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Human Rights Due Diligence Process

The Company Group’s operations involve employees, suppliers and neighboring communities, which may result in direct and indirect impacts on human rights. Therefore, human rights have been identified as a material issue and are integrated into the enterprise risk management and sustainability practices.

Impact Boundary

Boundary Rights-holders
Internal boundary Full-time employees, contract employees, probationary employees
Value chain Suppliers, contractors, raw material suppliers
External boundary Community in operational areas, customers, related rightsholders

Impact, Risk and Opportunity

Possible negative impact Enterprise risk Opportunity
  • Violations of workers' rights, including discrimination or workplace harassment
  • Restrictions on freedom of association and collective bargaining
  • Risks related to child labor or forced labor in the supply chain
  • Impacts on community rights, health, and safety
  • Compliance and non-compliance with applicable laws and regulations
  • Risks to the Company's reputation and stakeholder confidence
  • Risks to business performance, projects, and business continuity
  • Strengthen relationships with employees, communities and suppliers
  • Enhance labor and supply chain management standards
  • Promote a culture of respect for human rights

Assessment of Human Rights Risks and Impacts

RATCH conducted a Human Rights Due Diligence in 2025 in accordance with the three-year review plan to evaluate the appropriateness and completeness of the Human Rights Risk Register, as well as the effectiveness of prevention, mitigation, and remediation measures. The due diligence process followed the UN Guiding Principles on Business and Human Rights (UNGPs) and covered the Company, its subsidiaries, joint ventures and Tier-1 suppliers.

Human rights risks and impacts assessment procedures
Human rights risks and impacts assessment procedures
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Scope of human rights risk assessment
Scope of human rights risk assessment
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Results of human rights risk assessment and management measures
Risk issue: Supplier/contractor’s occupational health and safety

Management measures

  • Human Rights Policy: To reaffirm the Company's commitment to respect, protect, and promote human rights throughout the value chain.
  • Human rights practices: To outline the framework and guidelines for implementing human rights principles.
  • Supplier Code of Conduct: To establish standards for responsible business practices for suppliers and all parties involved in the supply chain.
  • Safety, Occupational Health and Working Environment Policy: To promote a safe and conducive working environment for the well-being of employees, contractors and related personnel.
  • Risk Management Policy: To encompass the identification, assessment and systematic management of human rights risks.
  • Legal compliance: To ensure strict compliance with laws and regulations related to safety, occupational health and working environment across all areas of operation.
  • Drug prevention measures: To reduce work-related accidents and protect the health and safety of employees, contractors and workers in the supply chain.
  • Safety practices and enforcement of the use of personal protective equipment: To prevent workplace accidents and injuries.
  • Safety, Occupational Health and Working Environment Committee: To oversee and continuously monitor safety operations across the organization.
  • Occupational Health and Safety Management System (ISO 45001:2018): To implement a standardized framework for managing occupational health and safety risks.
  • Job risk management: To identify, assess, and control work-related hazards.
  • Safety requirements for suppliers, contractors and sub-contractors: To ensure participation in safety training and compliance with occupational health and safety measures while performing work at office areas or power plants.
  • Monitoring, inspection and evaluation of contractors and sub-contractors: To inspect and evaluate compliance with the organization's safety requirements.
  • Complaint and whistleblowing process and remediation mechanism: To provide accessible and fair channels for stakeholders to report human rights violation and receive appropriate remediation.
  • Stop Work Authority: To prevent hazards that may threaten the life, well-being and safety of workers.
Risk issue: Community living standards

