in the communities, employees and external agencies e.g. firefighters etc.
Controlling Approach:
Immediate-term Solution
- Remedy for effected groups
Long-term Solution
- Establish a long-term economic, social and environmental recovery plan
- Strictly inspect all equipment prior to using
- Install an alarm system
- Conduct risk assessment throughout operation process to develop measures to ensure safety in process and communicate with all stakeholders to clarify the procedure and all risks.
- Consider the use of appropriate technologies, and procure equipment, chemicals and Tug Boat for cleaning oil stains in an emergency situation
Description:
- Potential risks associated with environmentally friendly products, which made from palm oil, corn, sugarcane and cassava.
- The company could be directly or indirectly related with feedstock suppliers who use child labor, forced labor and other forms of illegal employment.
Controlling Approach:
- Operate according to the supplier risk management system which covers supplier selection, supervision, capability determination, monitoring and evaluation of suppliers’ performance.
- Inform suppliers at the operational level and operate in respond to the operational governance which is in compliance with the company’s rules and standards, as well as International Labor Organization (ILO) regarding labor rights.
- Conduct Annual Supplier Conference, allowing all suppliers to understand GC’s requirements and put them into practice.
- Conduct Environmental, Social and Governance (ESG) Assessment to its First Tier supplier to ensure that there are no issues, along with established a controlling approach. Moreover, the suppliers could also conduct an ESG assessment on GC as well.
Description:
- Contractors may not have sufficient knowledge about using appropriate equipment which may cause accidents while operating.
Controlling Approach:
- Operate according to the supplier risk management systems which cover the process of selecting suppliers, governance and setting the capabilities required for operation, monitoring and assessing.
- Organize safety training for contractors.
- Integrate safety standards and management systems as one of selection criteria for suppliers.
- Assess contractors’ safety and organize workshop on contractors’ safety management to strengthen the system and culture of safety, and monitor the result quarterly.
Description:
- Negative impacts on the environment and communities if the company does not have a suitable environmental management system.
Controlling Approach:
- Implement preventive and corrective measures in accordance with legal standards. This covers waste management, reduction of GHG emissions and water management.
- Monitor and review emissions of all types of pollutions generated from the company’s operation.
- Conduct regular assessment on the waste management and establish a response plan for an emergency situation relating to waste management.
- Constantly develop environmentally-friendly innovations, such as bio-filler installation.
- Operate projects which encourage the rights and quality of life of local community around the factory areas e.g. Water management project for community to have an access to drinking and clean water.
Description:
- On 27th July 2013, 50,000 liters of crude oil leaked into the sea and subsequently environmental impact on biodiversity and environmental degradation.
Controlling Approach:
Immediate Solution
- Clean up the oil slick within seven days of the accident.
- Remedy for affected groups
Long-Term Solution
- Establish a long-term economic, social and environment recovery plan.
- Review all related procedure and risky operation such as prohibiting execute oil unloading when the wave is higher than 2.5 meters.
- Strictly monitor equipment prior to using.
- Consider the use of appropriate technologies, equipment and chemicals including Tug Boat, which is used for cleaning oil slick in an emergency situation.
- Improve the incident management system to rapidly respond to the incident.
- Review emergency plan and conduct the drill regularly
