Reviewing Human Rights Disclosure of Leading Companies in Asia

Table of Tables

Table of Figures

Acknowledgements

This research, Reviewing Human Rights Disclosure of Leading Companies in Asia, would not have been possible without the support of Oxfam Novib under the ‘FAIR for ALL’ program and the Dutch Ministry of Foreign Affairs.

We extend our sincere appreciation to the authors of key reports from Oxfam in Asia and its network of partner organizations, whose in-depth research on supply chain transparency and human rights challenges provided a critical foundation for this study.

We also acknowledge the significant contribution of the World Benchmarking Alliance (WBA), particularly their pioneering work on the Corporate Human Rights Benchmark (CHRB), which served as a key reference point for the assessment frameworks used in this research.

Finally, we express our deepest gratitude to our research team for their exceptional dedication and meticulous efforts in data collection, analysis, and synthesis. Their commitment to rigorous research methodologies and their insights were instrumental in shaping the findings and recommendations presented in this report.

Sal Forest Co., Ltd. March 2025

Executive Summary

Global supply chains pose intricate challenges due to the diverse human rights practices across countries. Acknowledging this complexity, human rights due diligence (HRDD), as outlined in the United Nations Guiding Principles on Business and Human Rights (UNGPs), stands out as an international standard for safeguarding human rights. Business organizations are expected to respect human rights throughout their operations, including in their supply chains.

This research aims to examine how business organizations, operating across diverse supply chains, align with human rights principles through the implementation of HRDD practices. The research team reviewed the reports of Oxfam’s partners to summarize pertinent supply chain characteristics and key challenges highlighted in the following supply chains: maize, medicinal plant, and mining in Myanmar; rice, cashew, and rubber in Cambodia; seafood in Thailand; and sugar in India. The research team then examined human rights policies of the top 5 companies within each supply chain, comparing them to the scoring criteria of World Benchmarking Alliance’s Corporate Human Rights Benchmark (CHRB).

Based on our comparison of companies’ relevant human rights policies and CHRB criteria, we found that no top 5 companies in the following supply chains discloses any human rights-related policies: cashew in Cambodia, mining in Myanmar, and rubber in Cambodia.

Several top 5 companies in the rice supply chain in Cambodia, the sugar supply chain in India, and the medicinal plant supply chain in Myanmar disclose their commitment to human rights. However, these companies disclose only high-level and blanket commitment to respecting human rights, with some lacking any reference to relevant UN conventions or standards such as the UNGPs. We did not find any disclosures beyond high-level commitments from these companies in both supply chains.

The supply chains for which the top 5 companies disclose the most human rights-related policies are the seafood supply chain in Thailand and the maize supply chain in Myanmar. We reason that this is primarily because 1) severe human rights violations in Thailand’s seafood supply chain, particularly involving human trafficking, have been exposed in global news since 2014, prompting major exporters to materially improve their human rights practices, and 2) top companies in both supply chains are major exporters with a global reach, meaning that they are under pressure to apply their group-wide human rights policies across the board to all supply chains.

However, the research team found that among companies that publish human rights policies and claim that they have adopted UNGPs, there is a significant disclosure disparity

between companies. For example, in the seafood supply chain of Thailand, although Charoen Pokphand Foods (CPF), Kiang Huat Sea Gull Trading, and Thai Union Group all specify that they set up a specific committee to formulate sustainability strategy and/or risk management, only Thai Union specifies that the process of materiality assessment is informed by 12 stakeholders, including daily/migrant workers and NGOs. This implies that the process is probably “informed by the experiences of affected stakeholders or external human rights experts” as stipulated in this CHRB criteria.

Among the top 5 maize companies in Myanmar, only CPP Myanmar (part of CP Group from Thailand) and Myanmar Awba Group disclose human rights-related policies that are at least partially aligned with CHRB criteria. However, the grievance mechanism of CPP Myanmar is much less clear and inclusive than that of CPF, a major CP Group company. Meanwhile, Myanmar Awba Group discloses its whistleblowing handling process in some detail but does not extend the process to handle human rights-related grievances.

Chapter 1 Introduction

Background and Rationale

In the current landscape, global supply chains pose intricate challenges due to the diverse human rights practices across countries. Acknowledging this complexity, human rights due diligence (HRDD), as outlined in the United Nations Guiding Principles on Business and Human Rights (UNGPs), stands out as an international standard for safeguarding human rights. Business organizations are expected to respect human rights throughout their operations, including in their supply chains.

Numerous international organizations, such as the Organisation for Economic Co-operation and Development (OECD) and International Labour Organization (ILO), have embraced HRDD practices, integrating them into their standards. Some countries, including France, Norway, and Germany, have enacted laws and mandatory measures to enforce human rights due diligence. Additionally, the European Union (EU) is actively developing regional legislation on HRDD. These examples underscore the increasing importance of HRDD.

This research aims to examine how business organizations, operating across diverse supply chains, align with human rights principles through the implementation of HRDD practices.

Objective of the research

● To examine human rights practices of companies in various supply chains, based on the reports of Oxfam’s partners.

● To assess the human rights policies of the top 5 companies within each supply chain.

Research Methodology

The research team applied the main research methodologies as follows:

1) Literature review

1.1) The research team reviewed the reports of Oxfam’s partners to summarize pertinent supply chain characteristics and key challenges highlighted in the following reports:

● Guidelines for Transformational Partnerships and Women’s Economic Empowerment (Institute for Social Entrepreneurship in Asia, 2021)

● Value Chain Study for Corn in Bamaw, Kachin State (Fresh Studio, 2023)

● Medicinal Plant Documentation in Pawkhlo: Phase 1 Report (Marshall Kramer, n.d.)

● Ground-based Situational Analysis of Kachin State’s Mining and Jade Industry following the Coup (K-SAG, 2023)

● Study of the Impacts of the Military Coup on Natural Resource Extractive Sectors in Kachin State (n.d.)

● Ecosystem and Women’s Participation in the Implementation of Contract Farming in Cambodia: The Cases of Rice, Cashew, and Rubber (The NGO Forum on Cambodia, 2023)

● Strengthening the Ecosystem Conducive to the Effective Implementation of Contract Farming (The NGO Forum on Cambodia, n.d.)

● Precarity and the Pandemic: A Survey of Wage Issues and COVID-19 Impacts among Migrant Seafood Workers in Thailand (Oxfam International, 2021)

● Human Cost of Sugar: Living and Working Conditions of Migrant Cane-cutters in Maharashtra (Oxfam India, 2020)

● Human Cost of Sugar: A Farm-to-mill Assessment of Sugar Supply Chain in Utter Pradesh (Oxfam India, 2018)

1.2) The research team conducted literature review on human rights principles and practices which are accepted as international standards.

● United Nations Guiding Principles on Business and Human Rights (UNGPs)

● Human rights due diligence (HRDD)

● Corporate Human Rights Benchmark (CHRB)

2) The research team examined human rights policies of top 5 companies within each supply chain. The companies were selected in terms of market share or the number of workers, depending on available information.

3) The research team assessed human rights policies of the companies compared to CHRB criteria.

Chapter 2 Key challenges and findings in supply chains

The research team summarized pertinent supply chain characteristics and key challenges highlighted in each report of Oxfam’s partners. The research team also selected the top 5 companies within each supply chain in terms of market share.

Agricultural value chains in ASEAN

Institute for Social Entrepreneurship in Asia (ISEA) published a research “Guidelines for Transformational Partnerships and Women’s Economic Empowerment” in October 2021. The research aims to study and propose a set of guidelines that support and incentivize agricultural value chain practitioners to engage women and men small-scale producers in ways that would empower them and transform their lives, livelihoods, and communities in ASEAN and its member states.

To be noted, the research team did not map the supply chain for this report because the scope of the report is too broad.

Key issues found in the report

ISEA’s report focuses on agricultural value chains (AVC) in ASEAN which have huge potential to contribute to address poverty and inequality in the region. The research team summarized key issues from ISEA’s report as follows.

Poverty in agricultural sector in ASEAN

☛ The agriculture sector significantly contributes to employment in ASEAN member states. Women and men small-scale producers are the pillars of the agriculture sector. However, poverty remains significantly higher among them and is expected to increase with the overall impact of COVID-19 on the region’s economy.

Gender inequality

☛ Women play an important role in AVC in ASEAN. The report stated that 48–75 percent of employed women working in agriculture sector in Cambodia, Myanmar, Lao PDR, and Vietnam. Moreover, one-third of ASEAN workers in agriculture are women. This figure could be higher as women are usually part of unpaid family labor.

☛ Almost 60 percent of women are paid less than men. Besides, women have other barriers to participations. For example, women are often limited by unpaid care and domestic work responsibilities. Women have limited access to resources or credit. The report states that only 13 percent of women in ASEAN own agricultural land.

Maize in Bamaw, Kachin state, Myanmar

In May 2023, Fresh Studio published Value Chain Study for maize in Bamaw, Kachin state, Myanmar. The research aims to examine the cost and benefits of maize farming, evaluate the market flow among market players, and propose project interventions aimed at supporting the Alinn Bamaw community’s farmers in Kachin area.

Figure 1 Maize value chain in Bamaw, Kachin state, Myanmar

Harvest/ Production Aggregation Dry Processing Distribution and Marketing

Activity

Actor

Farmers

• Seed

• Fertilizers

• Agrochemicals Domestic Export

Township collectors Wholesaler Processors

Consumers

Township broker Wholesaler Food service industry

Source: Value Chain Study for Corn in Bamaw, Kachin State (Fresh Studio, 2023)

Key issues found in the report

The research team summarized key issues from the report as follows.

Limited knowledge transfer

● Farmers commonly share their knowledge only through discussions with other farmers and field staff from the trade company. There is no appropriate channel for farmers to learn about new agricultural methods and practices. Additionally, there is a lack of educational organizations that can provide agricultural knowledge to the farming community.

Exchange rate fluctuations

● Exchange rate fluctuations in Myanmar result in increased input costs. Farmers have consequently reduced their utilization of these inputs, such as fertilizer, which has nearly doubled to triple in the past two years due to issues related to currency exchange rates and transportation costs. This has led to farmers applying a lower amount of fertilizer compared to what is necessary for cultivation, potentially leading to soil degradation in the long term.

Limited access to loans and high interest rates

● Farmers face challenges in accessing microfinance loans because they do not have land title as collateral for the financial institution. As a result, most farmers tend to borrow from traders to meet their input needs. If farmers borrow from other sources that do not require a land title, interest rates can range from 5-10 percent with gold or other assets used as collateral. If farmers cannot provide collateral, the interest rates can go up to 10-20 percent.

● Farmers, who purchase seeds and fertilizers with loans from traders, are expected to pay back the loans after harvesting their crops. This leaves them no chance to wait for better crop prices before they settle their debts.

Limited irrigation facilities

● Maize production largely depends on the monsoon season, which accounts for approximately 90 percent of the total production due to limited irrigation facilities in Myanmar. Farmers who have access to irrigation facilities have higher yields and better quality compared to corn produced during the monsoon season.

