Key Human Rights Risks at APSEZ
The following Human Rights issues have been identified as priorities to be addressed across our businesses and value chains:
Forced Labour
Child Labour
Fair Wages
Equal Remuneration
Working Hours
Health & Safety
Harassment
Discrimination
Eradicating Forced Labour & Child Labour
We implement comprehensive policies and enforce stringent measures to guarantee that no forced or child labour occurs at any of our operational sites.
Defining Forced Labour
All work or service that is exacted from any person under the threat of a penalty, or for which the person has not offered himself or herself voluntarily.
Indicators
Unreasonable fees leading to debt bondage, deception, restriction of movement, isolation, abuse of vulnerability, intimidation and threats, abusive living and working conditions; withholding of wage, excessive overtime, and retention of personal document.
Defining Child Labour
Work that deprives children of their childhood, their potential and their dignity, and that is harmful to their physical and mental development.
Indicators
Mentally, physically, socially or morally harmful to children; interferes with their schooling by depriving them of the opportunity to attend school; obliges them to leave school prematurely; or requires them to attempt to combine school attendance with excessively long and heavy work.
Potential Impact Across the Value Chain
- Communities and supply chains, such as in warehouse operations, transportation, construction, and upstream material
- Vulnerable groups are migrant workers, agency workers, third party employees, temporary workers and self-employed, women and children
APSEZ Policies to Address the Impact
Read furtherCode of Conduct
Read further Supplier Code of Conduct
Read furtherGuidelines for Human Rights
Prevention Strategy
We actively support our suppliers in formulating plans to reduce the risk of forced labour and child labour. We are engaged in building the capability of our suppliers to understand what a responsible recruitment system looks like, and how to properly implement it. They are encouraged to adopt:
- A Responsible Recruitment Policy that clearly articulates the supplier’s responsible hiring commitment, setting expectations internally and externally for agencies, sub-contractors, and importantly their other suppliers (our tier two suppliers)
- Clear contracts with agencies that include clauses relating to the prohibition of passport retention, payment of recruitment fees and prohibition of child labour
- Training for management and workers to understand the key components of responsible recruitment and its importance, besides providing transparency for workers on their rights
- Grievance mechanisms, allowing workers the opportunity to confidently raise any concerns they may have
- Background verification for each of the employees and workers
- Mandatory government issued ID proof checks
Earning Fair Wages and Equal Remuneration
We have established policy guidelines to ensure fair wages for all employees and workers, as well as equal remuneration for similar or equivalent work throughout the organisation.
Defining Fair Wages
A wage level that covers the workers’ and their families’ basic needs and provides some discretionary income
Defining Equal Remuneration
Refers to the principle that women and men should receive equal pay for work of equal value; ensures that individuals performing identical or similar jobs receive the same pay; also extends to different jobs that are evaluated to be of equal value based on objective criteria such as skills, qualifications, working conditions, levels of responsibility, and effort required
Potential Impact Across the Value Chain
- Primarily in supply chains
- Vulnerable groups found in low skilled, labour-intensive segments, as well as linked to part-time work and outsourcing
Prevention Strategy
- Prior to suppliers’ onboarding, ensuring they comply with all applicable laws and regulations for minimum wages
- Remunerations designed to adhere to the Government of India’s Minimum Wages Act, 1948 and Wage Act 2019
- Monitoring our entire compensation structure to ensure that all employees are paid appropriately
APSEZ Policies to Address the Impact
Read furtherSupplier Code of Conduct
Read furtherGuidelines for Human Rights
Ensuring Reasonable Working Hours
Cognisant of the importance of work-life balance, we take all steps to ensure that reasonable working hours are followed at our sites and operational areas.
Defining Reasonable Working Hours
Working hours that comply with national law and ILO conventions, or connected to the worker’s right to health and family life
Potential Impact Across the Value Chain
- Various supply chains, e.g. in warehouse operations, construction and transportation
- Vulnerable groups include migrant workers, agency workers, temporary workers and self-employed
Prevention Strategy
- Adherence to regulations that limit the maximum number of hours an employee can work per week, e.g. in India, Working Time Directive limits the average working week to 48 hours
- Providing breaks and rest periods during work hours as required by regulations
- Offering flexible working hours to accommodate employees' personal needs and improve work-life balance
- Maintaining accurate records of employees' working hours to ensure compliance with labour laws
APSEZ Policies to Address the Impact
Read further Working Hours Guidelines
Read furtherSupplier Code of Conduct
Read furtherGuidelines for Human Rights
Promoting Health and Safety
At APSEZ, the health and safety of our workforce is a top priority, shaping our core operational policies and actions.
