Sustainability

Human Rights Management

Sustainability

Human Rights Management

Sustainable Development Goals
   





Human Rights Impacts of PTT Operations

PTT has been actively developing and implementing a human rights management system alongside its sustainable management initiatives since 2015. This includes conducting Human Rights Due Diligence, which encompasses the entire business operations of PTT and its subsidiaries under the PTT Group Way of Conduct throughout supply chain. The most recent assessment in 2023 identified several significant risks, notably in the areas of safety and occupational health for employees and contractors, labor rights, working conditions of suppliers, community welfare, and indigenous rights. These assessment findings have been integrated into PTT's sustainability materiality assessment. This comprehensive assessment covers all dimensions of economic, environmental, and social impacts, aligning with the Global Reporting Initiative (GRI) Sustainability Reporting Standard 2021: GRI 3: Material Topics 2021.

Management Approach

PTT Human Rights Policy

PTT acknowledges the paramount importance of human rights issues in ensuring the organization's long-term sustainability. As such, it has laid down a foundational commitment to uphold human rights as a core practice within PTT. The Company adheres steadfastly to principles of human rights as delineated by both legal statutes and internationally recognized standards. These include the United Nations Universal Declaration of Human Rights (UDHR), the United Nations Guiding Principles on Business and Human Rights (UNGP), and The ILO Declaration on Fundamental Principles and Rights at Workestablished by the International Labour Organization (ILO), etc. PTT demonstrates its unwavering dedication to conducting business with due respect for human rights by articulating its commitment explicitly in the PTT Human Rights Statement. This declaration bears the signature of the Chief Executive Officer and President, underscoring the Company's resolve to prevent, manage, and mitigate the risks of human rights infringements across its operations. This commitment extends particularly to key stakeholders such as employees, local communities, and business partners, and their employees. Furthermore, PTT places a strong emphasis on enforcing Furthermore, it also demonstrates its commitment in the policy of regulating and ensuring compliance with laws, rules and regulations of PTT Public Company Limited. 

Structure of governance, roles, and responsibilities of committees and management in human rights management

In the pursuit of human rights initiatives, which have been integrated into the organization's sustainability management framework, the Board of Directors of PTT has entrusted the Corporate Governance and Sustainability Committee (CGSC) as one of the sub-committees under the PTT Board of Directors ,with the responsibility of overseeing policies and ensuring the sustainability of the PTT Group. This encompasses the management of human rights across PTT's supply chain, involving qualified and experienced committee members well-versed in managing human rights impacts across diverse domains as follows:

Mr.Chatchai Phromlert Chairman/ Independent Director Educations
  • Bachelor of Arts (Political Science), Chulalongkorn University
  • Master of Public Administration, Chulalongkorn University
Work Experiences
  • March 9, 2023
    Chairman, Anti-Money Lundering Office (AMLO)
  • March 22, 2023
    Expert, Office of the Police Commission
  • October 1, 2017
    Permanent Secretary, Ministry of Interior
  • Past   Chairman, Metropolitan Electricity Authority
  • Past   Chairman, Provincial Waterworks Authority
  • Past   Chairman, Provincial Electricity Authority
Mrs.Phongsaward Neelayodhin Independent Director/Chairman of the Enterprise Risk Management Committee​ Educations
  • Bachelor of Laws Program, Thammasat University
Work Experiences
  • 2022 - Present   Permanent Secretary, The Ministry of Justice
  • Acting Director of Strategic Transformation Office (STO)
  • Deputy Secretary-General, Office of the Council of State
  • Permanent Law Councillor, Office of the Council of State
  • Honorary Member of National Savings Fund
  • Member of the Committee on Legislative Drafting and Subordinate Legislation Proposed to the Cabinet Panel 3
  • Member of the Committee on Jurisdiction over Positions
  • Honorary Member of the Buddhist Scripture Education Committee
  • Director of Transport Law Section
  • Director of Political and Public Administration Law Section
  • Director of Administrative Law Bureau
  • House of Representatives Liaison Officer
  • Cabinet and Parliamentary Liaison Officer, Office of the Council of State
Associate Professor Dr.Narongdech Srukhosit Independent Director/Member of the Audit Committee Educations
  • Bachelor of Law (First Class Honors), Chulalongkorn University
  • LL.M., University of Cambridge , UK.
  • Ph.D. (Law), University of Edinburgh, UK.
Work Experiences
  • 2001 - Present
    Tenured Lecturer, Faculty of Law, Chulalongkorn University
Mr.Wattanapong Kurovat Director/Member of the Enterprise Risk Management Committee Educations
  • Master of Business Administration (MBA), Western Michigan University, USA
  • Bachelor of Political Science, Thammasat University
Work Experiences
  • 2023 - Present
    Director General, Department of Alternative Energy Development and Efficiency,
    Ministry Of Energy
  • 2021- 2023
    Director/ Member of the Corporate Governance and Sustainable Development Committee,
    PTT Exploration and Production Public Company Limited
  • April 2021
    Director/ Member of the Nomination and Remuneration Committee,
    IRPC Public Company Limited
  • 2019 - March 2021
    Director/ Member of the Risk Management Committee, IRPC Public Company Limited
  • 2019 - 2023
    Director General, Energy Policy and Planning Office
  • 2018 - 2019
    Deputy Director General, Energy Policy and Planning Office
  • 2015 - 2018
    Director, Power Policy Bureau, Energy Policy and Planning Officed
Mr.Jatuporn Buruspat Independent Director/Chairman of the Corporate Governance and Sustainability Committee Educations
  • Bachelor of Arts in Political Science, Chulalongkorn University
  • Master of Arts in Political Science, Chulalongkorn University
  • Master of Science (Forest Resource and Environment Administration),
    Kasetsart University
  • Honorary Doctorate Degree of Philosophy in Environmental Technology and Management,
    Kasetsart University
  • Honorary Doctorate Degree of Philosophy in Political Science,
    Mahachulalongkornrajavidyalaya University
Work Experiences
  • 2019 - Present
    Permanent Secretary, Ministry of Natural Resources and Environment
  • 2017 - 2019
    Director-General, Department of Marine and Coastal Resources,
    Ministry of Natural Resources and Environment
  • August 11, 2015 - January 7, 2021
    Independent Director, TOT Public Company Limited

Performance incentives for the Board of Directors are comprehensively assessed, encompassing environmental, social, governance as well as human rights considerations, aligning with the State Enterprise Assessment and Management (SE-AM) framework. PTT has instituted a policy for fair and equitable compensation for board members (further details can be found in Section 2 of the 56-1 One Report under Corporate Governance, specifically in the "Board Compensation Policy of PTT" section, and on the Company's website under the Corporate Governance section).