Major maize companies in Myanmar

To consider the policies of major maize companies in Myanmar, the research team used the list of Maize seed company that provided by Mordor Intelligence, a market research organization. Mordor Intelligence listed five companies that hold substantial market share and actively participate as key players in the maize seed market in Myanmar (Mordor Intelligence, 2023).

● Charoen Pokphand Produce Myanmar Co., Ltd.

● Myanmar Awba Group Co., Ltd.

● Corteva Agriscience (Myanmar) Co., Ltd.

● East West Seed Myanmar Co., Ltd.

● Limagrain Myanmar Co., Ltd.

In addition, the above companies are seed business license holders in Myanmar that have been certified by the Ministry of Agriculture Livestock and Irrigation Seed Division of

Myanmar (Department of Agriculture, 2022). Thus, the research team chose 5 companies from the list above to consider their policies which are shown below.

☛ Charoen Pokphand Produce Myanmar Co., Ltd. (CPP Myanmar)

Charoen Pokphand Group (CP group) is the largest player in the maize seed market in Myanmar, with a significant market share, and has also been the most active player in the market (Mordor Intelligence, 2023). The research team found human rights policies and practices of CP group which is CPP Myanmar’s parent company. However, the research team could not find CPP Myanmar’s human rights policies.

☛ Myanmar Awba Group Co., Ltd.

Established in 1995, Awba is Myanmar’s largest manufacturer and distributor of agricultural technology with a focus on crop protection, crop nutrition, and high-quality seeds (Awba Group, 2023). The research team found that the company is committed to respecting human rights. The company has assessed risks related to human rights. Also, there is a grievance policy for the company’s workers.

☛ Corteva Agriscience (Myanmar) Co., Ltd.

Corteva Agriscience (Myanmar) Co., Ltd. operates as a subsidiary of Corteva Agriscience, an American company specializing in agricultural chemicals and seeds. This subsidiary has been instrumental in the development and distribution of maize seeds to smallholder farmers in Myanmar. Additionally, the company focuses on environmental issues such as sustainable innovation, biodiversity, climate, diversity, and equality (Corteva, 2023). However, the research team could not find human rights policies and practices of the company.

☛ East West Seed Myanmar Co., Ltd.

East-West Seed is a company that develops tropical plant varieties for smallholder farmers. The company initiated developing and improving plant varieties in Southeast Asia in 1982 and began operations in Myanmar in 2009, with a particular focus on researching and developing maize seeds as part of the company’s product (East West Seed, 2023). However, the research team could not find human rights policies and practices of the company.

☛ Limagrain Myanmar Co., Ltd.

Limagrain Myanmar Co., Ltd. operates as a subsidiary of Limagrain Field Seeds, a company specializing in the supply of seeds, including maize, wheat, sunflower, and others, for farmers. The company commenced its expansion into the seed market in Southeast Asia in 1997. In Myanmar, the company focuses on the distribution of maize seeds (Limagrain Field Seeds, 2023). However, the research team could not find human rights policies and practices of the company.

Mining in Kachin State, Myanmar

In April 2023, K-SAG published research on the impact of the military coup on the mining sector in Kachin State. The research focused on the period after the coup, emphasizing the adverse effects on the environment and local livelihoods.

The mining value chain shown in Figure 2 illustrates the example of gold mining value chain from upstream to downstream. The Figure 2 illustrates the process of gold production and distribution. Artisanal miners extract gold and sell it to local buyers. A middleman may be involved in facilitating sales to a gold buying house. Alternatively, a foreign mining company may conduct industrial gold mining. The gold buying house then sells to gold export companies, which provide gold to international refineries for final distribution and marketing.

Actor Activity Gold Mining

Artisanal Gold mining

Artisanal Miners Local Gold Buyer Middleman

Industrial gold mining

Foreign Mining Company

Market/Intermediaries Distribution and Marketing Gold Buying House Gold Export Companies International Gold Refineries

Source: Gold from children’s hands: Use of child-mined gold by the electronics sector (Schipper, Haan, & Dorp, 2015)

Despite the ongoing political crisis and armed conflicts following the coup in Myanmar, there has been a notable increase in natural resource extraction in Kachin State, including mining for jade, amber, gold, rare earth minerals, and illegal timber logging. The weakened rule of law and enforcement due to the coup have led to a tenfold surge in illegal gold mining, even among those with licenses who openly violate regulations. The involvement of military-affiliated companies, drug lords, and ethnic armed organizations has resulted in environmental damage, labor rights issues, and an increase in drug abuse as listed below.

Figure 2 Gold mining value chain in Myanmar

Key issues found in the report

The research team summarized key issues from K-SAG’s report as follows.

Informal taxation and lack of regulation

● The extractive industry in Kachin State operates under informal taxation practices. Jade and amber miners are obligated to pay informal taxes to the Tatmadaw (Myanmar’s armed forces) and the Kachin Independence Army (KIA) for their operations.

● The industry’s potential for high revenue, corruption, and a lack of transparency have resulted in minimal revenue realization. This lack of regulation and involvement of military-affiliated entities perpetuates inequality.

Environmental degradation

● Two-thirds of gold miners in Kachin State operate in conservation areas, watershed areas, and rivers leading to damage to natural habitats, river depletion, and land degradation. Deforestation is one of the most significant impacts, as trees are cut down to make way for mining activities. This caused soil erosion and sedimentation, leading to further environmental degradation. In addition, the use of heavy machinery, for example, backhoes and water cannons on riverbanks and streambanks has led to water pollution such as the alluvial sand flowing downstream causing damage to local farmland, local fish species, and drinking water sources.

● They also intentionally allow their waste to contaminate the farmland of the local people, making it impossible for them to continue farming. Consequently, they are forced to sell their land to the gold miners for mining purposes, leaving local communities’ helplessness.

Limited job opportunities/labor rights

● Ongoing political instability and the pandemic have severely limited job opportunities in Kachin State. Those with close relationships with local authorities and access to capital are deepening inequality in job opportunities.

● The fear of being forcibly recruited by the KIA discourages many Kachin people from participating in the industry, leading to higher unemployment rates and increased difficulties for local communities.

● The research also states that female and child laborers are paid less than their male counterparts, earning only 70 percent of what men receive.

Increased drug abuse

● In some areas where illegal mining takes place the sale of drugs is rampant. Some mine owners even provide drugs to addicts. Additionally, two-thirds of laborers in some areas are paid for drugs like opium or methamphetamine (locally known as “Yaba”). This unregulated drug trade poses a threat to the safety of individuals in these areas, particularly youth, as drug sales are now conducted openly in the streets due to the absence of law enforcement.

Human rights violation

● Since the coup, restrictions have been imposed on residents passing through security gates, causing inconvenience. Arbitrary actions by Shanni militia members, including beatings and harassment, worsen the situation. These actions further distress and harm struggling communities in the Indawgyi region, violating their human rights.

Mining companies in Myanmar

To evaluate the policies of mining companies in Myanmar, the research team utilized the list of mining companies provided by the Myanmar Business Directory (Myanmar Business Directory, n.d.), a comprehensive resource for business information. The result showed that there are 226 mining companies on the website, but only 7 of these had their own website. The names of 7 mining companies are listed below.

● 24 Hour Company Limited

● A1 Mining Co., Ltd.

● Developers Entrepreneurs Liaison Construction Organizers Ltd (Delco)

● Georesources Mining Co., Ltd.

● PanAust Limited

● UMG Group

● Jewellery Luck Co., Ltd

No information was found on the market share or export values of these companies. Thus, the research team randomly picked 5 companies from the list above as representative of mining companies in Myanmar to explore their policies as follows.

☛ A1 Mining Co., Ltd.

A1 Group of Companies, initially established as a construction company in 1990, has grown to become one of Myanmar’s leading construction entities. Their success and financial security in the construction industry have enabled them to diversify their business into other sectors including the mining sector through A1 Mining Co., Ltd. (A1 Group of Companies, n.d.).

A1 Mining Co., Ltd., a subsidiary of A1 Group of Companies, has been allocated a granite quarry in Yebyu Township, Tanintharyi Region. They plan to export granite for building and road construction, with over 100 million tons of deposits. Additionally, they are exploring tin and tungsten in Karathuri Township, Kawthoung District, in collaboration with the Ministry of Mines and DGSE Geologist team. The company is also interested in joint foreign partnerships for the exploration and extraction of these resources, including a project near the Thailand-Myanmar border (A1 Group of Companies, n.d.). However, the research team did not find human rights policies and practices of the company.

☛ Developers Entrepreneurs Liaison Construction Organizers Ltd (Delco)

Delco, as part of the Panwa Group of Companies, is Myanmar’s largest mining, mineral processing, and metallurgical company, specializing in tin-tungsten and mixed ores. They operate one of the nation’s biggest mining sites in the Dawei District of Tanintharyi Division in southern Myanmar, with permission for large-scale mining for 50 years. Their tin-tungsten product primarily serves the electronics and high-tech industries due to tin’s versatile applications. They are also committed to building an efficient and responsible approach in their operations to promote sustainability (Delco, n.d.). Delco mentioned that they support communities in a sustainable way. However, the research team did not find human rights policies and practices of the company.

☛ Georesources Mining Co., Ltd.

Georesources is a Myanmar-based company specializing in exploration and mining. Established as a Geological Survey and Exploration Team in 2008, it evolved into Georesources Mining Co., Ltd. in 2010. The company is known for its significant role in discovering manganese deposits in Eastern Shan State, Myanmar. It offers comprehensive services including exploration, mining development, and marketing of metals and minerals (Georesources group of companies, n.d.).

Georesources is involved in a variety of mining projects across Myanmar, focusing on a wide range of minerals. Key projects include silica mining in the Mandalay Region and tin exploration in Mon State. Their activities cover the exploration and development of numerous minerals such as copper, gold, coal, and limestone, reflecting their extensive involvement in Myanmar’s mining sector (Georesources group of companies, n.d.). However, the research team did not find human rights policies and practices of the company.

☛ UMG Group

UMG group, established in 1998, is a leading multi-sector company in Myanmar. It began with trading generators and heavy equipment spare parts, quickly gaining a significant market share. The company expanded into nine business sectors, including the mining sector with over 3,000 employees across over 40 subsidiary companies (UMG, n.d.).

In the mining sector, UMG Myanmar, through its subsidiaries First Resource Co., Ltd, United Masterpiece Co., Ltd, and Bright Resource Co., Ltd, focuses on extracting natural resources in Myanmar. Since its inception in 2011, the company has emphasized eco-friendly practices in its mining operations. UMG’s primary products include gypsum, barite powder, and granite rock, with ongoing exploration for other industrial raw materials and metals like tin and tungsten (UMG, n.d.). The research team did not find the human rights policies and practices of the company. However, they announced their blacklist of employee publicly on their website (UMG, n.d.).

☛ Jewellery Luck Co., Ltd.

Jewellery Luck Group of Companies, established in April 1995 in Myanmar, initially focused on trading and hotel operations. Over time, the company expanded into timber manufacturing, logging, logistics, transportation, and timber trading, both domestically and internationally (Jewellery Luck, n.d.).