Management measures

  • Human Rights Policy: To serve as the framework guiding the Company Group's business operations in respecting and protecting human rights.
  • Risk Management Policy: To cover the assessment and management of human rights and social risks across the organization.
  • Complaint and whistleblowing mechanism: To provide accessible, fair, transparent and secure channels for all community stakeholders to report concerns or violations.
  • Remediation measures for the affected stakeholders: To ensure appropriate corrective actions, including communication and consultation with local government authorities to determine suitable solutions and compensation.
  • Communications channel via Community Relations Division: To consistently receive community feedback, opinions and concerns.
  • Preparation of emergency and crisis response plans: To prepare and implement response procedures, including evacuation plans and regular emergency drills.
  • Compliance with social measures and community development plans: To ensure adherence to requirements specified in the Environmental Impact Assessment.
  • Establishment of a tri-partite committee: To promote collaboration among the government sector, the private sector and community.
  • Community opinion surveys and hearings: To gather feedback from community stakeholders for continuous improvement.
  • Implementation of community development plans: To support community well-being, including and the preservation and promotion of local traditions and culture.
  • Establishment of a joint coordination mechanism for small power producers: To align operational directions among nearby or overlapping operators and enhance cooperation and knowledge sharing to improve overall efficiency.
  • Establishment of local committees for compensation and relocation: To manage community impacts in a fair, transparent and systematic manner.
Risk issue: Land acquisition and community relocation

Management measures

  • Human Rights Policy: To serve as the framework guiding the Company Group’s business operations in respecting and protecting human rights.
  • Risk Management Policy: To cover the assessment and management of human rights and social risks across the organization.
  • Complaint and whistleblowing process: To provide accessible, transparent and secure channels for all community stakeholders to report concerns or violations.
  • Complaint mechanism and remediation process: To ensure that community members affected by the Company Group’s operations can report grievances and receive fair and timely remediation.
  • Remediation measures for the affected stakeholders: To implement appropriate corrective actions, including communication and consultation with local government authorities to determine suitable solutions and compensation.
  • Communications channel via Community Relations Division: To consistently receive community feedback, opinions and concerns.
  • Preparation of emergency and crisis response plans: To implement response procedures covering evacuation plans and regular emergency drills.
  • Establishment of a tripartite committee: To promote collaboration among the government sector, the private sector and community in the decision-making process.
  • Community opinion survey: To gather feedback for impact assessment and continuous improvement.
  • Preparation of community development plans: To promote and preserve local traditions and culture.
  • Systematic dispute resolution process: To facilitate joint negotiation and mediation with relevant government authorities, including the determination of compensation in accordance with applicable laws and regulations.
  • Establishment of local committees for compensation and relocation: To oversee compensation, assistance, and relocation processes, ensuring transparent, fair and systematic coordination.
Risk issue: Information safety management for all rights holders

Management measures

  • Human Rights Policy: To serve as the framework guiding the Company Group’s business operations in respecting and protecting human rights.
  • Risk Management Policy: To cover the identification, assessment and management of risks in all dimensions, including human rights and personal data protection.
  • Complaint and whistleblowing process: To provide accessible, transparent and secure channels for all community stakeholders to report concerns or violations.
  • Complaint mechanism and remediation process: To ensure that community members affected by the Company Group’s operations can report grievances and receive fair and timely remediation.
  • Network and Computer Usage Policy: To ensure appropriate and secure use of the Company’s information technology systems.
  • Information Technology Security Policy: To prevent cyber risks and unauthorized access to information systems.
  • Prevention of Misuse of Inside Information Policy: To prevent improper use or disclosure of internal information.
  • Personal Data Protection Policy: To safeguard the rights of data subjects and strengthen confidence in the Company’s information management practices.
  • Cookies Policy: To ensure transparency in the storage and use of cookies on the Company’s website.
  • Personal data protection guidelines: To provide guidance for compliance with applicable data protection laws and standards.
  • Personal Data Protection Working Committee: To oversee personal data protection management, conduct quarterly performance evaluation, and assess the organizational capabilities under the Privacy Maturity Model (PMM).
  • Business Continuity Policy and Disaster Recovery Plan: To ensure operational continuity and mitigate impacts during emergency situations, particularly in the event of data leakage or data loss.
  • Inclusion of data security measures: To incorporate data security measures into procurement processes and contractual terms and conditions with business partners.
  • Reinforcement of data leakage prevention measures: To strengthen data protection through the deployment of data loss protection (DLP) tools.
Risk issue: Treatments of suppliers’ workers