At the managerial level, the Governance Risk and Compliance Management Committee (GRCMC) oversees risk management and legal compliance. Assistant to the Managing Director for Sustainable Governance manages sustainability under the Executive Vice President, Sustainability Management with the Sustainability Strategy Division developing processes and supervises sustainability and human rights management for both PTT and its subsidiaries. These initiatives are efficiently disseminated across all corporate functions to ensure organizational-wide efficiency and effectiveness.



Corporate Governance and Sustainability Committee (CGSC) convene quarterly to review efficiency and effectiveness to  track progress and offer insights on long-term/yearly objectives, assess performance regarding material topics, and human rights risks, operating plans and risk management plans. Previously the Corporate Governance and Sustainability Committee (CGSC) has provided recommendations for continuous improvement of the human rights management system/process, including progress reports to the PTT Board of Directors. Also

Human Rights Awards 2022


PTT’s Human Rights Management Process 

The PTT Group Human Rights Management System was developed in 2015 and formalized as the PTT Group Human Rights Management Guideline. It serves as the framework for managing human rights issues related to the PTT Group's business operations. This guideline encompasses all activities that could potentially affect human rights across all value chain.

PTT Group drives companies within its umbrella to adopt and adhere to the Human Rights Management Guidelines outlined in the PTT Group Way of Conduct. This entails necessitating the disclosure of risk assessments, along with corresponding risk mitigation plans, in alignment with the sustainability governance framework on a quarterly basis. Additionally, companies are  reported  their progress back to PTT for board presentation purposes.


Presently, PTT has integrated its human rights management system into the organization's sustainability management process in a systematic manner. This involves identifying human rights issues and risks through comprehensive Human Rights Due Diligence, which is one perspective considered in assessing the organization's material topics.. The impacts of human rights within each material topic are then conveyed to ethical practices through PTT's Sustainability Management Framework for 2021-2025, with annual and long-term goals set for completion by 2030. The aim is to achieve zero human rights violations by 2030. Strategies, plans, and performance indicators are established and disseminated as part of the government enterprise performance evaluation system at both organizational and departmental levels. Progress reports on achieving goals and plans are submitted to the committees quarterly according to the sustainability governance structure as follow:

Human rights performance indicators and significant impact/risk issues 

Indicators

Scope of Evaluation 

Weight (%)

  • Indicators and targets (Lagging KPI) measure the effectiveness of human rights management.
  • human rights violations = 0
PTT's Sustainability Management Framework for 2021-2025 -
  • Indicators and targets according to (Lagging KPI) compliance with laws and PTT regulations (Non-compliance).
  • Non Compliance covers actions that are serious disciplinary offenses. This includes violations of human rights in various areas.
  • Measure the performance of every executive. From the level of Chief Operating Officer to all Senior Executive Vice President.
5
  • Climate change management affects the right to access a clean, healthy, and sustainable environment.
  • State Enterprise Assessment Model (SE-AM): GHG emission intensity (Scopes 1, 2 and 3).
  • Corporate KPIs/ Functional KPIs: Amount of GHG emissions in Scopes 1 and 2.
  • As part of the performance indicators of the Chief Executive Officer and President of PTT, who also response as a member of the PTT Board of Directors.
  • These metrics gauge the performance of the Chief Operations Officers, Senior Executive Vice President., and relevant departments.
5
  • Occupational health and safety impact basic labor rights to the safe work environment of employees and contractors 
  • Master Plan KPIs and Corporate KPIs/Functional KPIs: Safety management effectiveness of employees and contractors. It consists of indicators. Total Recordable Injuries Rate, Lost Time Accidents, and Process Safety Events Tier 1
Evaluate the performance of all executives, starting from the Chief Operations Officers and Senior Executive Vice President to those lower. 5


Human Rights Due DiligenceGRI 407-1, GRI 408-1, GRI 409-1

Currently, PTT is acutely aware of the paramount importance of both promoting and adhering to Principles, Declarations, International Covenants, Conventions, Laws and Standards/Guidelines regarding human rights. This dedication ensures the sustainability of the Company's operations to minimize impact and risk to stakeholders.. There is a steadfast commitment to identify, manage and conduct devising measures aimed at preventing human rights violations for all stakeholders, including employees, business partners (such as contractors, suppliers, and goods and service providers), customers, and local communities comprehensively and systematically

The identification and assessment of risks related to human rights violations have been seamlessly integrated into various stages of the Company's business operations. This includes conducting Due Diligence during mergers or acquisitions and analyzing and assessing the results of Environmental Impact Assessments (EIAs) for large-scale construction projects as mandated by law. These processes provide opportunities for stakeholders affected by human rights impacts to participate in evaluating the effectiveness of mitigation measures through environmental indicators. Additionally, hazards and risks related to safety and occupational health are regularly evaluated in accordance with ISO standards across all operational areas. Moreover, internal control processes are in place across all organizational units, ensuring that all risks are managed through well-defined measures and appropriate management plans. Progress reports are consistently provided to management in each responsible department for oversight and further action.

For Human Rights Due Diligence (HRDD) in line with international standards, including the United Nations Guiding Principles on Business and Human Rights (UNGPs), PTT has instituted a plan to regularly review and enhance the HRDD process every two years or in response to significant events that impact risk or have substantial consequences Such as investing/expanding a new business in a new area icountry or with high human rights risks.

The primary objective of the comprehensive HRDD process is to identify and evaluate current and potential human rights issues across the entire value chain, encompassing the activities of PTT and its business partners, contractors, suppliers, and service providers. The key aim of identifying and assessing human rights issues is to proactively mitigate risks by implementing measures to address impacts and effectively manage the risk of human rights violations. The process involves the following steps:

1. Defining the Group’s business scope.

2. Defining the context of human rights.

3. Identifying/assessing human rights issues at the operational level and related rights at the individual level.

4. Risk assessment.

5. Identifying controls and mitigating risks.

6. Evaluating residual risks.

7. Monitoring and reviewing.


Process of assessing human rights risks

PTT has undertaken a Human Rights Risk Assessment (HRRA) as an integral part of its comprehensive Human Rights Due Diligence (HRDD) process, aiming to scrutinize human rights issues pertinent to the company's business conduct and activities across its entire value chain including

PTT subsidiary 's operations throughout all  value chain (100%).