Additionally, the company has a significant presence in the mining sector, partnering with Myanmar’s Ministry of Natural Resources for lead extraction in the Bawsaing area of Kalaw township. Their mining business, situated in the Bawsaing area of Kalaw township, Southern Shan State, Myanmar, spans over a 1000-acre site. Established on July 20, 2009, the company primarily focuses on extracting Lead (PbS, PbCO3) and mixed ore, with an estimated lead deposit of approximately 2.6 million tons at the current site (Jewellery Luck, n.d.). However, the research team did not find human rights policies and practices of the company.

Medicinal plant in Myanmar

Marshall Kramer published research “Medicinal plant documentation in Pawkhlo”. This project aims to empower Takapaw as citizen scientists by providing training and demonstrations. This would enable them to conduct future research to identify local resources, enhance local resource management skills, and develop appropriate materials for engaging with scientific, legal, and conservation experts/authorities. Subsequent project stages may include extensive documentation and potential expansion into neighboring indigenous territories, along with regional collaboration in bioresource management.

Due to limited data on medicinal plant value chain in Myanmar, the research team utilized a conceptual framework based on the study “Linking Medicinal Plant Production with Livelihood Enhancement in Bangladesh: Implications of a Vertically Integrated Value Chain,” authored by Shahidullah, A.K., and Haque, C.E., published in 2010. The value chain is shown in the figure below.

Harvest/ Production

Actor Activity

Individual Farmer/ Homestead Growers

Intermediary

Local Paikers/ Sub-regional Beparies/ regional Beparies

Processing/ Roasting Distribution and Retailing

Herbal Processors/ Ayuravedic Manufacturer/ Unani Manufacturer Wholesaler/ Exporter

Source: Shahidullah, A.K., & Haque, C.E. (2010)

Key issues found in the report

The research team summarized key issues from the report as follows.

Lack of knowledge about reserving forest areas as herbal medicine forests

Distributors Store Dispensaries

Herbal Doctors

● Takapaw members were worried about the absence of accurate documentation, aiming to safeguard valuable cultural resources from exploitation and ensure local management in the future.

● Interest in documenting practices of designating forest areas as “herbal medicine forests” to support indigenous management in the long term, especially amid threats from large-scale conservation projects by the Forest Department and international conservation agencies.

● Takapaw engaged a professional ethnobotanist, balancing financial constraints and the need for local capacity building, to develop objectives for the initial phase of medicinal plant documentation in Pawkhlo.

Medicinal plant companies in

Myanmar

To consider the policies of major medicinal plant companies in Myanmar, the research team searched for the major companies by using the International Trade Centre and the Directorate of Investment and Company Administration Myanmar. The list of companies is shown in the table below.

Figure 3 Medicinal plant value chain in Myanmar

Maw Myae Co., Ltd.

SGS Myanmar Limited n/a

FAME Pharmaceuticals Industry Co., Ltd. n/a

Source: The International Trade Centre (2023) and the Directorate of Investment and Company Administration Myanmar (2023)

There are only 5 companies found on the website and only 2 of these companies have data on turnover value. Thus, the research team selected all companies on the list to consider their policies.

☛ Sein Wut Hmon Co., Ltd.

Sein Wut Hmon Group, a distinguished conglomerate in Myanmar, exhibits a diverse business portfolio, with a notable emphasis on the cultivation and distribution of medicinal plants. This strategic focus underscores the group’s commitment to the health and wellness sector. Alongside its significant involvement in distribution, manufacturing, service, retail, and trading, the group operates through key subsidiaries: Sein Wut Hmon Co., Ltd. (distribution), IMU Enterprise Ltd. (manufacturing), Sein Myo Daw Co., Ltd. (trading), and Star Way Co., Ltd. (distribution). The cultivation and distribution of medicinal plants represent a crucial aspect of the group’s operations, positioning it as a pivotal player in both the agricultural and healthcare markets in Myanmar.

☛ Pacific-AA Group Limited

Pacific-AA Group Limited was established in 1996. AA Medical has emerged as the preeminent pharmaceutical distribution company in Myanmar, renowned for its extensive network and reliability. The company boasts a comprehensive national presence with branch offices strategically located throughout Myanmar. Additionally, AA Medical has expanded its global footprint with subsidiary operations in both Singapore and the United States, further solidifying its status as a leading entity in the pharmaceutical distribution sector.

☛ Shan Maw Myae Co., Ltd.

Shan Maw Myae Co., Ltd. is a Myanmar-based, market-oriented social business led by Managing Director Mr. Nyan Lin. They believe in making profits alongside benefiting people and the environment. Shan Maw Myae’s mission is to support Myanmar’s food safety by

transferring HYB (High Yield by Bio Technology) program to farm-land so as to achieve soil improvement, environmental conservation of high yield, productivity, and good agriculture practices to sustain the agro-based industry. Another mission is to develop Green Family Program by collaborating with native farmers of each Myanmar village, all interested parties, and our technical experts.

Shan Maw Myae will transform farmers’ top objective in agriculture practice so as to overcome their difficulties and risks in cultivation by providing food agriculture practices with technical experts. So that farmers’ incomes, productivity, and agro-based industry will grow up highly. In this way, the nationwide agriculture objective can be achieved.

Their business focuses on manufacturing and distributing agricultural and livestock products, healthcare & food products, and promoting organic farming along with exporting organic fertilizers, farm products, and medicinal plants. Apart from that, Shan Maw Myae also provides technical assistance to farmers, with 22 branch offices nationwide and a network of approximately 70,000 farmers. Shan Maw Myae is expanding its business in various aspects for valuable agricultural products through technical assistance to farmers, marketing and processing, and value-added sales.

☛ SGS Myanmar Limited

Established in Myanmar in 1948, SGS holds the distinction of being both the nation’s longest-standing multinational and its premier inspection, verification, testing, and certification (IVTC) provider. Renowned for the unwavering quality of its services, unparalleled competency, and unwavering integrity, SGS has fostered long-standing trust with diverse clients encompassing a vast array of industries and government agencies within Myanmar. This enduring reputation is demonstrably upheld by the dedication and expertise of our passionate employees, who consistently prioritize integrity, safety, and quality in their daily endeavors. Further solidifying our commitment to excellence, our laboratory boasts a comprehensive range of testing services catered to a multitude of sectors, including agricultural products, food, minerals, soil, water, and inorganic fertilizers.

Increasing consumer demand for diverse and authentic herbs and spices coincides with heightened regulatory stringency regarding purity, quality, safety, traceability, and authenticity in the food industry. Recognizing this dynamic landscape, SGS offers comprehensive testing, inspection, audit, and certification solutions designed to empower your business in delivering safe, compliant, and authentic herbs and spices to your customers. As a recognized benchmark of quality and integrity, SGS provides tailored solutions wherever you operate globally, supporting compliance with renowned food safety regulations like the US Food Safety Modernization Act (FSMA) and fostering social responsibility across your supply chain.

☛ FAME Pharmaceuticals Industry Co., Ltd.

Maintaining a high degree of integrity in the production of FAME’s herbal medicinal products is paramount. The company’s pharmaceutical manufacturing plant adheres to stringent quality standards, operating under Good Manufacturing Practices (GMP) guidelines established by the World Health Organization (WHO) and the International Organization for Standardization (ISO). Initially certified in 2002 under ISO 9001:2000 (Quality Management System), the plant subsequently achieved ISO 14001:2004 (Environmental Management System) and OHSMS 45001:2018 (Occupational Health and Safety Management System) certifications in 2006, awarded by Bureau Veritas Certification, the United Kingdom. Currently, the facility operates under the updated ISO 9001:2015 standard. In 2014, the plant further garnered organic certification from the United States Department of Agriculture (USDA), enabling the production of high-quality organic finished products.

Additionally, established in 2010, the FAME clinic utilizes alternative medicine methodologies to address health concerns within Myanmar’s population. Employing a holistic approach, the clinic treats patients with acute and chronic diseases affecting the urological, respiratory, central nervous, and cardiovascular systems through a combination of herbal medicine, dietary and nutritional modifications, and therapeutic exercises. Today, the company has over 300 employees dedicated to producing a variety of natural and organic herbal medicinal supplements and natural consumer products for local and export markets. FAME also provides high-quality raw plant materials for both markets.

Rice in Cambodia

The NGO Forum on Cambodia published research on “Ecosystem and Women’s Participation in the Implementation of Contract Farming in Cambodia: The Cases of Rice, Cashew, and Rubber” in July 2023. The research aims to study the participation process of women in contract rice farming in Cambodia.

Key issues found in the report

The report focuses on the participation process of women in contract rice farming in Cambodia which has problems and obstacles in agriculture. The research team summarized key issues from the report as follows.

Impact of climate change

● From the report, it is found that global climate change significantly affects agricultural production, both in terms of adapting to changes and developing production technologies to cope with changing weather conditions.

Rice-growing households

Village traders

Foreign traders

Village cooperatives

Local small rice mill

Local medium and large rice mill

Foreign rice mill

Source: Centre for Child Rights and Business (2023)

Limited access to financial services

● Although Cambodia has the Agricultural and Rural Development Bank, commercial banks, and Micro Finance Institutions (MFIs) provide financial services to farmers with low capital, the report also found limitations in accessing financial services from these institutions and complex loan application procedures.

Limited women participation

● The report found no discrimination or lack of opportunities for women in managerial roles within agricultural cooperatives. At the cooperative level, both women and men have equal opportunities to participate and compete for management positions on the Board. Recruitment is based on merit, and free and fair elections are conducted during the annual cooperative summit. For example, in a cooperative in Battambang, women hold 57.1 percent of the Board composition. However, women still encounter limitations when participating in cooperative board management positions or other activities as follows:

● Level of education: Low levels of education may impact women’s confidence in their work within agricultural cooperatives.

● Financial incentives: The lack of financial incentives, such as working in the capital city or abroad, can provide women with higher compensation than working in agricultural cooperatives.

Figure 4 Rice value chain in Cambodia

● Household chores: Women are more responsible for household chores than men, which can limit their participation in agricultural cooperatives.

● Decision-making power: Women often face opposition from their husbands when they want to travel to other provinces to attend agricultural cooperative activities.

Major rice companies in Cambodia

To consider the policies of major rice companies in Cambodia, the research team uses data from trademap.org which provides a list of Cambodian companies in the rice sector. There are 45 companies in total, but only 20 companies have data on export turnovers and the number of employees. Data is shown in the table below.

Source: trademap.org

To select the top 5 companies, the research team considered the export value of the companies as the priority criteria. There are only 4 companies that have information on their websites which are Green Trade Company, Signatures of Asia, Soma Trading, and Baitang (Kampuchea). The research team selected these companies as the first four major companies in terms of their export value. Also, these companies have information found on websites.

Table 2 Companies in Cambodia’s rice sector

Then, the research team considered the number of employees as the second criterion. It is found that Golden Rice (Cambodia) is the second largest company in terms of the number of employees. Thus, it is selected as the fifth company.

☛ Green Trade Company

Green Trade Company was established in 1998 by sub-decree # 72 of 23 November 1998. It is a merger of 4 former state-owned companies, Cambodian Food Company, Material & Equipment Company & Agricultural Product Company, and Camtran Co. GTC, which was formed as a public enterprise like a state-owned enterprise (Green Trade Company, n.d.).

