Human Rights Risk Assessment

Human rights risk assessment has been integrated into various risk assessment processes at key stages of the Company’s business operations. These include the identification and assessment of environmental risks, as well as occupational health and safety hazard identification and risk assessment in accordance with ISO standards across all operational areas.

Human rights considerations are also incorporated into the Company’s risk assessment and internal control processes across all organizational activities. The Company provides opportunities for stakeholders who may be affected by human rights issues to express their opinions and expectations, which are taken into consideration in human rights risk assessments and in evaluating the effectiveness of impact mitigation measures.

Stakeholder feedback is gathered through various channels, including supplier and customer audits, grievance and complaint channels, Voice of Customer (VOC), and engagement with suppliers and business partners.

All identified risks are managed by the Risk Management Working Group and the Human Rights and Labor Practices Committee, which are responsible for proposing the human rights risk assessment plan covering both the Company’s internal operations and its entire supply chain for approval.

Relevant departments are required to conduct human rights risk assessments at least once a year, as well as collect and analyze the results and establish appropriate measures and management approaches. These are then presented to the Risk Management Committee for consideration.

Progress is also reported periodically to the management of each business function to ensure effective monitoring and continuous management of human rights risks.

Risk Assessment Criteria

The Company has established five levels of likelihood for the occurrence of potential events, as follows:

Level

Likelihood

Description

1

Very Low

No occurrence within the past 1 year.

2

Low

Occurs once per year and is unlikely to recur.

3

Moderate

Has occurred at least once and may occur up to 2 times per year, but can be prevented.

4

High

Occurs frequently or is likely to occur up to 3 times per year and cannot be prevented.

5

Very High

Occurs repeatedly or more than 3 times per year and cannot be prevented.

The Company has also established five levels of impact severity resulting from identified risks: Very Low, Low, Moderate, High, and Very High.

The assessment considers relevant human rights issues relating to employee rights, customer/supplier/business partner rights, and community and environmental rights. Each level of impact severity is determined based on the nature of potential impacts associated with the Company’s key operational processes. An incident may involve one or multiple human rights issues.

Where multiple issues are involved, the highest level of impact severity identified under the assessment criteria will be applied, as follows:

Employee-Related Issues

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คำอธิบาย

Level

Impact Level

Description

1

Very Low

  • No individuals are affected by any form of human rights violation.
  • No damage or loss of personal data.
  • Minor employee injury or illness that does not require absence from work.

2

Low

  • 1–2 individuals are affected by human rights violations or employee personal data breaches.
  • Employee injury or illness requiring absence from work for no more than 7 days.

3

Moderate

  • 3–4 individuals are affected by human rights violations or employee personal data breaches.
  • Employee injury or illness requiring absence from work for more than 7 days.

4

High

  • 5–6 individuals are affected by human rights violations or employee personal data breaches.
  • An employee sustains a serious injury or becomes disabled as a result of an accident.
  • Employee injury or illness is severe, requiring more than 7 days of absence from work or resulting in the loss of an organ, physical disability, or loss of work capability.

5

Very High

  • More than 6 individuals are affected by human rights violations or employee personal data breaches.
  • Severe human rights violations occur, causing reputational damage to the Company and financial loss.
  • Employee injury or illness is severe and results in death.

Customer / Supplier / Business Partner-Related Issues

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คำอธิบาย

Level

Impact Level

Description

1

Very Low

  • No individuals are affected by any form of human rights violation.
  • No damage or loss of personal data.
  • No individuals are affected by safety issues arising from the use of products or services.

2

Low

  • 1–2 individuals are affected by human rights violations or personal data breaches, or experience safety impacts arising from the use of products or services.

3

Moderate

  • 3–4 individuals are affected by human rights violations or personal data breaches, or experience safety impacts arising from the use of products or services.

4

High

  • 5–6 individuals are affected by human rights violations or personal data breaches, or experience safety impacts arising from the use of products or services.
  • The incident results in negative publicity through various media channels.

5

Very High

  • More than 6 individuals are affected by human rights violations or personal data breaches, or experience safety impacts arising from the use of products or services.
  • The incident results in widespread negative publicity through various media channels and causes financial loss to the Company.

Community and Environmental Issues

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คำอธิบาย

Level

Impact Level

Description

1

Very Low

  • No individuals are adversely affected by environmental operations impacting the community and the environment.
  • No individuals are affected by violations or non-compliance with applicable laws.