The HRRA process involves scrutinizing and managing existing measures within PTT's business operations, as well as those associated with its business activities throughout the value chain, with the primary objectives of identifying, mitigating, preventing, and rectifying human rights risks.

This risk assessment process encompasses the following steps:

  1. Identify Human Rights Issues
    Identify all human rights issues relevant to PTT's operations throughout the value chain and business relationships, considering their impacts on the business and potentially affected rights holders (including vulnerable groups such as women, children, indigenous peoples, local communities, migrant workers, subcontracted workers, persons with disabilities, pregnant women, LGBTQI+). This involves reviewing and benchmarking against similar industries globally, using both internal and external data on human rights global trends.
    It covers the following issues related to the PTT Group:

    Labor Rights

    Community

    Security

    Environment

    Customer and Consumer

    Corporate governance

    • Work Environment:
    • Freedom of association and collective bargaining
    • Forced labor and labor conscription
    • Child labor
    • Safe and healthy working conditions
    • Non-discrimination
    • Harassment and sexual harassment
    • Human trafficking
    • Standards of living and quality of life
    • Community health and safety
    • Community participation
    • Cultural heritage
    • Minority groups, including indigenous people
    • Displacement and resettlement
    • Safety management
    • Knowledge and understanding of security and safety related to human rights
    • Water resources
    • Impact of pollution
    • Waste and hazardous material management
    • Impact on biodiversity
    • Challenges in accessing energy
    • Health and safety of consumers 
    • Data privacy 
    • Anti-corruption
    • Legal compliance tracking
    • Human rights regulations
  2. Assess Natural Risks
    Assess natural risks (risks that are inherent and not controlled or mitigated by any measures) related to the identified human rights issues.
  3. Evaluate Residual Risks
    Evaluate residual risks (risks from PTT's controls or measures) associated with the identified human rights issues.
  4. Prioritize Risk Importance
    Prioritize the most significant human rights issues, which represent the highest remaining risks.

Assessment of actual or potential impacts
Scope of Human Rights Risk Assessment: The assessment covers PTT's operations and activities throughout the value chain.

The scope of the comprehensive human rights due diligence and risk assessment of PTT encompasses the operations of PTT and its subsidiaries, following PTT's governance guidelines throughout the entire value chain.


The assessment of human rights risks is conducted considering two factors: impact and likelihood. 

Criteria for assessing human rights risks: Impacts 

The impact on human rights is assessed based on various factors such as geographical, social, and economic factors, as well as the scale, scope, and limitations of the ability to mitigate negative impacts and restore the situation to its original state.

Impact
SeverityScaleScope of Affected Rights HoldersIrremediability Nature
   

Extreme (4) 
Impacts on physical and mental health and safety of rights holders with severe consequences, e.g.:
  • Reaching a state of disability
  • Being life-threatening
Affecting all rights holders within the group (such as all community members, all employees, all partners, all customers) and/or specific vulnerable groups consisting of two or more individuals. It is not feasible to restore to the original condition and/or will take a long time to recover (more than 5 years).


 
 

High (3) 

Impacts on the physical and mental health and safety of rights holders, up to the point of work cessation. Affecting the majority of rights holders (more than 50% of the rights holders) and/or a rights holder in specific vulnerable groups. It takes a relatively long time to restore to the original condition (more than 3-5 years).

 

Medium (2)

Causing minor to moderate impacts on the physical and mental health and safety of rights holders to an extent that they require medical treatment. Affecting certain rights holders (less than 50% of the rights holders). It takes a period of time to restore to the original condition (1-3 years). 

 

Low (1)
No or little impact on health and safety (physical and mental) of the right holder By first aid or medical treatment. Not affecting the rights holders. It does not take much time or takes a very short time to restore to the original condition (less than 1 year).

Criteria for assessing human rights risks: Likelihood

PossibilityFrequency and/or Possibility Likelihood
   

Extreme (4)
Occurred regularly and/or have the potential to occur regularly
(daily/weekly).

A very high likelihood of occurrence
(more than 20%)

   

High (3)

Occurred frequently and/or have a high likelihood of occurrence
(monthly/quarterly)

A high likelihood of occurrence
(More than 10% to 20%)

   

Medium (2)

Occurred infrequently and/or have a low likelihood of occurrence
(once a year within 1-2 years)

A low likelihood of occurrence
(More than 5% to 10%)

 


Low (1)

Almost never occurred and/or almost no chance of occurrence
(no more than once in 3-5 years)

Almost no chance of occurrence
(Below or equivalent to 5%)

Human Rights Risk Matrix

  • The assessment of human rights risks will be conducted using the matrix as shown to determine the importance of human rights issues.
  • Human rights risk assessment consists of two dimensions:
    • Impact (severity of impact, number of affected rights-holders, and ability to mitigate the impact)
    • Likelihood of occurrence
  • The scope of the assessment covers all rights-holders who may be affected (including vulnerable groups) by human rights violations.
  • Salient human rights issues will be those with a risk level classified as "Extreme."

Operational Integration

Since 2015, PTT has been conducting comprehensive assessments of human rights risks, encompassing all principal business units under its direct operation,the scope of these assessments was broadened to incorporate businesses invested in through subsidiaries within the PTT Group, in alignment with the PTT Group Way of Conduct. This effort encompasses PTT itself and 16 other group companies, totaling 17 entities, operating across 50 locations spanning 21 countries. These diverse businesses range from exploration and petroleum production to petrochemicals and refining, from oil and retail to coal, electricity, new ventures, and infrastructure. This initiative covers 100% of the operational areas managed directly by PTT and 100% of the areas managed by PTT Group companies under PTT's management authority.

Recent result of Human Rights Risks Assessment from PTT Operations (Own Operations) PTT Group (including Joint Venture) and Traders/Contractors (Tier 1)

PTT operational area

PTT Group including Joint Ventures

Traders/Contractors
(Tier 1)

Percentage of areas assessed for potential human rights risks. 100 100 100
Percentage of area assessed to be at risk 8.33 (2 places out of 24 places) 0
Significant risk issues
  • Employee:
  • Occupational health (health) and safety of suppliers and contractors
  • Discrimination and harassment.
  • Local communities
  • Health and safety
  • Standard of living
-
Percentage of area assessed to be at risk measures are established and followed to prevent risks. Including determining remedies for those who may be affected.