The company has a goal to make good security of foodstuffs and guarantee a stable marketing price for the government. Also, the company wants to increase the exports of Cambodian rice to become the largest exporter in the world. The company also emphasizes improving employee standards specified in the corporate strategy (Green Trade Company, n.d.). Regrettably, the research team could not locate specific details of the human rights policies on the company’s website.

☛

Signatures of Asia Co., Ltd.

Signatures of Asia Co., Ltd. operates as an agribusiness entity dedicated to environmental stewardship. Within its portfolio of agricultural products cultivated through contractual farming arrangements, rice production takes precedence (Signatures of Asia, n.d.).

A foundational tenet guiding the company’s business conduct is the imperative that customers are provided with products adhering to sustainable standards. Simultaneously, the company is committed to ensuring farmers receive equitable returns for their contributions to the agricultural supply chain. Furthermore, the company’s core emphasizes fostering honesty, transparency, and accountability. These values are foundational in elevating the Cambodian enterprise into an internationally recognized entity and a sustainable, enduring business partner. In addition, the company has also received various standards for being an organic producer, such as Organic milling & exporting Certification, EU Organic Standard, Organic farming Certification, and US Organic Standard (Signatures of Asia, n.d.).

Regrettably, the research team could not locate specific details of the human rights policies on the company’s website.

☛ Soma Trading Co., Ltd.

Soma Trading Co., Ltd. was established in 2011 to export good quality rice and fruits. The company is one of the companies of the Soma Group, which invests in six business sectors: Infrastructure, Agriculture, Trading, Education, and Hospitality & Real Estate in Cambodia (SOMA GROUP, n.d.).

Regrettably, the research team could not locate specific details of the human rights policies on the company’s website.

☛ Baitang (Kampuchea) PLC

Established in 2008, Baitang (Kampuchea) PLC operates as a rice milling company with pivotal objectives to advance the quantity and quality of paddy and rice production. These endeavors are undertaken with the explicit goal of facilitating exportation to international markets (Baitangrice, n.d.).

The research team could not locate specific details of the human rights policies on the company’s website.

☛ Golden Rice (Cambodia) Co., Ltd.

Established in 2009, Golden Rice (Cambodia) Co., Ltd. specializes in the comprehensive processes of rice drying, milling, and packaging, with a primary focus on facilitating rice exports. Also, the company garnered accreditation from various standards, attributable to the implementation of rigorous management systems, including the Quality Management System (ISO 9001:2015), Food Safety Management System (GMP/HACCP), Social Accountability Management System (SA 8000:2014), and Environmental Management System (ISO 14001:2015) (Golden Rice (Cambodia), n.d.).

Regrettably, the research team could not locate specific details of the human rights policies on the company’s website. Nevertheless, the company’s homepage explicitly states its commitment to respecting and aligning with internationally recognized conventions and statutes related to human rights, labor rights, the well-being and safety of all stakeholders, as well as compliance with local environmental regulations. It is noteworthy that this declaration extends inclusively to the company’s business partners.

Cashew in Cambodia

The NGO Forum on Cambodia’s report aims to investigate the current state of contract farming in Cambodia, with a specific focus on the participation of women and to provide a comprehensive overview of the contract farming ecosystem, identify challenges, and offer practical recommendations to strengthen the system and enhance stakeholder confidence. The study focuses on three specific crops: rice, cashew, and rubber, in different regions of Cambodia.

Source: Trade SWAp Pillar 2 Task Team on cashew nuts (2008)

Key issues found in the report

The NGO Forum on Cambodia’s report focuses on women’s participation in cashew contract farming in Cambodia which could be identified and improved in promoting gender roles and equality. The research team summarized key issues from The NGO Forum on Cambodia’s report as follows.

Lack of production knowledge

● Farmers’ knowledge of cashew nut production has improved due to training and handson experience. However, challenges persist in the use of fertilizer and pesticides, with farmers relying on suppliers lacking proper knowledge. Additionally, farmers also lack the technical know-how to mitigate production losses caused by pests and tea mosquito bugs.

Figure 5 Cashew value chain in Cambodia

Limited access to finance

● Although access to finance has improved, rigid loan terms and conditions remain. While the interest rates from government banks are lower than private institutions by about 50 percent, collateral-based lending remains common, further limiting borrowing. Also, government banks target processors and exporters who have collateral or higher ability to pay, not agricultural cooperatives and farmers.

Lack of support from PDAFF

● The lack of support from the Provincial Department of Agriculture, Forestry, and Fisheries (PDAFF) for agricultural cooperatives (ACs) and farmers, especially in terms of providing technical advice on agriculture to farmers, despite their coordinating role in implementing contracts.

Dispute Resolution Challenges

● Conflicts and disputes often arise in contracts between farmers and buyers, but there are no clear guidelines for resolving these disputes. Dispute resolution typically occurs outside of formal mechanisms, involving various levels of authority, from village chiefs to higher agricultural departments, depending on the contract type. However, the involvement of higher authorities is typically limited to formal contracts, and they are not legally obligated to intervene in disputes arising from informal contracts.

Limited women participation

● Women’s participation in contract farming and agricultural cooperatives has increased, with more women involved at the farmer level and taking up various roles in management teams. However, their representation in top leadership positions is still low, despite equal opportunities and strong encouragement, several factors constrain women from holding top positions often due to factors like domestic responsibilities, societal norms, lack of confidence, and lack of financial incentives.

Major cashew companies in Cambodia

To consider the policies of major cashew companies in Cambodia, the research team used the data from Trade Map which provides trade statistics on imports and exports by product group and across 200 countries (International Trade Centre, 2023). Trade Map provides the list of 27 companies in total, but only 15 companies that have the data on turnover.

Source: The International Trade Centre (2023)

The research team chose the top 5 companies in terms of export turnover to explore their policies as follows.

☛ Green Trade Company (GTC)

GTC was established in 1998. The company is a merger of 4 former state-owned companies and was formed as a public enterprise in the nature of a state-owned enterprise. GTC is a trader of paddy & rice and also trading in other commodities (GTC, 2024). The research team could not find any policies relevant to human rights on the company’s website.

☛ Soma Trading Co., Ltd.

SOMA Trading Company Limited was established in 1995 and began exporting rice in 2011. The company is a trader and exporter of rice from Cambodia to many countries and a distributor of a variety of products from consumer goods (Soma Group Co., Ltd., 2024). The research team could not find any policies relevant to human rights on the company’s website.

☛ Loran Group PLC

Loran Group PLC was founded in 1994. The company’s line of business includes manufacturing rice and cleaning and polishing rice (Bloomberg, 2024). The company is Cambodia’s leading rice producer, exporter, and importer for local and international markets such as Germany, USA, China, etc. (LORAN Group PLC,2024). The research team could not find any policies relevant to human rights on the company’s website.

☛ D&D Pattanaik Group Co., Ltd.

D&D Pattanaik Group Company Limited, founded in 1997 as an IT company, has progressively diversified its business ventures over the years. By 2012, the company had developed an ambitious growth strategy with a focus on expanding into the Mining and Agriculture sectors. Actively seeking joint venture partnerships, the company aimed to participate in acquiring economic land concessions and initiating agriculture projects, particularly in plantation. The primary agricultural products include rice, tobacco, and cashews (D&D Pattanaik Group, 2024). However, the research team could not identify any relevant policies pertaining to human rights on the company’s website.

☛ Men Sarun Import & Export Co., Ltd.

Men Sarun Import & Export Co., Ltd. is a wholesaler and exporter of rice products (CDRI, 2011). Unfortunately, the company’s website (www.mensarun.com.kh) cannot be reached. The research team tried to search for information from other sources but there was no information found.

Rubber in Cambodia

The NGO Forum on Cambodia’s report aims to investigate the current state of contract farming in Cambodia, with a specific focus on the participation of women and to provide a comprehensive overview of the contract farming ecosystem, identify challenges, and offer practical recommendations to strengthen the system and enhance stakeholder confidence. The study focuses on three specific crops: rice, cashew, and rubber, in different regions of Cambodia.

Smallholder/ Agricultural Cooperatives

Source: Ecosystem and Women’s Participation in the Implementation of Contract Farming in Cambodia: The Cases of Rice, Cashew, and Rubber (2023)

Key issues found in the report

The NGO Forum on Cambodia’s report focuses on women’s participation in rubber contract farming in Cambodia which could be identified and improved in promoting gender roles and equality. The research team summarized key issues from The NGO Forum on Cambodia’s report as follows.

Unsustainability on production

● Rubber cooperatives lack skills in sustainable production practices, AC management, leadership, and financial literacy. Most decision-making is dependent on Civil Society Organization (CSO) officials.

Figure 6 Rubber value chain in Cambodia

● Most of the agricultural cooperatives (ACs) established helped by various organizations, both public organizations and CSOs have had discontinuous activities without much follow-up action or systematic approaches. As a result, they created ACs that could not sustain their functions after the projects were over.

Inequality of technology in rural areas

● There is a barrier to communication in rural areas due to the lack of telecommunication and internet access, causing problems in communication and the distribution of market price information. As a result, cooperative members, who are smallholders in the ecosystem, are not always aware of the actual price, potentially affecting their revenue.

Gender inequality and lack of women’s participation

● While efforts have been made to ensure women’s equal representation in AC and project activities in Cambodia, there are still challenges in achieving meaningful participation and impact. Although there is a target of at least 30 percent female participation, the quality and impact of women’s contributions in AC management are being observed. Several barriers hinder women’s participation, including traditional roles prioritizing family and childcare, logistical challenges, lower interest in technical aspects, and the need for mindset changes.

Facilitation and Resource Constraints

● Governance organizations related to the rubber sector received limited funding and their local staff remains insufficient due to a lack of incentives, coordination, and effective governance.

● The rubber sector in Cambodia has received comparatively little attention and funding compared to major food crops. Additionally, funding is primarily directed towards capacity building, with restrictions preventing budgets from being allocated to crucial tangible investments or construction projects.

Major rubber companies in Cambodia

To consider the policies of major rubber companies in Cambodia, the research team used the data from Trade Map which provides trade statistics on imports and exports by product group and across 200 countries (International Trade Centre, 2023). Trade Map provides the list of 13 companies in total, but only 8 companies that have the data on turnover.

Source: The International Trade Centre (2023)

The research team chose the top 5 companies in terms of export turnover to explore their policies as follows.

☛ Sopheak Nika Investment Group Co., Ltd.

Sopheak Nika Investment Group Co., Ltd. is one of the largest rubber growers and exporters in Cambodia (The Phnom Penh Post, 2023). Unfortunately, the company doesn’t have an official website. The research team tried to search for information from other sources but there was no information found.

☛ Memot Rubber Plantation Co., Ltd.

Memot Rubber Plantation Co., Ltd. is one of the rubber plantation companies in Cambodia (Khmer Times, 2023). Unfortunately, the company’s website (http://www.memot-mrp.com) cannot be reached. The research team tried to search for information from other sources but there was no information found.

☛ Krek (Cambodia) Co., Ltd.

Krek (Cambodia) Co., Ltd. is one of the rubber plantation companies in Cambodia (FAO, 2021) and also an importer and exporter of rubber products (Volza, 2024). Unfortunately, the company doesn’t have an official website. The research team tried to search for information from other sources but there was no information found.