2

Low

  • 1–2 individuals are adversely affected by environmental operations impacting the community and the environment.

3

Moderate

  • 3–4 individuals are adversely affected by environmental operations impacting the community and the environment.

4

High

  • 5–6 individuals are adversely affected by environmental operations impacting the community and the environment.
  • The incident results in negative publicity through various media channels.

5

Very High

  • More than 6 individuals are adversely affected by environmental operations impacting the community and the environment.
  • The incident results in widespread negative publicity through various media channels and causes financial loss to the Company.

Risk Prioritization

The Company assesses human rights risk levels based on the Likelihood and Impact Level of potential human rights impacts. The assessment results are used to prioritize human rights risks into four levels, as follows:

Risk Level Classification

คำอธิบาย

Risk Score

Risk Level

17-25

High

10-16

Moderate

4-9

Acceptable

1-3

Low

Human Rights Risk Assessment Matrix

Column 2

Column 3

Column

Column

Column 4

Impact Severity

Likelihood / Frequency of Occurrence

Description

Description

Description

Description

Row

Very Low (1)

Low (2)

Moderate (3)

High (4)

Very High (5)

Very High (5)

5

10

15

20

25

High (4)

4

8

12

16

20

Moderate (3)

3

6

9

12

15

Low (2)

2

4

6

8

10

Very Low (1)

1

2

3

4

5

The Company determines the severity of risk impacts by ranking risk levels from low to high and establishing appropriate risk management approaches for each level, as follows:

  • Low Risk

The likelihood and severity of the event are very low and considered insignificant. No further action is required.

  • Acceptable Risk

No additional control measures are required. However, opportunities for further improvement should be considered, and the risk should be continuously monitored to ensure that the severity of potential impacts does not increase.

  • Moderate Risk

Efforts must be made to reduce the risk level by implementing appropriate risk mitigation measures within a reasonable timeframe. The effectiveness of these measures should be periodically monitored to ensure that the severity of the risk is reduced. Preventive and control measures may include the preparation of relevant documentation, preventive measures, and remediation guidelines for affected individuals.

  • High Risk

The risk must be reduced immediately, with appropriate resources and specific control measures allocated to manage the risk during the corrective and improvement process. Additional measures may also be considered to control or further reduce the risk.

Risk Assessment Results and Risk Mitigation Measures

The Company conducts human rights risk assessments and monitors its human rights performance, while also providing employees with training and awareness programs to prevent potential human rights issues and adverse impacts arising from the Company’s activities. In 2025, the Company’s human rights performance was as follows:

Target

Actions

Performance Results

Zero Human Rights Violations

  • The Company’s business operations and activities undergo human rights risk assessments covering 100% of all activities and processes.
  • Any business operations or activities identified as potentially causing human rights violations must undergo 100% investigation and remediation.
  • Human rights performance reports are presented to the Risk Management Committee and disclosed in the Company’s Annual Report.

In 2025, there were no reported incidents of or complaints regarding human rights violations, and no high-risk human rights issues were identified from the Company’s risk assessment across its business activities and value chain.

In addition, the Company has established systematic and effective human rights practices and management processes, supported by the following measures:

Issue

Human Rights Prevention and Mitigation Measures

Fair and Equal Labor Practices

  • Establish a Human Rights Policy as a framework for business practices.
  • Establish clear criteria and procedures for labor practices to ensure fair and equitable treatment of employees.

Occupational Health and Safety of Employees, Customers, Suppliers and Business Partners

  • Establish an Occupational Health, Safety and Working Environment Policy as a framework for operations.
  • Establish an Environmental Management Policy as a framework for operations.
  • Establish procedures for incident reporting, investigation and monitoring.

Protection of Personal Data of Employees, Customers, Suppliers and Business Partners

  • Establish a Personal Data Protection Policy covering customers, suppliers, business partners and employees as a framework for operations.
  • Provide employees with training on personal data protection laws and principles of information security.

Non-Discrimination against Customers, Suppliers and Business Partners

  • Establish a Procurement Policy and procurement procedures.
  • Establish a Customer, Supplier and Business Partner Relationship Management Policy.

Environmental Impacts from the Company’s Operations

  • Establish an Environmental Management Policy as a framework for operations.
  • Establish measures for monitoring environmental performance to ensure that the Company’s operations do not adversely affect the environment and surrounding communities.
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