Human Rights Issues and Affected Rights Holders Employees: Occupational Health (Health) and Safety

Key operational areas where significant human rights risks are identified:

  • PTT Public Company Limited (Headquarters)
Existing measures and additional measures to prevent significant human rights risks

Existing and additional measures are implemented to safeguard employee rights across all operational domains:

  • Engage a physical therapist to offer guidance and design programs or activities for employees to stretch their bodies every hour.
  • Adapt work equipment (tables/chairs) to suit working conditions and ergonomic standards.
  • Establish a workplace stress management program.
  • Draft a comprehensive human rights statement encompassing Quality, Security, Safety, Health, and Environment Policy and institute a SSHE Committee to ensure employees' voices are heard.
  • Implement SSHE (Safety, Security, Health, and Environment) management standards for the PTT Group, adhering to international QSHE standards such as ISO45001 and ISO14001, to foster a safe and conducive environment for employees.
  • Enforce fundamental PTT Life Saving Rules and promote their application during all operational periods.
  • Facilitate incident reporting, encompassing accidents, near-miss incidents, and substandard actions or conditions (Sub-Standard Act/Conditions), through the Incident and Non-Compliance Report System accessible on the organization's intranet.
  • Provide diverse channels for reporting concerns through various platforms:
    • 1365 Contact Center
    • The accused individual's supervisor.
    • Human Resources Management Department of each business unit directly.
    • Labor Relations Complaint System within the Labor Relations Division.
    • Relations Affairs Committee
    • Joint Consultation Committee (JCC)
  • State Enterprise Workers Union, PTT Public Company Limited.
Details of human rights risks that may occur:
  • Human rights risks related to occupational health (health) and safety of employees may arise from unsafe working conditions or prolonged working hours, potentially leading to symptoms of office syndrome.

Affected rights-holders and vulnerable groups:

  • Persons with disabilities, women, pregnant women, and LGBTQI+ individuals.
Relevant human rights based on principles outlined in the International Bill of Rights: The Universal Declaration of Human Rights (UDHR), International Covenant on Civil and Political Rights (ICCPR), and International Covenant on Economic, Social, and Cultural Rights (ICESCR).
  • Right to life.
  • Right to fair and satisfactory working conditions.
  • Right to a decent livelihood.
  • Health rights.

Human Rights Issues and Affected Rights Holders Employees: Occupational Health (Health) and Safety

Key operational areas where significant human rights risks are identified:
  • PTT Public Company Limited
  • PTT Group companies (in Thailand)
Existing measures and additional measures to prevent significant human rights risks 

Existing and additional measures are implemented to safeguard supplier and contractor rights across all operational domains:

  • Conduct a thorough review of safe practices concerning electrical system operations and ensure effective communication of these practices to suppliers operating in the respective area.
  • Develop a Sustainable Supplier Code of Conduct (SSCoC) for suppliers and contractors, ensuring compliance with regulations across all operations, particularly in the realms of human rights and occupational health and safety.
  • Implement fundamental safety protocols known as PTT Life Saving Rules and advocate for their adherence during all operational periods.
  • Craft a comprehensive human rights statement encompassing Quality, Security, Safety, Health, and Environment Policy.
  • Establish SSHE management standards for the PTT Group by adhering to international QSHE standards such as ISO45001 and ISO14001, aimed at fostering a safe and conducive environment for trading partners and contractors.
  • Implement an incident reporting system, encompassing accidents, Near Miss incidents, and instances of substandard actions or conditions (Sub-Standard Act/Conditions), accessible through the Incident and Non-compliance Report System on the organization's Intranet.
  • Provide diverse channels for reporting concerns through various platforms:
  • 1365 Contact Center
  • pttplc.com
  • “PTT Voice” pttvoice@pttplc.com.
Details of human rights risks that may occur:
  • Human rights risks related to occupational health (health) and safety of suppliers and contractors may arise from injuries or accidents associated with work, such as electric shocks and working at heights.
Affected rights-holders and vulnerable groups:
  • Women, migrant workers, labor hired by third parties, persons with disabilities, pregnant women, LGBTQI+ individuals.
Relevant human rights based on principles outlined in the International Bill of Rights: The Universal Declaration of Human Rights (UDHR), International Covenant on Civil and Political Rights (ICCPR), and International Covenant on Economic, Social, and Cultural Rights (ICESCR).
  • Right to life.
  • Right to fair and satisfactory working conditions.
  • Right to a decent livelihood.
  • Health rights.

Human Rights Issues and Affected Rights Holders Business Partners and Contractors: Discrimination and Harassment

Key operational areas where significant human rights risks are identified:

  • PTT Group companies (in Thailand)
Existing measures and additional measures to prevent significant human rights risks

Existing and additional measures are implemented to safeguard supplier and contractor rights across all operational domains:

  • Develop a comprehensive human rights statement emphasizing zero tolerance for all forms of discrimination in employment and conduct.
  • Establish a manual outlining principles of good corporate governance, ethical standards, and business ethics. This manual explicitly states that “PTT upholds equality for all its personnel, prohibiting discrimination based on factors such as origin, race, nationality, gender, age, skin color, religion, disability, marital status, family background, educational background, or any other irrelevant status unrelated to job performance.”
  • Implement a Sustainable Supplier Code of Conduct (SSCoC) requiring PTT's suppliers to adhere to equal treatment principles for their employees. This includes ensuring non-discrimination in hiring, compensation, training opportunities, promotion, and termination or dismissal, regardless of gender, race, skin color, religion, age, marital status, pregnancy, political beliefs, or disabilities, among others.
  • Provide diverse channels for reporting concerns through various platforms:
  • 1365 Contact Center
  • pttplc.com
  • “PTT Voice” pttvoice@pttplc.com.
Details of human rights risks that may occur:
  • Human rights risks potentially arising from discriminatory practices and breaches against suppliers and contractors, which may stem from unfair task assignments or intimidation, as well as physical violence against employees or superiors.

Affected rights-holders and vulnerable groups:

  • Women, migrant workers, labor hired by third parties, persons with disabilities, pregnant women, LGBTQI+ individuals.
Relevant human rights based on principles outlined in the International Bill of Rights: The Universal Declaration of Human Rights (UDHR), International Covenant on Civil and Political Rights (ICCPR), and International Covenant on Economic, Social, and Cultural Rights (ICESCR).
  • Minority rights.
  • Equal rights of individuals under the law, ensuring equal protection and non-discrimination.
  • Right to express opinions, access information, and freedom of expression.
  • Right to a decent living.
  • Right to fair and satisfactory working conditions.