☛ Tai Seng Import Export & Construction Co., Ltd.

Tai Seng Import Export & Construction Co., Ltd. is in Phnom Penh, Cambodia. The company works as import and export agents and wholesale traders of rice and agricultural products (CambodiaYP, 2024). Unfortunately, the company’s website (http://www.taiseng-sez.com) cannot be reached. The research team tried to search for information from other sources but there was no information found.

☛ First Bio-Tech Agricultural (Cambodia) Co., Ltd.

First Bio-Tech Agricultural (Cambodia) Co., Ltd. is Cassava & Wheat Processer (CCC, 2024). Unfortunately, the company’s website (www. centurygroup.com.kh) cannot be reached. The research team tried to search for information from other sources but there was no information found.

Seafood in Thailand

The Civil Society Organization Coalition for Ethical and Sustainable Seafood conducted research on “A Survey of Wage Issues and COVID-19 Impacts Among Migrant Seafood Workers in Thailand” in July 2021. The research aims to explore the impact of COVID-19 on migrant workers in the seafood industry in Thailand.

Source: Department of Fisheries (2022)

Key issues found in the report

The report examines the problems and obstacles in four main components of the fishing industry in Thailand, including fishing, aquaculture, pre-processing, and processing factories. The findings of the report highlight various instances of labor rights violations and injustices prevalent in these sectors. The research team summarized key issues from the report as follows.

Figure 7 Seafood value chain in Thailand

Income below minimum wage

● The survey results revealed that over half, or 58 percent, of the workforce earned a monthly income less than the minimum wage (calculated as daily minimum wage X 30 days). According to Thailand’s labor laws, workers are supposed to receive an average salary of 9,699 baht per month. However, the survey found that the average compensation received by workers was only 9,218 baht per month. Among all sectors, those in the fishing industry had the highest average salary (11,365 baht per month) due to the Ministerial Regulation on the Protection of Labour in Sea Fisheries, B.E. 2561 (2018), which determined the minimum wage for migrant labor.

Lack of coverage of the law

● The Ministerial Regulation on the Protection of Labour in Sea Fisheries, B.E. 2561 (2018), applies specifically to fishing and stipulates that employers must pay wages every month, not less than the minimum wage multiplied by 30 days, and must make direct transfers to the workers’ bank accounts. However, even though there are specific legal protections for the fishing industry, these workers still face long working hours, reaching up to 14 hours per day or more. Therefore, it cannot be said with certainty that the compensation received by the labor force is equitable.

Informal employment

● According to the survey, informal employment remains a significant issue, as the Ministerial Regulation on the Protection of Labour in Sea Fisheries, B.E. 2561 (2018), does not extend to informal labor practices in other seafood-related industries beyond fishing. This has led to a continued prevalence of informal employment practices, such as verbal contracts, irregular working hours, the absence of guaranteed monthly incomes, and more. During the COVID-19 pandemic, it became evident that the number of working days decreased significantly, with some laborers working as few as two days per week, resulting in inadequate income for their livelihoods.

● Furthermore, Thai law mandates that foreign laborers must have a single employer specified in their work permits, which prevents them from seeking additional income opportunities from different employers. They face increased legal risks if they engage in such activities secretly to supplement their income.

Lack of maternity rights

● Migrant workers often encounter challenges accessing various pregnancy, childbirth, and childcare rights. These factors contribute to some female laborers leaving their jobs during pregnancy. Many must sell personal assets or incur debt to prepare financially for childbirth and childcare.

Gender pay gap

● The survey found that female migrant workers in the Thai seafood industry earn approximately 3,000 baht less per month than their male counterparts, roughly 30 percent less. Overall, 38 percent of male workers earn less than the minimum wage when calculated every month, while 80 percent of female workers earn less than the monthly minimum wage.

Major seafood companies in Thailand

To consider the policies of major fishery companies in Thailand, the research team selected the top 5 companies utilizing official data obtained from tradereport.moc.go.th, a platform published by the Office of the Permanent Secretary of the Ministry of Commerce. The results indicate that these five companies exhibit varying degrees of disclosure regarding human rights-related documents. Below, a brief history of these companies is provided, outlining their main products, export markets, and human rights-related policies.

☛ Charoen Pokphand Foods Public Company Limited (CPF)

Charoen Pokphand Foods Public Company Limited (CPF), a subsidiary of Charoen Pokphand Group Co., Ltd., was established in 1978 with an initial focus on animal feed production and sales. Over time, CPF has diversified its business operations to encompass farming, processing, and food production. In the seafood industry, CPF not only manufactures aquaculture feed but also engages in aquaculture itself, primarily focusing on shrimp and Tilapia (fish). The products resulting from these activities are exported to over 40 countries worldwide (Charoen Pokphand Foods, n.d.). CPF is committed to adhering to international standards across various policies, including those related to human rights, labor, and environmental, social, and governance (ESG) considerations.

☛ Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited was founded in Hat Yai, Songkhla province in 1978. The company primarily focuses on frozen seafood manufacturing, encompassing a wide range of products such as shrimp, squid, cuttlefish, and octopus. The manufacturing processes include both cooked and uncooked variations (Reuters, 2024). Regarding its human rights-related policies, the company transparently shares its annual report on its website, providing details about the human rights due diligence conducted by the company (Kiang Huat Sea Gull Trading Frozen Food, 2023).

☛ Thai Union Group Public Company Limited

Thai Union was established in Samut Sakhon in 1997 with a focus on the manufacturing and export of canned tuna. Over the years, its product offerings have diversified to include various seafood items such as tuna, sardines, mackerel, herring, salmon, and shrimp, available in canned, frozen, and ready-to-eat formats (Thai Union, 2024). Through strategic

mergers and acquisitions, Thai Union has expanded its customer base across several continents, serving clients in North America, Europe, Asia, and the Pacific. The company actively adheres to internationally recognized standards, which are evident in its annual publication of a sustainability report.

☛ Marine Gold Products Company Limited

Marine Gold Products Company Limited was founded in 2000 with the objective of globally exporting shrimp products. Presently, the company exports its shrimp products to various regions worldwide, including the USA, Canada, the UK, the EU, and Asia. Notably, the company has received the Thai Labor Standard Certificate with the highest level of achievement from the Department of Labor Protection and Welfare, Ministry of Labor, since 2004. Despite this recognition, it is worth noting that the company’s website does not currently feature publicly available human rights-related documents (Marine Gold Products, 2024).

☛ Golden Seafood International Company Limited

Golden Seafood International Company Limited was established in 2010 in Ranong with a focus on exporting seafood products. Its primary offerings comprise raw and cooked shrimps, including black tiger and Vannamei varieties (Golden Seafood International, 2024). The company’s export markets encompass China, Japan, and Australia. Regarding its human rightsrelated policy, Golden Seafood International does not publicize any information on its website.

Sugar in India

Oxfam India conducted two significant research studies: “Human Cost of Sugar: A Farm-to-mill Assessment of Sugar Supply Chain in Uttar Pradesh” (2018), which evaluates the difficulties encountered by small and marginal farmers as well as farm workers in the sugar value chain, and “Human Cost of Sugar: Living and Working Conditions of Migrant Cane-cutters in Maharashtra” (2020), aimed at shedding light on systemic problems within the Maharashtra sugar supply chain to encourage discussions and initiatives among key stakeholders.

Key issues found in the report

Oxfam India’s report focuses on the systemic issues in the Uttar Pradesh and Maharashtra sugar supply chain to trigger discussions and action from key stakeholders. The research team summarized key issues from Oxfam India’s report as follows:

Poverty and indebtedness

● Approximately 80 percent of the population relies on agriculture and animal husbandry as their sole sources of income, constituting their primary means of livelihood. However, persistent drought conditions in the region have led to agricultural distress, pushing people towards migration as there are limited alternative employment opportunities.

Harvest/ Production

Actor Activity

Sugarcane Workers

Intermediary

Port Mukkadam/ Deputy Mukkadam

Mukkadam/ ContractorTier 2

Mukkadam/ ContractorTier 1

Government

Source: Oxfam India (2020)

Processing/ Roasting

Distribution and Marketing

Sugar Mills

Traders (National/ International)

Institutional buyers

● The government’s employment guarantee scheme, The Mahatma Gandhi National Rural Employment Guarantee Act (MGNREGA), has not proven effective in providing viable alternative livelihoods. In Beed, out of the 0.9 million workers registered under MGNREGA, only 135,000 were able to secure employment. Moreover, those who did find work often faced issues such as delayed or non-payment of wages.

● The dire agricultural situation, coupled with the lack of viable alternatives, has resulted in widespread indebtedness among the local population. Many workers resort to borrowing from local moneylenders or labor contractors, who often charge exorbitant interest rates ranging from 3-5 percent per month. The inability to repay these loans on time traps them in a vicious cycle of debt.

Access to land and water

● In parts of Maharashtra, there are ongoing land and water conflicts that disproportionately impact historically marginalized castes. These communities live separately in villages, often without proper land ownership. They face challenges due to insufficient water storage and lack of resources to buy or transport water. Consequently, they are last in line for water supply, causing significant hardships, especially for women. In some cases, drinking water in these communities has been contaminated with human waste, notably in regions like Konkan in Maharashtra.

● Residents purchase water from private tankers, costing between 700-1,000 rupees for 2,000-2,500 liters, due to the absence of reliable public water supply. In certain areas where water is supplied through canals, the marginalized communities are often excluded as the water is diverted upstream towards more influential groups.

Figure 8 Sugar value chain in India

● The water scarcity also affects livestock, forcing farmers with cattle to rely on government fodder camps to prevent distress sales during droughts.

● Abundant availability of water in the region has led to over-exploitation of groundwater. Water conservation practices are not practiced by farmers.

● Sugar mills and distilleries in several parts of Uttar Pradesh are also found to be polluting water bodies by discharging untreated effluents into water bodies.

Unfair wage

● Workers in the sugar industry face a problem where contractors, not the sugar mills that hire them, handle their pay. This often results in them not getting the full payment they deserve and unclear deductions from their wages. The only option for these workers is to change contractors, but even this doesn’t help their financial struggles. This situation keeps them stuck in a cycle of debt that never ends.

● These workers face harsh conditions as they lack access to leaves, and any absence results in unexplained wage deductions, ranging from 500-1,000 rupees per day. Additionally, they experience unjustified adjustments to their wages and advances. Even when they work hard to repay advances, their earnings are further reduced.

● It was found that farmers generally do not practice any documentation for the farm workers they employ. Wages vary between 200 to 400 rupees for men and 80 to 200 rupees for women as against the state government specified minimum wages of 293, 322, and 361 rupees for unskilled, semi-skilled, and skilled workers respectively.

Lack of occupational health and safety

● The work environment, including poor lighting, slippery surfaces, and hazardous objects, puts the workers at high risk of accidents and injuries.

● Workers lack proper legal protections, insurance, and compensation for the risks they face while performing their jobs. This leaves them vulnerable in the case of accidents and injuries.

● Children are forced into labor, engaging in tasks that are physically demanding and potentially dangerous. Their involvement in such activities deprives them of their right to education and exposes them to significant risks.

