Human Rights Management

Human Rights Management

Opportunities and Challenges

The passage of laws and the development rules, regulations, and guidelines related to business and human rights have gained significant traction over the past several years. This reflects increased expectations from government and civil society for the business sector to operate in ways that seriously respect human rights. In 2019, the Thai government announced its first National Action Plan on Business and Human Rights (NAP), making Thailand the first country in Asia to make actual progress on business and human rights. Important challenges confronting Thailand which are also relevant to operations of the PTT Group include labor rights; awareness on the UN Guiding Principles on Business and Human Rights (UNGP) among state enterprises; impacts to and consultation with communities in areas with large-investment development projects, especially in special economic zones (SEZs); government procurement and hiring practices; and access to remediation. Hence, the PTT Group is committed to respecting human rights in all operating activities in order to avoid rights violations of stakeholders.

Human Rights Management Approach

Commitment

PTT is mindful of human rights' importance to corporate sustainability. PTT has therefore laid down the foundation to ensure respecting human rights as PTT's fundamental practice, while upholding human rights principles as stipulated by the laws and international standards. This comprises the United Nations Universal Declaration of Human Rights (UNUDHR), the United Nations Guiding Principles on Business and Human Rights (UNGP), and the International Labour Organization (ILO). In conjunction, PTT has also joined in as part of the United Nations Global Compact (UNGC) and the Global Compact Network Thailand (GCNT). Additionally, PTT is also active in providing information to public sector, which supports the drafting of National Action Plan on Business and Human Rights (NAP) and the 4th National Human Rights Plan.

Therefore, PTT has adhered and respected to human rights principles in line with PTT Human Rights Statement and PTT Compliance Policy, and established Human Rights Issues as a part of the Group's Sustainability Management Policy and Framework. PTT has encouraged other companies in the group to apply and operate in line with the management framework, which requires disclosures of risk assessment and risk mitigation plan for transparency.

Building Corporate Culture in Human Rights

Roles and Responsibilities of the Board and Directors

Regarding the Group's Human Rights performance, PTT's Board of Directors has assigned Corporate Governance Committee to oversee PTT Group's Sustainability Management and Policy, which covers human rights management throughout PTT Group's supply chain. This is overseen by Organization Management and Sustainability Function, comprises Senior Executive Vice President and Executive Vice President for Sustainability Management. Furthermore, Corporate Management Department is assigned to manage performance in line with the Group's Human Rights Management System. This includes communicating policies to responsible functions, whose duty is to ensure effective compliance to human rights management approach across PTT. The Subject Matter Experts (SMEs) working group for human rights-related issues include the following functions: Human resource, Security, safety, health & environment (SSHE), Corporate social responsibility, Procurement, and Compliance. Performance is reported to Corporate Governance Committee quarterly. 

Furthermore, Corporate Governance Committee closely monitors progresses and provided recommendations on operational plans, annual targets, results of human rights risks assessment, and risk management plan. The committee has approved the review of PTT Group Human Rights Management System. The Management System’s addition includes guidelines for corporate governance, compliance, and assessment of human rights impacts towards stakeholders. Also, PTT Board has monitored sustainability performance which is significant and may affect human rights, such as Climate Change management issues, Safety, and Anti-corruption.

Building Corporate Culture in Human Rights

Communication and Training

To foster understandings in business and human rights, PTT continues to raise awareness to all employees through internal journal articles, magazines and public relations emails. The content is drafted to ensure reader's ease in comprehension and cover contents about human rights statement/policy, approaches, management systems and case studies from various businesses. PTT also conducted PTT Group's Sustainability Management and PTT Integrated Management System (PIMS) training courses for related employees at all levels. The content covers human rights performances in business sector, as well as best practices in business operations with respects to human rights. The trainings commenced in 2014. As of now, the training has been conducted with 46 cohorts. Additionally, PTT has conducted an online course about PTT’s governance and compliance policy to encourage employees’ knowledge of ethical operations, anti-corruption, and human rights in operations. This course is required for all employees and determined as performance indicators of function- and division- managers onwards. In 2020, PTT started to share lessons learned on business and human rights through podcasts in order to increase communication channels with employers at all levels.