Human Rights Issues and Affected Rights Holders Local Communities : Health and Safety

Key operational areas where significant human rights risks are identified:
  • PTT Public Company Limited
Existing measures and additional measures to prevent significant human rights risks

Existing and additional measures are implemented to safeguard surrounding community rights across all operational domains:

  • Utilize technology for enhanced surveillance, such as employing drones for increased monitoring and surveillance frequency.
  • Educate the local community on basic pipeline inspection practices, empowering them to assist in monitoring activities.
  • Implement Process Safety Management (PSM) in PTT operational zones along with PTT safety risk assessments.
  • Craft a human rights statement encompassing Quality, Security, Safety, Health, and Environment Policy to instill community confidence in health and safety measures.
  • Establish protocols for managing significant incidents and validate control measures (Barrier Validation).
  • Develop PTT's emergency and crisis management plan and conduct regular drills to practice emergency response procedures.
  • Conduct community outreach sessions to communicate safety measures and emergency preparedness, actively engaging with community members and considering their feedback in operations.
  • Arrange meetings with community leaders to address complaints promptly, fairly, and systematically, while fostering community confidence through active listening and dialogue.
  • Disseminate information regarding construction plans in the area to the community, welcoming their input and addressing concerns.
  • Provide channels for community complaints, such as the Call Center at 1365
  • Provide the emergency phone number for the natural gas pipeline system at 1540.
Details of human rights risks that may occur:
  • Potential human rights risks concerning the health and safety of communities may emerge from on-site accidents that could impact community members, such as fires, explosions, oil or gas spills, and chemical releases from pipeline transportation.

Affected rights-holders and vulnerable groups:

  • Local community, indigenous peoples, women, pregnant women, individuals with disabilities, LGBTQI+ individuals, and children
Relevant human rights based on principles outlined in the International Bill of Rights: The Universal Declaration of Human Rights (UDHR), International Covenant on Civil and Political Rights (ICCPR), and International Covenant on Economic, Social, and Cultural Rights (ICESCR).
  • Minority rights.
  • Right to life.
  • Right to fair and satisfactory working conditions.
  • Right to a decent living.
  • Right to effective remedies.
  • Health rights.
  • Right to a fair juridical process.

Human Rights Issues and Affected Rights Holders Local Communities : Standard of Living

Key operational areas where significant human rights risks are identified:
  • PTT Group companies (in Thailand)
Existing measures and additional measures to prevent significant human rights risks 

Existing and additional measures are implemented to safeguard surrounding community rights across all operational domains:

  • Develop a comprehensive human rights statement encompassing Quality, Security, Safety, Health, and Environmental Policies to ensure that the Company’s operations do not disrupt community members.
  • Facilitate an environmental, health, and community impact assessment through an inclusive engagement process, allowing communities near PTT facilities to voice concerns regarding the operational impact, facilitating corrective actions, and ongoing resolution of various issues.
  • Establish a community relations manual outlining protocols for community engagement and development activities, aligning with international standards by embedding human rights principles into the guidelines.
  • Engage directly with local communities to foster trust and confidence in the Company’s safety measures and emergency preparedness, while actively soliciting feedback to inform its operational practices.
  • Convene meetings with community leaders to address grievances systematically, promptly, and impartially, prioritizing active listening and fostering community trust.
  • Disseminate information regarding construction plans within the area, ensuring transparency and responsiveness to community suggestions and concerns.
  • Establish community complaint channels (such as the Call Center 1365).
Details of human rights risks that may occur:
  • Potential human rights risks to community well-being may stem from various sources, including chemical and oil spills from shipping vessels, disruptions caused by operational activities like gas or oil odors, inadequate waste management, excessive noise pollution from roads, accidental spills of hazardous waste, and the discharge of chemicals and oils from operations into drainage systems.
Key operational areas where significant human rights risks are identified:
  • Local community, indigenous peoples, women, pregnant women, individuals with disabilities, LGBTQI+ individuals, and children
Relevant human rights based on principles outlined in the International Bill of Rights: The Universal Declaration of Human Rights (UDHR), International Covenant on Civil and Political Rights (ICCPR), and International Covenant on Economic, Social, and Cultural Rights (ICESCR).
  • Minority rights.
  • Right to life.
  • Right to effective remedies.
  • Right to a decent livelihood.
  • Health rights.
  • Right to work.

 

Key Sustainability Issues with Human Rights 

Implications Analysis and assessment of key sustainability issues reveal that the company's direct and indirect operations, such as natural gas separation and investments in various energy/fuel industries (e.g., coal mining), significantly contribute to various negative impacts of climate change. These impacts include environmental degradation, loss of biodiversity, and a subsequent decline in the population's quality of life, encompassing health issues, food and water insecurity, and displacement. Therefore, PTT has incorporated climate change as a critical factor in its strategic direction-setting process. In 2022-2023, the PTT Board of Directors approved strategic directions, long-term goals, and business plans reflecting the company's efforts to transition its business model towards a low-carbon society. These efforts aim to mitigate the impact and risks of climate change on communities, society, and future generations. The key initiatives include:

  • Divested investments in the coal business to focus on clean energy, reduce pollution, and mitigate environmental and community impacts, particularly those residing near mining areas.
  • Setting a target to increase renewable energy (RE) power generation capacity to 15 GW by 2030 and reduce conventional power generation capacity by 5 GW.

Rights holders and vulnerable groups 

PTT takes into account all groups of rights holders who may be affected during the Human Rights Due Diligence process, encompassing employees, suppliers, subcontractors, contractors, business partners, local communities, customers/consumers, and vulnerable groups (including migrant workers, women, indigenous people, LGBTQI+ individuals, civilians, persons with disabilities, disadvantaged individuals, and children). PTT effectively communicates its commitment to and respect for human rights across the entire supply chain by raising awareness among various stakeholders through suitable channels, such as:

  • Employees: Training sessions conducted from their first day of employment, SSHE courses, basic human rights training programs, and internal communication channels like emails, videos, etc.
  • Business partners: Annual trade seminars held (at both organizational and business unit levels), and engagement with other relevant groups such as networks, associations, institutions, and governmental bodies.