● Incidents, including accidents and deaths, often go unreported, further hiding the true extent of the problem and preventing appropriate action from being taken.

Gender inequality

● High female labor participation in Maharashtra’s sugarcane farms is due to the practice of hiring worker couples (‘jodis’), but it restricts opportunities for women without male family members, limiting their employment prospects.

● Women are burdened with childcare and care work responsibilities in the absence of childcare facilities. Safety concerns lead young girls to accompany their parents, causing a significant dropout rate, especially among girls. In 2009, the dropout rate for girls was 41 percent, with 27 percent leaving due to poverty, leading to early child marriages and prevalent domestic violence and abuse.

● Women farmers with or without land ownership have limited decision-making powers. They contribute to the farming process through their labor during the sowing and harvesting seasons. Only when male members are absent in the family do women take up a more proactive role.

● Working in sugarcane farms is considered taboo for women in the community. Families with landholdings of over 2 ha do not allow the women to participate in sugarcane farming. For small and marginal farmers, who are largely dependent on the labor of their family members, women participate in sugarcane cultivation.

● Scarcity of water in the Marathwada region has made existing toilets unusable, leading to open defecation among residents.

● Poor menstrual hygiene causes fungal and bacterial infections, potentially leading to severe conditions like pelvic inflammatory diseases (PID), vaginitis, uterine infections, and cervical cancer.

● More than 90 percent of women in these labor camps are estimated to be anemic due to poor diet.

● Female sugarcane workers experience extensive rights violations, as they are denied Maternity Benefit entitlements, compelling them to work during pregnancy, face minimal medical assistance during labor, and return to cane cutting within 7-10 days postpartum, without access to essential facilities like Aanganwadi, a rural childcare center in India or crèche services.

● Female sugarcane workers lack crucial social security benefits like EPF and ESIC, despite efforts by the Maharashtra government to establish a welfare board in 2019; funding concerns persist, underscoring the dire absence of support and protection, leaving these women in vulnerable and precarious situations.

Child labour and lack of right to education

● Each year, around 200,000 children under the age of 14 accompany their parents for cane harvesting in Maharashtra, with over half falling within the 6-14 age group (54 percent boys and 46 percent girls). These children are drawn into labor as early as 6-7 years old, becoming full-fledged laborers by the age of 11-12. Their work is categorized as “family labor,” denying them their right to education.

● Migrant children aged between 12-16 years from states like Bihar, Madhya Pradesh, Chhattisgarh, Odisha, and West Bengal were reported to be hired through contractors as workers.

Major sugar companies in India

To consider policies of major sugar companies in India, the research team searched for the top 5 companies in the industry by turnover (USD) volume. The website of the International Trade Centre (2022) ranked the list of companies as shown in table below.

Source: The International Trade Centre (2023)

The research team selected the top 5 companies from the list above to explore their policies as follows.

☛ Uttam Sugar Mills Limited

Uttam Sugar Mills Limited was established in 2001. The company produces 21 different sugar varieties, widely available in Northern and Central India, including Rajasthan and Gujarat. These sugars are used by top stores, restaurants, airlines, and railway services. Their extensive distribution network and diverse clientele, including major hotels and retail giants, highlight the company’s commitment to quality and the value of its sugar products.

☛ K.P R. Mill Limited

K.P.R. Mill Limited was founded in 1984 and based in Coimbatore, India. The company is primarily recognized as an integrated apparel manufacturing entity in India. However, sugar production is also one of its main products. Alongside its significant role in the textile industry, where it produces a diverse array of yarns including compact, combed, carded, melange, and various blends like polyester cotton, viscose, and color melange, the company is also engaged in sugar production.

☛ E.I.D. Parry India Limited

E.I.D. Parry holds a notable historical position in India’s sugar industry, having established the nation’s first sugar plant in Nellikuppam in 1842, and continuing to be a trailblazer in its various business ventures to this day.

Table 5 Companies in India’s sugar sector

As one of the foremost sugar producers in India, E.I.D. Parry operates seven sugar plants strategically distributed across Southern India. These advanced facilities boast a combined sugarcane crushing capacity of 40,300 tons of cane per day (TCD), a co-generation power capacity of 140 megawatts (MW), and a distillery production capacity of 598 kiloliters per day (KLPD). The plants are situated in key locations including Nellikuppam, Pugalur, and Sivaganga in Tamil Nadu; Sankili in Andhra Pradesh; and Bagalkot, Haliyal, and Ramdurg in Karnataka.

In the nutraceuticals sector, E.I.D. Parry has established itself as a global leader and innovator in the production of organic spirulina and other microalgal products. Its ‘Parrys Spirulina’ product, which holds three major international certifications, is distributed in over 41 countries worldwide. The specialized nutraceutical manufacturing facilities dedicated to microalgal production are located in Oonaiyur and Saveripuram, Tamil Nadu.

Additionally, the company maintains a significant role in the farm input market through its subsidiary, Coromandel International Limited, further diversifying its business portfolio.

☛ Triveni Engineering & Industries Limited

Triveni Engineering & Industries Limited was incorporated in 1932. The company is based in India and is actively involved in sugar production and also operates in various engineering sectors, including power transmission, water and wastewater treatment, and defense. The company is structured into two main segments: sugar and allied businesses, and engineering businesses.

In its sugar and allied business segment, Triveni Engineering specializes in producing white crystal sugar and operates approximately seven manufacturing facilities within Uttar Pradesh. A key aspect of its operation involves utilizing molasses, a by-product of sugar production, as the primary raw material for ethanol and extra-neutral alcohol production.

The company’s power transmission business is centered on the manufacture of high-speed gears and specialized low-speed gearboxes. This sector primarily serves original equipment manufacturers (OEMs), offers aftermarket services, and engages in the retrofitting of gearboxes. Its clientele spans various industries, including the power sector, diverse industrial segments, and the defense sector.

In the realm of water and wastewater management, Triveni Engineering provides custom-engineered process equipment and comprehensive solutions, demonstrating its commitment to tailored and effective environmental management strategies.

☛ The Andhra Sugars Limited

The Andhra Sugars Limited, established in 1947, specializes in manufacturing a diverse range of products including sugar, industrial alcohol, chlor-alkali products, aspirin, sulfuric acid, and both liquid and solid propellants. Additionally, the company is engaged in power generation, utilizing both renewable and non-renewable resources.

The company’s operations are categorized into five primary segments: sugars, chlor-alkali, power generation, industrial chemicals, and others. The other segment encompasses the production of bulk drugs, UH 25, monomethyl hydrazine (MMH), liquid hydrogen, and hydroxyl-terminated polybutadiene (HTPB).

In its product portfolio, Andhra Sugars Limited offers a range of products in the categories of sugars, pharmaceuticals, chemicals, and fertilizers. The sugar product line includes varieties such as Grade S31 and Sugar-Grade M31. The pharmaceutical range comprises various forms of salicylic acid, sodium salicylate, and aspirin in different standards including United States Pharmacopeia (USP), British Pharmacopeia (BP), Pharmacopeia Europaea (Ph.Eur.), and Indian Pharmacopeia (IP). In the realm of chemicals and fertilizers, the company produces items like poly aluminum chloride (POWDER 30 percent). This diverse product range underscores the company’s multifaceted manufacturing capabilities and its role in various industrial sectors.

Table 6 Key challenges within each supply chain

Chapter 3 Literature review

In this section, the research team reviewed literature relevant to the human rights principles and practices that recognized as international standards. The results of the review will be used for assessing the policies and practices of the top five companies in each supply chain. The details are shown below.

United Nations Guiding Principles on Business and Human Rights (UNGPs)

United Nations Guiding Principles on Business and Human Rights (UNGPs) is a framework developed and published by the Office of the United Nations High Commissioner for Human Rights (OHCHR) in 2011. It aims to be an authoritative framework for what can reasonably be expected of companies when it comes to preventing and addressing harm to people (Shift, Oxfam, and Global Compact Network Netherlands, 2016). The UNGPs are grounded in three key pillars (United Nations, 2011).

(a) States’ obligations to respect, protect, and fulfill human rights and fundamental freedoms.

(b) Business enterprises’ role as specialized organs of society, required to comply with all applicable laws and respecting human rights.

(c) The need for effective remedies to address breaches of rights and obligations.

The UNGPs is expected to apply to companies of every size, industry, country of operation or domicile, ownership structure, and equally to production and services companies. Besides, the responsibility to respect human rights extends through business relationships at any stage or tier of the company’s supply chain (Shift, Oxfam, and Global Compact Network Netherlands, 2016).

Source: https://shiftproject.org/resources/ungps101/

Human rights due diligence (HRDD)

Human rights due diligence (HRDD) is one of the core principles as outlined in the UNGPs. It is considered to be an international standard for human rights protection. The UNGPs outline Principles 17-22, which provide a framework for businesses to actively pursue human rights issues. Based on those principles, business organizations are expected to conduct their business responsibly by adhering to human rights principles to prevent and mitigate losses. There shall be an impact assessment for actual and potential human rights violations, and such impact shall be closely monitored and communicated to the public to ensure that those affected receive attentive care and remedy (National Human Rights Commission, 2018).

The essence of the principles set out the following HRDD practices for business:

Guiding Principle 17: To identify, prevent, mitigate, and account for how they address their adverse human rights impacts, business enterprises should carry out HRDD. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. HRDD:

(a) Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its activities, or which may be directly linked to its operations, products, or services by its business relationships;

Figure 9 Three Pillars of the UNGPs

(b) Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations;

(c) Should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.

Guiding Principle 18: To gauge human rights risks, business enterprises should identify and assess any actual or potential adverse human rights impacts with which they may be involved either through their activities or as a result of their business relationships. This process should:

(a) Draw on internal and/or independent external human rights expertise;

(b) Involve meaningful consultation with potentially affected groups and other relevant stakeholders, as appropriate to the size of the business enterprise and the nature and context of the operation.

Guiding Principle 19: To prevent and mitigate adverse human rights impacts, business enterprises should integrate the findings from their impact assessments across relevant internal functions and processes and take appropriate action.

(a) Effective integration requires:

(1) Responsibility for addressing such impacts is assigned to the appropriate level and function within the business enterprise;

(2) Internal decision-making, budget allocations, and oversight processes enable effective responses to such impacts.

(b) Appropriate action will vary according to:

(1) Whether the business enterprise causes or contributes to an adverse impact, or whether it is involved solely because the impact is directly linked to its operations, products, or services by a business relationship;

(2) The extent of its leverage in addressing the adverse impact.

Guiding Principle 20: To verify whether adverse human rights impacts are being addressed, business enterprises should track the effectiveness of their response. Tracking should:

(a) Be based on appropriate qualitative and quantitative indicators;

(b) Draw on feedback from both internal and external sources, including affected stakeholders.

Guiding Principle 21: To account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders. Business enterprises whose operations or operating contexts pose risks of severe human rights impacts should report formally on how they address them. In all instances, communications should:

(a) Be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences;

(b) Provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved;

(c) In turn, not pose risks to affected stakeholders, personnel or, legitimate requirements of commercial confidentiality.