Management measures

  • Complaint and Violation Checks: RATCH conducts background checks on suppliers regarding labor complaints, illegal employment, and the use of child or forced labor to identify and assess potential human rights risks.
  • Human Rights Policy Review: RATCH screens suppliers based on their publicly disclosed human rights policies or practices as part of the supplier pre-registration and selection process.
  • Worker Information Collection: RATCH requires suppliers to provide worker information for each assigned job in order to verify the legality of employment.
  • Migrant Worker Document Verification: RATCH verifies migrant worker registrations and legal work permit as part of the supplier screening process.
Risk issue: Occupational health and safety

Management measures

  • Labor Law Compliance Checks: RATCH reviews suppliers’ compliance with labor laws and relevant regulations to ensure adherence to legal requirements.
  • Safety Record Checks: RATCH evaluates suppliers’ safety records to identify past accidents or non-compliance with safety requirements.
  • Orientation and Job Risk Assessment: RATCH organizes safety orientation and conducts joint job risk assessment prior to the commencement of work to prevent and reduce work-related risks.
  • Safety Equipment Requirements: RATCH requires suppliers to provide appropriate personal protective equipment (PPE), which is specified as a contractual requirement.
  • High-Risk Job Insurance Provision: RATCH requires suppliers to provide insurance coverage for workers performing high-risk jobs, such as work in confined space, work at height, or work in high-temperature environment.

Employee-related Human Rights Impact Assessment

In 2023, RATCH conducted the employee-related human rights impact assessment, to affirm the 2022 risk assessment results. The activity in 2023 entailed the employees of the Company and operational controlled entities as they are considered the most important internal rights-holders. It served as a review of the latest assessment of impacts on employees and the evaluation of the efficiency of current actions and preventive measures.

The assessment was conducted through an opinion survey involving employees in all business functions working in Thailand and abroad.

Steps of Human Rights Impact Assessment

Steps of Human Rights Impact Assessment
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Scope of Employee-related Human Rights Impact Assessment

Mapping of sample groups: The sample groups involved the employees of RATCH and operational controlled entities, separated into 5 groups according to the nature of their business units' operations. Such as fossil fuel power plants, renewable power plant, infrastructure, electricity-related and energy and head office. The sample size was based on a scientific method, to achieve an appropriate number of samples and complete representation of each business group. There were 645 respondents in total.

Scope of the survey: Involving employees working in Thailand, Lao PDR, Vietnam, Indonesia, Singapore and Australia.

Scope of the assessment: The issues covered in the assessment were based on the Company’s human rights issues gathered in 2022 and extended to cover the risks in international contexts and of other leading companies. The human rights aspects covered in the assessment are as follows:

Scope of Employee-related Human Rights Impact Assessment
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Summary of Employee-related Human Rights Risk Assessment Results

Work environment Low
Occupational health and work safety Low
Freedom of association and collective bargaining Low
Discrimination and intimidation Low
Illegal workforce Low

The assessment of human rights risks on the employees of RATCH and controlled business entities in 2023 showed the low level of risks in all aspects; work environment, occupational health and work safety, freedom of association and collective bargaining, discrimination and intimidation, and illegal workforce. Nevertheless, RATCH took employees’ recommendations into consideration and outlined additional actions aside from the prescribed prevention and control measures. The actions implemented in 2024 are summarized below:

Recommendations Continuous communications on the Human Rights Policy and guidelines through communication channels for employees’ engagement in the prevention of internal violation
Action in 2024
  • Communicated the Human Rights Policy to the employees of 3 operational controlled business entities in Thailand and 3 in Lao PDR via meetings, talks and discussions, to ensure their understanding in the Company Group’s human rights and sustainability operations for their cooperation in preventing violations across the supply chain of each entity.
  • Increased communications frequency and channels in additional languages to reach employees at all operating sites, to ensure the understanding in the same direction among the Company Group’s employees.
  • Organized an employee training on human rights, attended by 24 participants, focusing on basic knowledge about international human rights principles, the UN Guiding Principles on Business and Human Rights (UNGPs), and the integration of human rights management into the operations. The post-training evaluation showed 27.27% demonstrated the highest level of increased knowledge and understanding and 54.55% gained a high level, and 18.18% exhibited a moderate level.
Recommendations Inspection of work condition; and review of pay, compensation and welfare for more fairness and suitability to each employee’s job description/performance as well as continuous increases in the cost of living
Action in 2024
  • Reviewed and adjusted welfare, ensuring it was equitable, fair and suitable to each employee’s job description/performance and the current cost of living.