Corrective/preventive measures 

Complaint management and remediesGRI2-25

Complaint managementGRI2-16, GRI411-1

PTT has enhanced its system for handling complaints both internally and externally, proposing the expansion of complaint channels to include various types of grievances. This expansion aims to provide diverse and accessible avenues for all stakeholders to reach out conveniently at any time. The system supports communication in both Thai and English to address all types of complaints, including concerns and suggestions from stakeholders who may be affected. For overseas subsidiaries within the PTT Group, contact can be made through their respective websites and social media platforms, catering to local languages in each region.

Moreover, PTT has implemented a comprehensive policy for receiving and managing complaints within appropriate timeframes. This policy ensures clarity, consistency, transparency, confidentiality, and prioritizing protection without harassment, dismissal, punishment, or violence against complainants or witnesses. Stakeholders can monitor the progress of their complaints through the designated complaint system and employee relations channels. Additionally, PTT has established channels for reporting ethical violations in business operations for external individuals, including the Customer Relations Center 1365, the Contact Center, the Corporate Communication and Public Relations Department, the Office of the President, the Governance and Ethics Promotion Department, and the Investor Relations Department.

Furthermore, PTT has established channels for "Whistleblowing" both on its website www.pttplc.com and through "PTT Voice" (pttvoice@pttplc.com). These avenues serve as means for stakeholders to report any observed violations or corrupt practices within the organization. The information provided through these channels will be forwarded to the appropriate department for thorough review and action in accordance with established protocols. PTT has also conducted a comprehensive review and update of the Regulations of PTT Public Company Limited (PTT) Regarding Complaint Lodgement, Whistleblowing, Misconduct, and Non-compliance with Laws and Organizational Regulations of 2022 to establish clear criteria and guidelines for handling complaints, whistleblowing, misconduct, and non-compliance with laws and organizational regulations (Whistleblowing), ensuring transparent supervision, investigation, and consistency throughout the organization. Additionally, measures have been implemented to safeguard and uphold fairness for complainants or informants involved in providing pertinent information.

StakeholdersComplaint Lodgement PlatformsPossible Complaints
Employees
  • State Enterprise Workers Union, PTT Public Company Limited
  • Human Resources Management Department of each business unit directly
  • Labor Relations Department through the Internet-based labor complaint system or by phone
  • Relations Affairs Committee through employee representatives
  • Joint Consultation Committee (JCC)
  • Electronic media such as pttvoice@pttplc.com - labor relations, ethics, and integrity complaint system
  • Labor rights
  • Discrimination
  • Sexual and non-sexual harassment
Suppliers, Customers, and Third Parties
  • Customer relations ( 1365)
  • Directly send complaint letters to the PTT Chief Executive Officer and President, the Audit Committee, Assistant to the President - Internal Audit Office, Assistant to President - Corporate Human Resources, or Managers of the President Office and the Corporate Secretary and Investor Relations Department.
  • Utilize various electronic media channels such as www.pttplc.com, www.pttbluecard.com, Facebook PTT News, We love PTT, PTT Blue Society, and PTT Blue Card Application.
  • Joint meetings with business suppliers.
  • Consumer rights
  • Free, Prior And Informed Consent (FPIC)
  • Labor rights
  • Discrimination
  • Sexual and non-sexual harassment
  • Environmental pollution and disturbances
  • Safety and work environment
Communities Surrounding PTT Establishments
  • Deploy community relations personnel to designated areas based on predetermined maps to engage with the community, receive feedback, address concerns, and understand their needs and expectations. This includes designing effective channels for receiving complaints and establishing suitable communication methods tailored to each specific area for ongoing engagement.
Furthermore, PTT actively encourages its partners to establish robust complaint-handling mechanisms, both internally and externally. It supports partners in articulating their expectations regarding the promotion of these mechanisms, ensuring that all stakeholders in the supply chain have access to effective remedies.

PTT is deeply committed to safeguarding the rights of complainants and human rights defenders. It has established procedures to protect and uphold the rights of complainants and individuals providing relevant information, ensuring fairness throughout the process. Clear timeframes have been set for the efficient management of complaints, with a maximum of 30 days for each step in handling employee complaints. For external complaints, thorough review, resolution, and feedback are provided within 7 business days. Importantly, throughout the entirety of 2021, no complaints were received regarding human rights violations or practices that do not align with human rights laws.

ช่องทางการรับข้อร้องเรียนของกลุ่ม ปตท.


Remedies

TT places great importance on processes for protecting and remedying individuals who may be affected by its operations' human rights impacts. It ensures channels for lodging complaints are available in all circumstances, especially during emergencies and crises in each area. Moreover, PTT does not obstruct or hinder access to any remedial processes for those impacted or human rights defenders, whether within governmental or corporate frameworks. It also specifies formats for immediate remedies (Access to Remedy), including monetary forms such as compensation payments or financial aid support, as well as non-monetary forms. For example, setting up emergency complaint reception points to provide initial support, advice, or expert assistance. Additionally, it prepares communication channels to systematically receive and address feedback and complaints from stakeholders.

  • For PTT's partners: Suggestions and feedback are encouraged for improving the complaint system during annual partner seminars. Feedback received is then utilized by PTT for system enhancements, such as improving personal data management and enhancing complaint channels on the website.
  • For employees: Responsible departments invite representative employee groups to provide feedback for internal complaint system improvements and participate in testing these systems.

Furthermore, opportunities are provided for individuals who may be affected to lodge complaints through each project's complaint reception center or contact PTT's Call Center. PTT will analyze the root cause, take corrective action, and prevent recurrence according to subsequent procedures. In cases where the protection and remedy process cannot be preliminarily concluded, PTT will establish a mechanism for protection and remedy through the use of a tripartite task force. This task force comprises representatives from stakeholders, including local government representatives, community leaders, and relevant government agencies. Together, they manage the situation appropriately and effectively, aiming to achieve satisfaction for all parties involved.


Complaints regarding human rights 

Further details of these complaints can be reviewed on the PTT website under the section titled Ethical Conducts.

Communications and trainingGRI410-1

PTT has communicated statements regarding human rights, along with details of management, issues/impacts on sustainability, human rights, various impact reduction measures, avenues, and progress in addressing complaints for stakeholders to be informed and understand through appropriate channels. This includes activities in surrounding communities where community relations activities are conducted, platforms for community feedback, societal levels, and citizens through websites, news releases, as well as stakeholders at the organizational level such as investors and traders through Form 56-1 and annual trade seminars. More information can be found in the Form 56-1 One Report under the section "Driving Business for Sustainability" and the subsection "Building Relationships with Stakeholders."