Guiding Principle 22: Where business enterprises identify that they have caused or contributed to adverse impacts, they should provide for or cooperate in their remediation through legitimate processes.

The HRDD practices under the Principles of the UNGPs above are recognized as significant milestones and universal standard of human rights operation of the business sector over the past decade. International organizations have integrated the UNGPs, including the HRDD practices, into their standard. For example:

Corporate Human Rights Benchmark (CHRB)

World Benchmarking Alliance (WBA) is an organization operating at global, regional, and local levels to shape the private sector’s contributions to achieving sustainable development goals (SDGs) (World Benchmarking Alliance, n.d.). To support this mission, WBA has developed benchmarks as an essential tool for measuring and comparing corporate performance on the SDGs (World Benchmarking Alliance, n.d.).

The Corporate Human Rights Benchmark (CHRB) is one of the benchmarks developed by WBA. It provides a comparative snapshot of the largest companies evaluates their policies, processes, and practices for systematizing a human rights approach and how they respond to serious allegations (World Benchmarking Alliance, n.d.).

Nowadays, CHRB focuses on five sectors considered to be high risk for negative human rights impact which are (World Benchmarking Alliance, 2021)

● The apparel sector

● The automotive manufacturing sector

● The extractives sector

● The food and agricultural products sector

● The ICT manufacturing sector

CHRB is composed of five measurement themes, as follows.

● Theme A: Governance and policies - This theme focuses on a company’s human rightsrelated policy commitments and how they are governed.

● Theme B: Embedding respect and human rights due diligence - This theme assesses the extent of systems and processes established to implement the company’s policy commitments in practice.

● Theme C: Remedies and grievance mechanisms - This theme focuses on the extent to which a company provides remedies in addressing actual adverse impacts on human rights.

● Theme D: Company human rights practices - This theme focuses on selected human rights-related practices specific to each sector. The indicators seek to assess the actual practices occurring within companies to implement key enablers and business processes and to prevent specific impacts on human rights particularly at risk of occurring given the sector in question.

● Theme E: Responses to serious allegations - This theme focuses on responses to serious allegations of negative impacts a company may be alleged or reported to be responsible for by an external source.

Each theme contains a series of indicators based on the UNGPs, focusing on different aspects of how a business seeks to respect human rights across its operations and supply chain (World Benchmarking Alliance, 2021).

Figure 10 CHRB’s five measurement themes and individual weighting

Source: World Benchmarking Alliance (2021)

A.1.1

The research team used CHRB as a tool for assessing the policies and practices of the top 5 companies in each supply chain, which vary across different sectors. To simplify, the research team chose indicators considered ‘fundamental’ or a ‘minimum requirement’ for companies to disclose in their policies. These indicators should be commonly used in any sector. It can be stated that, at a minimum, companies should disclose their policies and practices corresponding to these indicators. The details are shown in the table below.

In this research, Theme D is excluded from our consideration because it focuses on selected human rights-related practices specific to each sector, which cannot be generalized in our study.

A.1.2.a

Commitment to respect human rights

A.1.2.b

Commitment to respect the human rights of workers: ILO Declaration on Fundamental Principles and Rights at Work

The company publicly commits to respecting all internationally recognized human rights across its activities. It must be clear that the commitment relates to all internationally recognized human rights, rather than to only one or more selected human rights. This only considers commitments to avoid adverse human rights impacts and does not include philanthropic commitments.

A.1.4

Commitment to respect the human rights of workers: Health and safety and working hours

The company publicly commits to respecting the principles concerning fundamental rights at work in the eight ILO core conventions as set out in the Declaration on Fundamental Principles and Rights at Work. It also has a publicly available statement of policy committing it to respect the human rights of workers in its business relationships.

Commitment to remedy

The company publicly commits to respecting the health and safety of workers and states that workers shall not be required to work more than 48 hours in a regular work week or 60 hours including overtime. The company also states that overtime work must be consensual and be paid at a premium rate. It also places equivalent expectations on its business relationships.

The company publicly commits to providing for or cooperating in remediation for affected individuals and workers and communities through legitimate processes (including judicial and non-judicial mechanisms, as appropriate), where it identifies that it has caused or contributed to adverse impacts.

Table 7 CHRB’s criteria for assessing human rights policies and practices

Indicator

A.1.5

Commitment to respect the rights of human rights defenders

A.2.1 Commitment from the top

The company publicly commits to not tolerating threats, intimidation, violence, punitive action, surveillance or physical, or legal attacks against human rights defenders, including those exercising their rights to freedom of expression, association, peaceful assembly, and protest against the business or its operations. It also places equivalent expectations on its business relationships. The company also commits to engaging with human rights defenders as part of operational processes of risk assessment and due diligence or supporting the work of human rights defenders to create a safe and enabling environment for the work of civil society in locations where it operates, at both local and national levels. (see also indicator C.5).

Note: The term ‘human rights defender’ is a broad and inclusive definition that refers to individuals or groups that, in their personal or professional capacity and in a peaceful manner, strive to protect and promote human rights. This includes affected communities, nongovernmental organizations and individuals, members of the media, lawyers, judges, academics, government officials and civil servants, or members of the private sector (including company employees.

The company’s human rights policy commitments are communicated at the board level and a board member or board committee oversees the company’s strategy, policies, and processes for respecting human rights. The board member or board committee possesses relevant knowledge, skills, and competence in the area of human rights. Board members or the chief executive officer (CEO) talk publicly about the company’s approach to addressing risks to people and the importance of human rights to the business.

Note: Management-level responsibility is assessed under indicator B.2.1. and therefore, not considered in this indicator

A.2.2 Board responsibility

A.2.3 Incentives and performance management

A.2.4 Business model strategy and risks

The company has processes in place at the board level to discuss and address human rights issues and how they fit within the company’s overall purpose and strategy, or a board committee regularly reviews the company’s strategy, policy, and management processes, as well as challenges and progress in managing human rights issues and provides examples of what was discussed. These discussions are informed by the experiences of affected stakeholders or external human rights experts.

The company provides incentives to the board linked to the implementation of its human rights policy commitments or targets. The company also reviews other board incentives to ensure coherence with its human rights policy commitments.

The company considers and addresses the impacts of its strategy and business model on the human rights of affected stakeholders at the board level. The term business model refers to the value a company seeks to deliver, and to whom and how it delivers that value in pursuit of commercial success. Where certain business models (e.g., fast fashion, gig-economy, depletion of natural resources) establish processes, incentives and practices that increase risks to workers, communities, or consumers, this can conflict with, or undermine, a company’s ability to respect human rights. Business model choices are linked to strategy and are governed by the board and shaped by senior management.

Indicator Heading Description

B.1.1

B.1.2

Responsibility and resources for day-to-day human rights functions

Incentives and performance management

B.1.3

B.1.4.a

B.1.4.b

B.1.5

Integration with enterprise risk management

Communication/ dissemination of policy commitment(s):

Workers and external stakeholders

Communication/ dissemination of policy commitment(s):

Business relationships

Training on human rights

The company outlines senior- level responsibility for human rights within the company as well as the organization of the day-to-day responsibility for human rights across relevant internal functions. This includes responsibility for the ILO core labor standards at a minimum. The company also allocates resources and expertise for the day-to-day management of human rights within its operations and business relationships.

Note: Board level responsibility is assessed under indicator A.2.1 and therefore not considered in this indicator.

The company provides incentives to senior managers linked to implementation of the company’s human rights policy commitments or targets. The company also reviews other senior managers incentives to ensure coherence with its human rights policy commitments.

The company integrates attention to human rights risks into its broader enterprise risk management system(s).

The company communicates its human rights policy commitment(s) to employees and other workers as well as to external stakeholders, in particular affected stakeholders. This includes the ILO core labor standards at a minimum.

The company communicates its human rights policy commitment(s) to its business relationships. In addition, it reflects its human rights commitments within the terms of its contracts (or other equivalent, binding arrangements) with business relationships (see also indicator B.1.7). This includes the ILO core labor standards at a minimum.

The company trains its workers and business relationships on its human rights policy commitment(s). This includes the ILO core labor standards at a minimum.

The company monitors the implementation of its human rights policy commitment(s) across its operations and business relationships and follows up on corrective actions and necessary changes to policies or processes and discloses its findings. The company involves workers in this process. This includes the ILO core labor standards at a minimum.

B.1.6

B.1.7

Monitoring and corrective actions

Engaging and terminating business relationships

Note: Indicators B.1.6 and B.2.3 are related but focus on different dimensions of a company’s actions: B.1.6 (which is in section B.1 on management systems) is about the company’s systemic approach to on-going monitoring and follow up on policy implementation while B.2.3 (which is in section B.2 on human rights due diligence) is about a specific step in the human rights due diligence process in addressing salient (or other) human rights risks and impacts

The company takes human rights considerations into account when deciding to engage or terminate business relationships. This includes offering incentives and support to business relationships to meet the company’s requirements.

B.1.8

Approach to engaging with affected stakeholders

The company has an approach to engaging with stakeholders on a regular basis. In doing so, it identifies affected stakeholders and engages in regular dialogue on human rights issues with them and their legitimate representatives. It also pays particular attention to those at heightened risk of vulnerability or marginalization and prohibits bribes or other favors that may divide communities. To facilitate informed engagement, the company provides meaningful information in accessible formats and languages.

Note: Engagement with affected stakeholders means engaging in a dialogue with the stakeholders who might be, or are, impacted by the company’s activities and/or with their legitimate representatives. Depending on the nature of the company’s operations, this can include (but is not limited to) workers, their families, local communities, consumers, and any other person or group of people whose life and environment might be impacted. Legitimate representatives are those that the affected stakeholders have asked to represent them. This can include (but is not limited to) community representatives, legal representatives and trade unions, community-based organizations and civil society organizations

B.2.1

Identifying human rights risks and impacts

B.2.2

Assessing human rights risks and impacts

B.2.3

B.2.4

Integrating and acting on human rights risks and impact assessments

The company proactively identifies its human rights risks and impacts on an on-going basis, including when these are triggered by key moments in the company’s activities (e.g. policy change, market entry, new projects). This includes engaging with stakeholders and vulnerable groups as part of the identification process.

Having identified its human rights risks and impacts, the company assesses them and then prioritizes its salient human rights risks and impacts. This includes engaging with stakeholders and vulnerable groups as part of the assessment process.

The company integrates the findings of its assessments of human rights risks and impacts into relevant internal functions and processes in order to take appropriate actions to prevent, mitigate or remediate its salient human rights risks and impacts. This includes engaging with stakeholders and vulnerable groups on any action taken or to be taken.

Note: Indicators B.1.6 and B.2.3 are related but focus on different dimensions of a company’s actions: B.1.6 (which is in section B.1 on management systems) is about the company’s systemic approach to on-going monitoring and follow up on policy implementation while B.2.3 (which is in section B.2 on human rights due diligence) is about a specific step in the human rights due diligence process in addressing salient (or other) human rights impact

Tracking the effectiveness of actions to respond to human rights risks and impacts

The company tracks and evaluates the effectiveness of actions taken in response to its human rights risks and impacts and describes how it uses that information to improve processes and systems on an ongoing basis. This includes engaging with stakeholders and vulnerable groups when evaluating the effectiveness of any action taken.