Defining Health & Safety
Encompasses a broader perspective, emphasising the right of every individual to a safe and healthy environment; includes not only workplace safety but also access to healthcare, clean water, and a safe living environment
Potential Impact Across the Value Chain
- Own operations, mergers & acquisition, local communities, and value chains
Prevention Strategy
- Every individual has the fundamental right to quality healthcare. The Adani Foundation is dedicated to ensuring that community households have access to top-notch health facilities right at their doorstep, fostering a healthier society
- Promoting inclusive practices that consider the needs of vulnerable groups, such as women, children, and individuals with disabilities, and ensuring equitable application of health and safety measures
- Conducting an internal audit to check the working environment of the operating sites, and ensuring the availability of safe and clean drinking water for entire workforce
- Providing health & safety trainings to the workforce related to their functional areas
APSEZ Policies to Address the Impact
Read furtherOccupational Health and Safety Policy
Read furtherGuidelines for Human Rights
Curbing Discrimination & Harassment
We have clear anti-discrimination and anti-harassment policies in place to ensure fair and equal treatment.
Defining Discrimination
Unfair or humiliating treatment on the grounds of gender, sexual orientation, race, colour, age, pregnancy, marital or social status, religion, political opinion, nationality, ethnic origin, disease or disability
Defining Harassment
Violence and harassment directed at persons because of their sex or gender, or affecting persons of a particular sex or gender disproportionately, and includes sexual and non-sexual harassment
Potential Impact Across the Value Chain
- Own operations and value chains
- Unconscious bias or discrimination ingrained in the work culture or discriminatory conducts of individuals
- Vulnerable groups include women, local communities, migrant workers, security personnels, LGBTQIA+ and minority groups
Prevention Strategy
- Taking proactive measures to nurture a safe and inclusive work culture across the organisation to ensure a workplace devoid of discrimination or harassment (including sexual and non-sexual harassment and exploitation)
- Implementing zero-tolerance policy, aligned with the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013, applicable to all employees
- Timely corrective or disciplinary action in cases of discriminatory behaviour or harassment
- Ensuring regular audits of our suppliers with respect to their policy commitment and systems & processes aimed at the prevention of harassment and discrimination
- Providing employees with multiple avenues, across regions and locations, to report their grievances, including the line manager, the Group Monitoring Committee (GMC) a centralised monitoring committee at the Group level, or the respective Internal Complaints Committee (ICC); Investigations and disciplinary action, including termination, for guilty individuals, taken by GMC/ICC, as relevant
- Organising regular awareness workshops, group meetings, online training sessions, and other programmes on preventing sexual and non-sexual harassment; Providing training in discrimination and harassment to all employees as part of the Code of Conduct
APSEZ Policies to Address the Impact
Read furtherCode of Conduct
Read furtherSupplier Code of Conduct
Read furtherHuman Rights Guidelines
Read further Diversity, Equality & Inclusion Guidelines
In FY 2024-25, 86% employees received training on Human Rights protection & issues like discrimination and harassment.
Group Monitoring Committee (GMC)
Overview
- Includes key stakeholders such as the Site Head, HR Head, HSE Head, Head of Security, Head of Corporate Affairs, and employee representatives
- Plays a vital role in overseeing policy implementation
Grievance Redressal Committees (GRCs)
- Each site's GRC is a subset of the GMC
- Consists of key stakeholders among on-roll employees at the site level
- Reflects commitment to inclusivity and transparency in policy oversight
- Ensures diverse perspectives in decision-making, fostering a comprehensive and fair approach to addressing workplace issues
Policy Oversight
- GMC ensures the implementation of policies
- Offers guidance to ensure continual compliance with established standards
- Crucial for maintaining a work environment, free from discrimination and harassment
Suo Moto Review
- In extreme circumstances, the GMC has the authority to initiate a suo moto review of an investigation or enquiry conducted by the ICC
- Ensures a thorough examination of cases and reinforces commitment to fair investigations
Monitoring of ICC Functions
- Actively monitors and reviews the functions of the ICC and GRC
- Acts as a facilitator, providing avenues for aggrieved individuals to register and escalate complaints if not adequately addressed by the local ICC
Escalation Process for Discrimination and Harassment Incidents
A robust Incident Reporting Procedure for Discrimination and Harassment process is followed at APSEZ, underscoring our strong adherence to Human Rights. The Grievance Management System (GMS) helps individuals in resolving Human Rights linked issues. It provides a transparent and effective platform for reporting complaints on various Human Rights concerns, including labour practices, ethics, and discrimination. The process is designed to ensure fair and timely resolution of grievances in the spirit of confidentiality.
Anyone affected by or interested in the company, such as workers, partners, clients, community members and other stakeholders, can report their concerns on the grievance section of the company’s website.
Grievance registers and complaint boxes are strategically placed across sites and locations to strengthen the reporting system, and to encourage stakeholders to express their concerns and seek resolution in a safe and sympathetic environment.
A dedicated email address – grievance.apsez@adani.com, has been provided for individuals, including employees and stakeholders, to report any grievances, thus enhancing the accessibility and efficiency of grievance handling and resolution.