    1. Increased the annual leave for employees with more than 10 years of working period from 10 days to 15 days and the rights to forward unused annual leave to the next year. Cumulative annual leave is capped at 20 days.

    2. Raised the allowance by THB 5,000 for dental care, eye care, vaccination, traditional Thai medicine/alternative medicine treatment, and treatments for mental illnesses for employees at all levels.

    3. Adjusted the performance evaluation criteria for employees in the Vice President level and lower. To make them fairer to all despite different lines of command and job descriptions, the criteria give scores according to their responsibilities at the enterprise, function, department, division, individual levels, as well as their engagement and behaviors.
Recommendations Safety culture for employees’ awareness and strict compliance with the Company’s safety and occupational health policy as well as safety measures
Action in 2024
  • Repeatedly emphasized the inspection of machinery/ equipment and personal protection equipment (PPE) prior to the start of work, to maintain them in good and ready-to-use condition and make a change in due time, as accidents are mostly caused by negligence.
  • Made safety one of the employee performance evaluation indicators.
  • Consistently organized safety training for all employees across the organization and increased the intensity and frequency for job operators with high-risk jobs or working in risk areas.
Recommendations Non-discriminatory treatment, fight against harassment, the diversity policy, the communications of complaint channels to all employees and assurance of complainant protection and fair investigation/correction of complaints
Action in 2024
  • Communicated the complaint channels to all employees as well as the complainant protection measures as prescribed in the Code of Conduct.
  • Allowed complainants to remain anonymous to ease their concerns about negative impacts.
  • Improved the complaint-handling procedure in the Code of Conduct and reviewed the Company’s regulations. All employees shall study and understand them and sign their acknowledgements.
Recommendations Protection of employees from the repercussions of exercising their freedom of association and collective bargaining and from employment of illegal labor
Action in 2024
  • Encouraged voluntary association through various activities like sports and music clubs.
  • Allowed employee to submit their recommendations on welfare improvement through the Welfare Committee’s employee representatives, so that the recommendations are tabled for further discussion and negotiation with the employer’s representatives for a better quality of life and a happy and safe work environment.
Additional measures to employee-related human rights risks
  • Outline the approaches to communicate human rights policy and guidelines to the Company Group’s employees, for their comprehension and strict compliance.
  • Promote employee engagement in preventing internal violations to human rights
  • Increase communications channels at operating sites and continuously organize training on human rights for the Company Group’s employees.
  • Supervise work safety concerning the equipment, tools and work environment, by scheduling regular examination of machinery and protective personal equipment (PPE) to keep them in good and ready condition.
  • Examine the work condition and ensure compliance with the Company Group’s safety requirements and safety measures on a regular basis.
  • Organize safety training for employees on a continuous basis.
  • Establish a complaint channel and fair complainant protection measures; update relevant measures to meet legal changes and universal standards; and communicates such updates to employees to establish trust in the complaint-receiving process which will prevent violations in the forms of discrimination, intimidation, obstructed freedom of association and collective bargaining and illegal workforce.
  • Set the guidelines for a review of pay, compensation and welfare, to keep them at an appropriate level and in line with the work conditions of each employee as well as changes in social conditions/trends.

Remediation

RATCH is committed to continuously conducting human rights risk assessment whilst preparing risk mitigation and prevention measures, monitoring and reporting of performance to ensure effectiveness of its human rights management. The Group also continues to review policy commitments as well as addressing any complaints and providing effective remedy in case of violation, to relevant affected rights holders.

In case of human rights violations or adverse human rights impacts caused by RATCH’s activities, the Group will take remediation actions, which may involve compensations and other forms of remedy including: apologies, restitution, rehabilitation, financial or non-financial compensation, and repetitive prevention measures.

RATCH’s Complaint-receiving channel and issue-solving procedure is outlined below

RATCH’s Complaint-receiving channel and issue-solving procedure
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