Human Rights and Labor Practices

Importance and Mission

The significance of human rights and fair working conditions to the Group lies in its commitment to creating sustainable employment opportunities through projects, ensuring alignment with applicable labor standards, legal wage agreements, and the principle of providing living wages.

The Group recognizes the rights to association and collective bargaining, respecting and supporting human rights protection both domestically and in accordance with labor regulations in other jurisdictions. Given that the Group primarily employs local labor and operates in sectors with relatively high labor related risks, it also considers the potential for modern slavery to ensure the prevention of forced labor and human trafficking within the renewable energy sector and across its supply chain. This reflects the Group’s commitment to ethical and responsible business conduct. The UN Guiding Principles on Business and Human Rights (UNGPs) (soft law) have become increasingly influential as a foundation for national legislation that businesses must be aware of. In addition, jurisdictions where the Group operate may impose binding legal requirements (hard law) that must be complied with. Human rights risks in renewable energy projects may increase due to their direct connection to climate change issues. Although climate change obligations may not directly apply to the private sector, governments may impose requirements that hold companies accountable for reducing greenhouse gas emissions. Renewable energy projects may also have direct impacts on local communities, particularly regarding land acquisition or labor rights. Investments in wind or solar power plants may affect the rights of indigenous peoples, requiring companies to comply with national and international obligations.

Implementing comprehensive human rights due diligence provides a platform for continuous stakeholder engagement to address potential risks arising from business operations in local communities. Materials used in renewable energy projects may also pose specific challenges. Energy storage technologies such as batteries require minerals including lithium, nickel, and zinc. The extraction of these minerals is closely scrutinized due to potential impacts on labor rights and indigenous communities. In addition, the production of solar panels may expose workers to hazardous chemicals such as cadmium. Renewable energy businesses should carefully consider the sources of materials used, especially where trade control risks exist. They should also prioritize monitoring and evaluation of the organization’s human rights performance. Human rights due diligence (HRDD) in the downstream value chain also extend to the disposal of technologies that rely on these materials at the end of their lifecycle. Renewable energy projects may involve new suppliers or partners within the supply chain, whose activities may pose risks to the business. The Group’s recruitment policies and processes focus on promoting fair treatment of employees, suppliers, and contractors in accordance with relevant standards.

This includes monitoring working conditions with attention to safety, and supporting fair wages that contribute to quality of life. A responsible supply chain is also essential to long term business sustainability. To this end, the Group has established a Supplier Code of Conduct as a shared guideline for ethical practices.

SDGs in Human Rights and Labor Practices

Goals and Performance Highlights

Goals

Performance Highlights 2025

Employees

Working conditions
Health and safety
Freedom of association
Right to organize
Right to collective bargaining
Discrimination
Human rights violations
Use of illegal labor
Personal data protection

Communities

Standard of living
Health and safety
Land acquisition
Resettlement

Suppliers/Contractors

Working conditions
Health and safety
Discrimination against customers/contractors during procurement and when working on site
Personal data protection
Use of illegal labor

Customers/Consumers

Health and safety
Personal data protection

ESG Performance Data

The Group conducted comprehensive Human Rights Due Diligence (HRDD) across the entire value chain, guided by the “Protect–Respect–Remedy” framework. This process enabled the identification of 4 strategic human rights risk areas that may affect key stakeholder groups, as follows:

1. Labor & Employee Rights

Risk context: Risks related to occupational health and safety, as well as the prevention of child labor and modern slavery in construction areas.

Business case: In commercial solar rooftop installation projects, failure to comply with safety measures may lead to severe accidents involving workers and contractors, directly affecting their rights to life and safe working conditions.

Mitigation & Corrective Measures:

Preventive measures: The Group enforces an occupational health and safety management system in accordance with ISO 45001 and conducts strict risk assessments prior to commencing any work. The Group also implements a Zero‑Tolerance Policy prohibiting child labor and forced labor.
Corrective and remedial measures: A whistleblowing mechanism is in place through accessible channels such as the website, email, and telephone. Whistleblowers are protected under a Non‑Retaliation Policy to ensure they are not subject to intimidation or adverse treatment.

2. Community Rights

Risk context: Environmental impacts from project operations (such as noise, dust, and odor) and the rights of local communities to participate in the process.

Business case: In 2024, the UPT Biomass Power Plant in Nakhon Ratchasima Province received community complaints regarding smoke and dust emissions from the exhaust stack, which potentially affected community health and daily life.

Mitigation & Corrective Measures:

Immediate corrective action: The Group conducted an on‑site inspection and coordinated with government authorities. The issue was found to be caused by moisture in the fuel. The pollution‑control system was subsequently improved, bringing emission levels back within safe and compliant standards.
Long-term preventive and remedial measures: The Company approved a budget to install “a real‑time Continuous Emission Monitoring System (CEMS)” at the plant entrance to enhance transparency. In addition, the Group invested in establishing the “Romklao Wind Farm Clean Energy Learning Center” in Mukdahan Province, in collaboration with universities and local communities, to create shared value (CSV) and support long‑term community well‑being.

3. Supply Chain & Business Partners

Risk context: Risks of complicity or indirect involvement in human-rights violations through suppliers and contractors.

Business case: A global risk in the solar-energy industry relates to the use of forced labor involving Uyghur ethnic groups in the Xinjiang region for the production of polysilicon, a key raw material used in solar panels.

Mitigation & Corrective Measures:

Preventive measures: The Group enforces its “Supplier Code of Conduct” for Sustainable Business Development, requiring all new suppliers with purchase values exceeding THB 500,000 (100%) to undergo an ESG assessment.
Corrective measures: If a supplier is found to have committed a severe human-rights violation (very high level), the Group reserves the right to “suspend operations or immediately terminate the business relationship” until the supplier has implemented corrective actions and mitigated impacts to an acceptable level.

4. Customer Rights

Risk context: Safety in service usage and the protection of customers’ personal data (Data Privacy).

Business case: Risks related to the unauthorized use or disclosure of personal data or energy-usage information of business customers (such as Solar Rooftop projects), as well as accidents caused by non-standard system installation.

Mitigation & Corrective Measures:

Preventive measures: The Group issues and strictly implements its “Personal Data Protection Policy” and “Information Security Policy”, and applies the Non‑conformity and Corrective Action procedures to ensure engineering quality control.
Assessment and improvement measures: Conducting customer satisfaction surveys and establishing direct complaint channels to gather feedback for continuous improvement of energy delivery and after‑sales services.
Diversity, Equity, and Inclusion Promotion: All stakeholder groups can be confident that there is no discrimination in recruitment, human‑resource management, training, or employee capability development. The Group does not discriminate based on age, disability, gender, marital status, pregnancy or maternity, political opinion, race/ethnicity, religion or belief, sexual orientation, socioeconomic background, union membership or participation in labor‑related activities, work arrangements, family status, or any other non‑work‑related factors. In 2025, the Group employed a total workforce comprising 123 Thai employees (69.9%), 38 Vietnamese employees (21.6%), 12 Mongolian employees (6.8%), 2 Japanese employees (1.1%), and 1 Singaporean employee (0.6%).