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Human Rights Risk and Impact Assessment in Indonesia

Human Rights

In 2024, as part of our ongoing human rights due diligence efforts, the Company conducted a comprehensive human rights risk assessment as part of due diligence for our mining business in Indonesia. The assessment involved thorough data collection, including workshops, a self-assessment questionnaire, and document-based research, to identify potential human rights issues. Each issue is assessed for impact to evaluate its severity and likelihood of occurrence. The findings highlighted 6 critical risks that need to be prioritized as the highest across all or most of the sites. These include working conditions, occupational health & safety, data privacy protection, environmental health and safety, internal grievance mechanisms, and supply chain management or business partner relationships. Following this impact assessment, we developed a targeted mitigation plan for each identified risk to effectively address and reduce its potential negative consequences.

Human Rights Principle

Human Rights Issue

Rights-holder/ Vulnerable Group

Mitigation Plan

Labor rights

Working conditions

Occupational health & safety

Data privacy protection

Employees and workers, third-party labor, employees with chronic diseases, migrant employees and workers, elderly employees and workers, women, workers with disabilities

• Engaging in labor rights communication with relevant rights-holders to ensure compliance with legal requirements and enhance overall performance

• Conducting assessments to ensure that third-party labors and vulnerable groups receive equal treatment and rights as fully outlined in the Company’s policy

• Developing training programs for management, employees, workers, and contractors, including third-party labor at the site to raise awareness and promote effective response

Environment

Environmental health & safety

Employees and workers, local communities, contractors, women, children, elderly individuals, people with disabilities

• Establishing two-way communication with key rights-holders such as local community leaders to collectively identify needs, concerns, and expectations

• Conducting a comprehensive assessment of policies and processes to engage with affected rights-holders, identify actual impacts and root causes

Grievance mechanisms

Internal grievance mechanisms

Employees and workers, women, children, elderly individuals, people with disabilities, migrant workers

• Developing awareness campaigns and training to educate employees, workers, and vulnerable groups about the available grievance channels. Use various formats such as workshops, seminars, and informational brochures to ensure that rights-holders are aware and know how to use the channel effectively

Value chain

Supply chain management or business partner relationships

Third-party labor, women, young, elderly individuals, people with disabilities

• Conducting assessment of current policies, processes, and business practice for third-party risk assessment throughout the entire third-party engagement lifecycle

• Incorporating ESG criteria into supplier selection

• Communicating the supplier code of conduct to contractors

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