Comprehensive Human Rights Due Diligence
We identify, prevent, mitigate and respond to any potential impacts on Human Rights in our business operations through a comprehensive due diligence process. The process involves identification and assessment of Human Rights related risks across own operations, value chain operations, and new partnerships such as mergers, acquisitions and joint ventures
The process covers the entire span of our employees, workers, suppliers, consumers and communities. In the pre-merger and acquisition stage, the process covers multiple attributes, including the country’s reputation and ongoing controversies pertaining to Human Rights such as child labour/forced labour/bonded labour, diversity, human trafficking, equal remuneration, sexual exploitation, racial/gender discrimination etc.
APSEZ’s Corporate Responsibility Committee, Corporate Social Responsibility Committee, and Stakeholders' Relationship Committee have been mandated with the task of overseeing the integration of policy commitment. These committees are also responsible for ensuring the alignment of material ESG aspects, including Human Rights, with the business strategy.
A systematic risk management process enables effective risk management at APSEZ.
- Enterprise Risk Management (ERM) framework integrates both top-down and bottom-up approaches. The bottom-up approach includes identification of risks by the employees, based on their circle of competence, and development of risk mitigation/prevention strategies by the senior management with the Board’s approval. The top-down approach involves senior management setting the risk appetite, defining risk policies, and ensuring alignment with the organization's strategic objectives. Mitigation measures are implemented by the functional teams at the site level, with oversight from the corporate team.
- Systematic periodic review is undertaken of the risk mapping to identify potential Human Rights issues. This helps us proactively address and mitigate any risks, ensuring that our operations and supply chain uphold our commitment to Human Rights. We regularly update our risk assessments, enabling us to implement necessary and timely measures to protect workers' rights and maintain high standards of safety and well-being. For example, we have implemented a security check-in process at all our operational sites to identify Human Rights risks associated with child labour and forced labour.
The Risk Management Committee identifies all potential issues, and accordingly adapts our due diligence approach to each incident based on the nature of the enquiry. Appropriate remedies are formulated and stakeholder engagements are undertaken to implement the required corrective actions in case of non-compliance. Self-Assessment Questionnaires (SAQs) help in assessing Human Rights risks in a quantitative manner, enabling the company to further strengthen its internal due diligence efforts.
We conducted the Self-Assessment Questionnaires (SAQs) for employees, suppliers, customers and the community. APSEZ reached out to all its employees with the Self-Assessment Questionnaires survey to identify Human Rights risks. Nearly 77% of the employees participated in the survey.
Heightened Due Diligence A well-defined Heightened Due Diligence process is in place and is pursued in situations of conflict and emerging Human Rights issues for the community. This is aligned to the company’s neutral approach in case of a conflict so that its activities do not influence the conflict dynamics in any manner.
Due Diligence for our Human Rights Risk Assessments
Conduct of initial SAQs, internal audits
Review of the results and risk assessment by the Risk Management Committee
Conduct due diligence of identified medium & high-risk areas
Approval of the necessary actions and remediation measures, to be implemented by the Board Committee
Implementation of corrective action and remediation by the functional team
Monitoring and communication of identified risks
Safeguarding Human Rights Across the Supply Chain
We ensure complete alignment of our suppliers to our commitment to safeguarding Human Rights. Aligned with this, we deploy an annual process to assess our suppliers on Human Rights issues. We follow a robust approach to protection against Human Rights abuses in our supply chain, covering:
- Working with suppliers to align with APSEZ’s Supplier Code of Conduct
- Assessing the Human Rights risks associated with our supply base
- Auditing supply base facilities that have a higher risk of substandard working conditions or other potential Human Rights risks
- Conducting regular trainings to build capacity, both with our suppliers and our employees, to improve the supply chain working and environmental conditions
- Collaborating with others in multi-stakeholder initiatives to develop tools and training that aid in continual improvement across the global supply chain
Our Human Rights Assessment Process is Focussed on Two Primary Objectives
Identifying Risk Areas
Pinpointing potential vulnerabilities and areas where our practices might not fully align with Human Rights regulations
Formulating Mitigation Plans
Developing strategies and actions to address and rectify the identified risk areas
| Human Rights risk assessment in last three years | % of sites subjected to Human Rights reviews or Human Rights impact assessments | Total assessed sites where risks have been identified (%) | % of the risks with mitigation actions taken |
|---|---|---|---|
| Own operations | 100% | 4.4* | 100% |
| Contractors & Tier 1 suppliers | 67% | 0.23% | 100% |
| Joint ventures | 100% | 00% | 00% |
* The identified 4.4% corresponds to the previous years, i.e. FY 2022-23 and FY 2023-24, where risks had been identified in newly acquired sites. The Group's culture, values, principles, and best practices on safety, workers’ well-being, good working conditions, and protection of workers’ rights have been progressively implemented to mitigate any risk of Human Rights violations.
In FY 2024-25, no sites were identified with Human Rights risks.