Additionally, PTT conducted an academic seminar titled 'Business and Human Rights' for executives and employees in relevant functions including Compliance, Corporate Reputation and Social Responsibility Planning, Strategic Procurement, Land Acquisition, Security and Safety, Customer Relationships Management, and Corporate Communications. The seminar's content covers overview of international human rights management, the government's directions, and how human rights issues can be cascaded from the businesses to state enterprises.

For training of security officers, PTT stipulated that the security companies must provide necessary trainings to the security officers in line with the company's Term of References. Emphasis is placed on human rights issues, such as raising awareness that security and safety are basic human rights for all, avoiding the use of violence against others, including against offenders. Moreover, security officers do not have the authority to make arrests, unless the offenders committed the offense on PTT's property. The accused are presumed innocent until proved guilty. In 2020, no human rights-related grievance was reported about PTT’s security officers.

Business Partners throughout the Supply Chain

PTT supports and encourages PTT's business partners to operate with consideration and respect to human rights, and in compliance with PTT's Human Rights Guideline. This starts from supplier screening, both existing contracts and new ones, in accordance to Environment, Social and Governance (ESG) criteria, in addition to fundamental criteria of quality and finance. Suppliers whose score did not reach established standards will not be allowed to be part of vendor list.

Additionally, PTT adopted the Supplier Sustainable Code of Conduct which covers issues on environment, labor rights, business ethics, etc. The Code of Conduct is enforced on suppliers with the contract values at over 2 million baht, and/or whose work affects safety and environment. This includes vendors who wish to register as suppliers with PTT. There are also performance monitoring through suppliers’ monitoring and assessment plan since 2016, especially for critical suppliers and high risk suppliers. If violation of Supplier Sustainable Code of Conduct is found, the improvement plan has to be approached. PTT has the right to terminate the contract if those violations are still found.

Human Rights Due Diligence

PTT Group's Human Rights Management

In 2016, PTT has set up PTT Group Human Rights Management System to serve as a guideline for management of human rights issues related to PTT Group's business operations. It also supports PTT Group's efforts in applying the necessary human rights management processes that covers all of PTT Group's activities which may incur human rights impacts throughout the operation cycle. These activities include merger and acquisition, construction, and decommission. PTT has announced its adoption of the system, and communicated to companies within PTT Group accordingly to ensure appropriate deployment of the system.

  

PTT Group's Human Rights Management

Human Rights Risk and Impact Assessment^GRI412-1

PTT Group’s Human Rights risks have been included as part of the enterprise risk management, and are under the responsibility of functional level management. Today, relevant units at functional level are managing human rights risks effectively through a risks management plan and reporting to relevant committees.  This comprehensive management approach resulted in zero human rights complaints. However, in case of high impacts and severity, PTT will consider management of human rights risks at a higher level, including business unit & support functional level and corporate level, respectively.

The risk assessment process covers identification of key issues, impacts on stakeholders, including employees, third-party contracted labour, local communities, vulnerable groups, and the likelihood of impacts at the national-level of operations, within PTT’s own operations, value chain and new business relations. The objective behind this risk assessment is to consolidate corporate human rights risk reports, in conjunction with project-level human right risks reports. PTT assesses human right issues and risk level every three years, or frequent as needed. The latter case includes when there are sudden changes in human rights risks, business activities, operating guideline/standards. This ensures all relevant risks have been assessed thoroughly, and ascertained in effectiveness of control measures and management system.

The process of human rights risk and impact assessment is as follows.

Human right risk and impact are assessed on two factors: impacts and likelihood

Risk Rating Scale: Impacts

Human rights impact is composed of many variables, including size, scope, and capacity limitations in reverting negative impacts.