For internal staff, PTT places a significant emphasis on cultivating awareness concerning both business operations and human rights issues. This is achieved through consistent communication channels such as articles, journals, and internal PR emails. These mediums cover a spectrum of topics, including declarations, policies, guiding principles, and human rights management systems, supplemented with real-world case studies across diverse business landscapes. Moreover, PTT offers comprehensive courses on sustainable management and fundamental human rights principles to all relevant personnel through training sessions and informative video materials. These educational initiatives delve into practical applications of human rights considerations within business operations, showcasing exemplary practices that prioritize human rights. Presently, foundational human rights topics are integrated into the SSHE1 course for new hires, spanning across 64 cohorts. Additionally, in 2022, an online course on Fundamental Human Rights Management was introduced, aiming to deepen comprehension of human rights within the fundamental business sector. This initiative aligns with stakeholder expectations, fosters organizational confidence, and propels sustainable business development, catering to employees across all levels.

In addition, senior executives have demonstrated leadership roles that prioritize human rights alongside business operations through various networks and media. For example, in 2021, PTT's Vice President of Legal Affairs participated in a seminar and shared best practices for human rights management at a sub-group seminar of the Thai capital market business with human rights (Phase 1), organized by the Securities and Exchange Commission (SEC). The course "Ethics and Gender Equality for Executives" was organized by the Department of Business Development and the Family Institute, aimed to enhance knowledge and understanding of human rights, promote gender equality, and advocate for the implementation of these principles for the maximum benefit of stakeholders. Additionally, interviews were given on "The Secret Sauce" podcast, focusing on transparency, accountability, human rights, and the laws that every company should be aware of. In 2022, the Chief Executive Officer and President, and executives, demonstrated their commitment to supporting the 10 principles of the Global Compact and SDGs at the GCNT Forum 2022. The Vice President of Strategy and Sustainability at PTT also participated as a speaker in the Business Week for Human Rights event in 2022. Additionally, PTT's Human Rights Management Task Force also took part in this event.

For the training of security personnel, PTT emphasizes the importance of providing necessary knowledge to all security personnel prior to commencing their duties, as stipulated in the terms of their employment contracts. The training focuses on human rights, with an emphasis on the fundamental right to safety for all individuals. Security personnel are instructed not to use violence against others, even in the case of wrongdoers. Furthermore, security personnel are not authorized to apprehend anyone except for wrongdoers found within PTT premises, and individuals accused of wrongdoing have the right to be presumed innocent until proven guilty according to the law. Each year, PTT and its subsidiaries conduct training sessions for security personnel to equip them with the skills necessary to handle various situations, such as community enclosures or confrontations with claimants. PTT collaborates with community members to enhance security measures or prevent violence that may arise within the Company's premises (This collaboration is particularly important in areas where security units may need to use force due to conflicts or other volatile situations). Training also covers procedures for managing threats, intimidation, and violence against women. In 2022, there were no human rights complaints lodged against PTT security personnel.

Network of cooperation on human rights

PTT participates as a signatory to the United Nations Global Compact (UNGC) and the Global Compact Network Thailand (GCNT) to support businesses that uphold and apply the principles of the ten international standards. Additionally, PTT also contributes by providing feedback to the government sector to support the development of the National Action Plan on Business and Human Rights (NAP) and the National Human Rights Plan, Version 4, continuously.

Partners and collaborators throughout the supply chain

PTT promotes and encourages business partners within its supply chain to operate with respect for human rights and adhere to PTT's human rights guidelines. This begins with the selection process of vendors, both existing and new, who operate based on environmental, social, and governance (ESG) criteria in addition to the fundamental standards of quality and finance. Vendors who do not meet the assessment criteria as per the defined standards will not be approved to be included in PTT's Approved Vendor List (PTT AVL).

Additionally, there is a Sustainable Supplier Code of Conduct consisting of four main principles covering human rights aspects: ethical business conduct, social responsibility, environmental responsibility, and safety. This code is enforced for traders contracting with PTT for amounts exceeding 2 million baht and/or projects that may impact safety and the environment. Continuous monitoring and evaluation of traders have been conducted since 2016, particularly focusing on significant and high-risk trader groups. In case of any violations found against the sustainable supplier code of conduct, corrective action plans must be developed. Furthermore, PTT reserves the right to terminate contracts upon continued breaches of the said conduct guidelines.

Promotion of Diversity, Equity, and Inclusion

PTT is committed to fostering a culture of acceptance and inclusivity, recognizing it as a foundational principle to instill confidence among all stakeholders that there will be no discrimination in any aspect of personnel management, including recruitment, HR practices, training, and skill development (Detailed diversity metrics, such as the ratio of female employees, gender pay gap, and indicators of religious diversity, are transparently provided on the PTT website under the "People Management Direction" section). This commitment extends to ensuring there is no discrimination based on age, disability, gender, marital status, pregnancy, political beliefs, ethnicity, religion, sexual orientation, socioeconomic status, union membership, work arrangements, family status, or any other irrelevant factors in PTT's employment practices.

Furthermore, PTT has established clear standards of conduct and disciplinary measures, which have been widely communicated to all employees. Violations of these standards may result in verbal warnings from supervisors or, in more serious cases, disciplinary action, the severity of which will be determined by the nature of the offense.

Any act or omission that constitutes segregation, discrimination, harassment based on sex or unrelated to sex, or restricts any benefits, whether directly or indirectly, without bias, because the individual is male, female, or exhibits characteristics different from their birth sex, or due to differences in nationality, race, religion, language, age, disability, physical or mental health condition (Item 3.8 of the HR Code of Conduct, Chapter 20: Standards of Behavior and Disciplinary Actions) is considered a disciplinary offense. Those who commit such actions shall be subject to disciplinary measures commensurate with the severity of the offense (Item 3 of the HR Code of Conduct, Chapter 20: Standards of Behavior and Disciplinary Actions). According to PTT's disciplinary guidelines, the above actions are considered moderate offenses, punishable by a salary suspension for up to 6 months in the following year (Item 2 of the Table annexed to the Disciplinary Penalties and Consideration of Mitigation Measures Guidelines).