Risk Rating Scale: Likelihood 

Human rights impact is composed of many variables, including size, scope, and capacity limitations in reverting negative impacts.

Rights Holders and Vulnerable Group

PTT addresses the following groups of rights holders during the due diligence process: employees, suppliers, contractors, business partners, local communities, customers/consumers, and vulnerable groups (migrant labor, women, indigenous people, LBGTQI, people with disabilities, underprivileged people and children).

PTT has assessed human rights risk since 2015. The assessment covered 100% of PTT’s core business operation area, including the Natural Gas Business and International Trading Business. In 2019, the scope of PTT Group’s human rights due diligence has also been adjusted to fit PTT Group Way of Conduct. There are 16 subsidiaries operating in compliance with PTT Group Human Rights Management System, altogether including 50 areas across 21 countries consisting of the Petroleum Exploration and Production Business, Petrochemical and Refining Business, Oil and Retail Business, Coal Business, Electric Utilities Business and Technology and Engineering Business.

Key human rights risks identified in PTT Group’s business operations consisted of occupational health and safety, migrant workers, human rights in supply chain (child/forced labor) and community’s quality of life. Sites with high human rights risks must prepare risk mitigation plans. However, PTT Group’s human rights risk level, per 2021 risk assessment, remains in the range of low to moderate. Such low and moderate risk assessment result is due to development of human rights management plan and utilization of control measures suitable for each area. There is quarterly monitoring on the operations to ensure risks remain within risk appetite. The monitoring also ascertains that control measures execute with maximum efficiency.

PTT identifies stakeholder groups who are potentially affected by its operations through stakeholders’ need assessment via engagement channels such as meeting, grievance centres, and survey and recommendation forms. For balanced management, the needs will be prioritized by the importance to the company and stakeholders. In 2020, the result of assessment showed the issues with high risk on human rights management, consisting of Climate Change (environmental and community rights), application of a circular economy approach (environmental rights and customers and consumer rights), and value creation for society (community rights).

Grievance Management and Remediation

Grievance Management^GRI411-1

PTT has developed grievance mechanism to receive complaints through internal and external channels in Thai and English, in order to ensure accessibility of all stakeholders and ensure the process that addresses all kinds of grievances, which also include human rights grievances, as well as the potentially affected stakeholders’ concerns and recommendations. For PTT’s subsidiaries in other countries, local websites and social media channels in local languages are available for contacting the company.

PTT is cognizant of the significance of whistleblower protection. PTT has an established procedure on whistleblower protection, including protection measures and fair process. The procedures and measures also cover witness and individuals who provide information or evidence. The company also sets up reasonable timeline for complaint management. For each step along the process, complaints received from employee must be manage within 30 days, while complaints received from external complainants must be investigated, resolved, and notified to complainants of its resolution and progresses within 7 working days. In 2020, there was no complaints incurred from human rights violations, nor non-compliance practices against human rights laws. Therefore, no remediation actions were taken in 2020.

Remediation

PTT prioritizes protection and remediation procedures for all individuals affected from its operations. The company provides channels to receive complaints particularly in crisis and emergencies in all areas of operations, set the process for expedient access to remedy, both as financial remedies (compensation, financial supports), and non-financial remedies. Non-financial remedies may include establishing emergency point to receive grievances and complaints to provide initial remediation, providing advices or recommendation supports from specialist, as well as providing communication channel to listen to concerns and complaints from stakeholders.

PTT has open channels for all affected individuals to report their complaints at the complaint mechanism of each project, or through PTT call center. For each complaint received, PTT will analyze the causes, find solution, and identify prevention measures. In case that the prevention and remediation processes cannot accommodate initial solution, PTT will designate the mechanism on prevention and remediation through grievance mechanism in the form of a tripartite taskforce. The taskforce consists of representatives from stakeholders including representative from local administration bodies, community leaders and relevant government agencies. This is to ensure that the case is properly and effectively managed, for the satisfaction of all parties.