Tracking the effectiveness of actions to respond to HRs risks and impacts

Human rights management process from the identification and comprehensive assessment of human rights risks. Establishing measures to manage and reduce human rights impacts/risks, communicating and enhancing awareness of human rights among executives and employees process for receiving and managing human rights complaints as well as following up and summarizing performance reports to the Board of Director according to the governance structure. The efficiency and effectiveness are inspected by the nternal Audit Department every 3 years. The results of the audit were reported to the Internal Audit Committee at the PTT Board level. The most recent audit in 2023 found 1 finding for improvement, which has been completely improved.

Investments of PTT Group’s Subsidiary in the Republic of the Union of Myanmar 

PTT adheres to the fundamental practice of respecting human rights and is deeply concerned about the violent events that occurred in Myanmar following the coup in 2021. The Company supports efforts to peacefully and vigorously address the crisis and comply with international standards in all operational areas. Additionally, it closely monitors the situation to improve decision-making processes and management practices, ensuring that the investments promote sustainable development goals and facilitate equitable access to energy resources. PTT earnestly hopes for the situation in Myanmar to stabilize and return to normalcy as soon as possible.

PTT Exploration and Production Public Company Limited (PTTEP), a subsidiary of PTT Public Company Limited, has participated in investing in the development project of natural gas resources in the Republic of the Union of Myanmar. Given the situation that unfolded in Myanmar in 2021, PTTEP has been monitoring and evaluating the circumstances to assess the various impacts on the Company and stakeholders involved. Subsequently, it has formulated corrective and preventive measures to enhance governance, management oversight, and responsiveness in a timely manner.
  • The initial Petrochemical and Natural Gas Business Management Committee has assessed various impacts that may arise, both in business and societal dimensions, such as the safety of workers, surrounding communities, energy security affecting the quality of life of the people, as well as human rights violations that occur. This assessment has been used to review risk evaluations and report to the PTT Board for consideration in setting directions for operations and appropriate corrective/preventive measures.

    After thorough consideration, in collaboration with companies within the Group, it is recognized that the development of natural gas resources for electricity generation is crucial for the country's development, benefiting both households and industries. It is a vital factor for the well-being of Myanmar's population, impacting daily life, healthcare, telecommunications, education, and various businesses that rely on energy to drive and develop the country's economy. Therefore, PTTEP continues its business operations.

  • PTT, as a major shareholder with a pivotal role in overseeing group companies, has instituted a series of corrective and preventive measures across various processes, including:
    • Appointing the Chief Executive Officer and President and the Chief Operations Officer of the Initial Petroleum and Natural Gas Business Group as directors on the Board of Directors of PTTEP. They are privy to detailed reports and empowered to provide direct feedback, recommendations, and directives.
    • Enhancing its adherence to regulations governing investment criteria and budget management for investments by PTT and its subsidiaries, as well as guidelines for overseeing investments in entities where PTT holds shares. These measures are aimed at facilitating decision-making, monitoring, and oversight of investments by PTT and its subsidiaries. Central to this effort is the Strategic Investment Management (SIM) process, overseen by an Investment Management Committee composed of experienced executives tasked with evaluating and screening investment proposals before presenting them to the PTT Board of Directors for approval. Investments with substantial value or diverse risks, encompassing critical sustainability concerns, must be presented to the Organizational Risk Management Committee for thorough consideration. Their insights are integral for informed decision-making regarding investments by the PTT Board of Directors. Following approval from the PTT Board of Directors, a systematic monitoring process will be instituted to report outcomes quarterly to the Investment Management Committee, the PTT Management Committee, and the PTT Board of Directors.
    • Forming a committee to bolster the organization's response to international incidents in Myanmar within the PTT Group, led by the Chief Operations Officer of the initial petroleum and natural gas business division. This committee comprises high-ranking executives from PTT and its subsidiaries with investments in Myanmar, serving as members. Its mandate is to closely monitor the situation and its effects on stakeholders, including employees and local communities, both directly and indirectly impacted. Additionally, the committee will conduct thorough reviews, establish remedial and preventative measures, and execute urgent and decisive actions.

      The interdependence of circumstances has highlighted instances where PTT and its subsidiaries may not align with human rights declarations and other established policies. Consequently, PTT has enhanced its internal control mechanisms. Policy-owning units now monitor and analyze various situations closely tied to the Company's operations. They identify and assess internal operational risks, along with risks associated with stakeholders in the value chain, which could lead to policy non-compliance. Should potential risks arise, systematic corrective and preventive measures are promptly implemented.
    • For the situation in Myanmar, in order to control, prevent, and mitigate risks that may affect the health, lives, and properties of employees and contractors in the area, PTTEP has significantly enhanced its safety, security, occupational health, and environmental management systems, as well as human rights management within its operational area in the Republic of the Union of Myanmar.
    • Transparently and timely communicating important situations and information to stakeholders. PTTEP has developed informative materials regarding decision-making and actions for various stakeholder groups, such as Securities and Exchange Commission disclosures, press releases on the website, etc.
    • Additionally, PTTEP continues its ongoing social projects aimed at promoting improved quality of life for communities in the areas where it operates. Given the current situation, PTTEP is deeply concerned about the welfare and safety of all Myanmar citizens and hopes for a swift resolution to restore peace and stability to the Republic of the Union of Myanmar.
    • Furthermore, PTTEP continues its ongoing social projects aimed at promoting improved quality of life for communities in the areas where it operates. Given the current situation, PTTEP is deeply concerned about the welfare and safety of all Myanmar citizens and hopes for a swift resolution to restore peace and stability to the Republic of the Union of Myanmar.

PTT Group is Negotiating to Mediate a Class Action Lawsuit Arising from the Montara Incident with a Group of Seaweed Farmers in Indonesia

PTTEP upholds the principle of respecting human rights as a cornerstone of its operations and places significant emphasis on environmental preservation in all business areas. In response to recent developments, PTT, under the name of PTTEP AAA, engaged in mediation with a group of seaweed farmers, as mandated by the Federal Court of Australia. This process adheres to standard legal procedures in Australia, culminating in a preliminary agreement. Under this agreement, PTTEP AAA will compensate a total of 192.5 million Australian dollars (approximately 129 million US dollars) to settle all group litigation, including allegations, with the seaweed farmers' group in Indonesia. However, it is essential to clarify that this settlement agreement does not imply any admission of liability on the part of PTTEP AAA. Detailed disclosure is not feasible at this juncture, as the settlement agreement remains under review by the Federal Court of Australia.