Indicator Heading Description

B.2.5 Communicating on human rights impacts

C.1

C.2

Grievance mechanism(s) for workers

C.3

Grievance mechanism(s) for external individuals and communities

The company communicates externally how it addresses its human rights impacts (i.e., throughout its due diligence process(es)) in a manner that is accessible to its intended audiences, especially affected stakeholders who have raised concerns, provides enough information to evaluate the adequacy of the response(s) and does not pose risks to affected stakeholders or personnel. Such communications should provide accurate, balanced, and complete information. This type of communication is distinct from engagement with affected stakeholders for the purposes of assessing or addressing specific impacts (see also indicators B.1.8, B.2.1 and B.2.2).

The company has one or more mechanisms (its own, third party or shared) through which workers can raise complaints or concerns, including in relation to human rights issues. The mechanism(s) are available to all workers and takes into account accessibility by marginalized groups. The mechanism(s) is not used to undermine the role of legitimate trade unions (or equivalent worker bodies where the right to freedom of association and collective bargaining is restricted under law) in addressing labor-related disputes, nor precludes access to judicial or other non-judicial grievance mechanisms. UN Guiding Principle 31 provides relevant criteria for the design and operation of such mechanisms.

The company has one or more mechanisms (its own, third party or shared) through which individuals and communities who may be adversely impacted by the company can raise complaints or concerns, including in relation to human rights issues. The mechanism(s) is available to all external individuals and communities and takes into account accessibility by marginalized groups. The mechanism(s) does not preclude access to judicial or other non-judicial grievance mechanisms. UN Guiding Principle 31 provides relevant criteria for the design and operation of such mechanisms.

C.4

Users are involved in the design and performance of the mechanism(s)

Procedures related to the grievance mechanism(s) are equitable, publicly available and explained

The company (or the initiative, in the case of a shared mechanism) engages with potential or actual users on the design, implementation, performance and improvement of the mechanism(s).

The company describes how complaints or concerns are received, processed and addressed. It also describes how those making complaints are informed throughout the process as well as how complaints may be escalated or withdrawn. In addition, the company takes steps to ensure equitable access to and participation in grievance process(es) through the provision of technical, financial or advisory support, as may be appropriate in light of the mandate, objectives and operations of the grievance mechanism(s). This includes an explanation of what outcomes the grievance mechanism(s) can and cannot offer to users in the form of remedy(ies) (including financial and non-financial).

C.5

Prohibition of retaliation for raising complaints or concerns

The company prohibits retaliation for raising complaints or concerns, including in relation to human rights issues. Retaliation can take many forms including physical, psychological, economic, or legal harm. In addition, retaliation may take place against many different people depending on the context, not only the person raising the complaint or concern, but also involving family, representatives, colleagues, trade union representatives, human rights defenders, witnesses, interpreters, friends, and others. Economic forms of retaliation can include negative actions connected with a person’s employment including demotion, disciplinary action, firing, salary reduction, job or shift reassignment, anti-union discrimination and blacklisting. Legal forms of retaliation can include vexatious litigation and strategic lawsuits against public participation (SLAPPs). These are civil, criminal, or administrative lawsuits without merit, but with the intent of preventing individuals or groups (including persons and organizations acting on their behalf) from engaging in criticism, opposition, public participation or similar activities in relation to a business’ operations.

C.7

Company involvement with state-based judicial and nonjudicial grievance mechanisms

The company does not impede access to state-based judicial or non-judicial mechanisms or other mechanisms (such as international mechanisms) for persons who make allegations of adverse human rights impacts. The company operates on the assumption that it will not require individuals to permanently waive their legal rights to bring a claim through a judicial or non-judicial process as a condition of participation in a grievance/mediation process and does not require confidentiality provisions (e.g., non-disclosure agreements) with respect to human rights grievances. It also does not impede access by competent authorities investigating and adjudicating credible allegations of human rights impacts. It participates in non-judicial grievance mechanisms provided by the state where these are available to resolve grievances

Remedying adverse impacts

C.8 Communication on the effectiveness of grievance mechanism(s) and incorporating lessons learned

E.1 The company has responded publicly to the allegation

The company provides for or cooperates in remediation to victims where it has identified that it has caused or contributed to adverse human rights impacts (or others have brought such information to the company’s attention, such as through its grievance mechanism(s)). It also incorporates changes to systems, processes (e.g., human rights due diligence processes) and practices to prevent similar adverse impacts in the future.

The company discloses information about the practical operation of the grievance mechanism(s) for its own workers and external individuals/ communities that may be adversely impacted by the company’s operations. This may include the types/nature of grievances filed, the number of complaints rejected and the grounds, and the outcomes and follow-up activities for completed cases. The company also describes how lessons from the mechanism contributed to improve its human rights management system and how it reviews the effectiveness of the grievance mechanism(s) on an ongoing basis to improve its functioning and address delays or non-implementation of outcomes agreed with stakeholders.

The company has responded publicly to the allegation and provided further details.

C.6

E.3

The company has investigated and taken appropriate action

The company has engaged with affected stakeholders to provide for or cooperate in remedy(ies)

The company has engaged with affected stakeholders to identify the causes of the impacts alleged. The company also reviewed and improved its management systems, informed by the views of affected stakeholders and/or their legitimate representatives, to prevent similar impacts from occurring in the future

The company has provided remedy to affected stakeholders. The company also demonstrates that the remedy offered is satisfactory to affected stakeholders and that it has been provided as agreed. If the company was not involved in the alleged impact(s), it provides evidence to demonstrate this.

Note: In circumstances where the company is unable to locate the relevant stakeholder(s) to have a dialogue or provide remedy for reasons of anonymity, the CHRB still expects the company to review its management systems and to engage in a dialogue with stakeholders, interpreted as the stakeholder type, not the specific alleged victims (e.g., individuals in similar working and living conditions in the same region, depending on the allegation).

Source: Revised from CHRB’s 2021 methodology.

Chapter 4 Assessment of the human rights policies of the top 5 companies within each supply chain

The research team assessed the policies and practices publicly disclosed on the websites of the top 5 companies within each supply chain. Blue ( ) indicates policies that are in full alignment with CHRB criteria. Orange ( ) indicates policies that are partially aligned with CHRB criteria. N.A. indicates that no policy is disclosed, or no relevant information is available.

We could summarize the policies of the top 5 companies in the following supply chain (as shown in Table 8–12):

● Seafood supply chain in Thailand

● Maize supply chain in Myanmar

● Sugar supply chain in India

● Rice supply chain in Cambodia

● Medicinal plant supply chain in Myanmar

To be noted, we found that no top 5 companies in the following supply chain disclose any human rights-related policies:

● Cashew supply chain in Cambodia

● Mining supply chain in Myanmar

● Rubber supply chain in Cambodia

A.1.1

Commitment to respect human rights

Table 8 Policies of top 5 seafood companies in Thailand compared with CHRB’s criteria

Among the top 5 seafood companies in Thailand, only Charoen Pokphand Foods (CPF), Kiang Huat Sea Gull Trading Frozen, and Thai Union Group disclose human rights-related policies that are aligned with some or all of CHRB criteria. Marine Gold Products and Golden Seafood International do not disclose any human rights-related policies that are aligned with CHRB.

Details of human rights-related policies at CPF, Kiang Huat, and Thai Union Group are summarized in the following Table:

Note: = partial alignment with CHRB, = complete alignment with CHRB and n.a. = not disclosed

The company publicly commits to respecting human rights as stated in the Universal Declaration of Human Rights (UDHR), the United Nations Guiding Principles on Business and Human Rights (UNGP), and the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work.

The company states its commitment to upholding internationally proclaimed human rights, as expressed in the United Nations Guiding Principles on Business and Human Rights (UNGPs), the United Nations Declaration on the Rights of Indigenous Peoples, and the ILO’s Declaration on Fundamental Principles and Rights at Work, and acknowledges its responsibility to prevent violations in its operations and value chain while addressing any associated human rights impacts.

A.1.2.a

Commitment to respect the human rights of workers: ILO Declaration on Fundamental Principles and Rights at Work

The company publicly commits to respecting the human rights of workers as reflected in the ILO Declaration on Fundamental Principles and Rights at Work. Additionally, it also publicly states that its business relationships are required to sign the Sustainable Sourcing Policy and Supplier Guiding Principle before working with the company.

n.a.

The company publicly commits to respecting the human rights of workers as reflected in the ILO Declaration on Fundamental Principles and Rights at Work. Additionally, it also publicly states that its business relationships are required to sign the Supplier’s Business Ethics and Labor Code of Conduct before working with the company.

CHRB Indicator

Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Thai Union Group Public Company Limited

A.1.2.b

Commitment to respect the human rights of workers: Health and safety and working hours

The company publicly commits to respecting the health and safety of its workers, emphasizing that overtime work is consensual and will be compensated according to Thai labor law regulations. Additionally, it publicly mandates that business partners must adhere to the Sustainable Sourcing Policy and Supplier Guiding Principle before engaging in any collaboration with the company. However, Thai labor law on overtime work exceeds 60 hours per week.

The company publicly commits to respecting the health and safety of workers, emphasizing that working overtime is voluntary and is rewarded as overtime pay by Thai labor law. However, it does not publicly mandate that business partners must adhere to its labor policy, and Thai labor law on overtime work exceeds 60 hours per week.

The company publicly commits to respecting the health and safety of workers, emphasizing that working overtime is voluntary and is rewarded as overtime pay by the labor law of the country. Additionally, it publicly mandates that business partners must adhere to the Supplier’s Business Ethics and Labor Code of Conduct before engaging in any collaboration with the company. However, the labor law of its operating countries varies, for example, Thai labor law does not specify that overtime work is permitted for 60 hours per week at maximum.

A.1.4

Commitment to remedy

The company publicly commits to remediating affected stakeholders of human rights violations through a legitimate process.

A.1.5

Commitment to respect the rights of human rights defenders

A.2.1

Commitment from the top

The company sets up the Corporate Social Responsibility and Sustainable Development Committee to formulate sustainability plans and strategies, oversee sustainability practices and performances, and communicate them to stakeholders through public disclosure. Human rights issues constitute a crucial component of the company’s three sustainability ambitions. However, the company does not specify the requirement of possessing human rights-related competence in the qualification of board members. n.a.

The company publicly commits to providing remedies or facilitating access to remedies for affected individuals in the cases where it causes or contributes to adverse human rights impacts.

Although the company showcases an example of supporting a human rights defender, it does not publicly state its commitment to respecting the rights of human rights defenders.

The company establishes a Sustainable Development Committee tasked with overseeing and controlling the company’s operations to ensure compliance with set goals and obligations, which include but are not limited to tuna sourcing and human rights-related policies. However, the company does not specify the requirement of possessing human rights-related competence in the qualification of board members.

CHRB Indicator Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Thai Union Group Public Company Limited

A.2.2

Board responsibility

A.2.3

Incentives and performance management

The company states that the Board of Directors is responsible for monitoring and evaluating the performance to ensure continuous development and improvement across various sustainability dimensions, including human rights. However, the company does not explicitly state that the discussions are informed by the experiences of affected stakeholders and external human rights experts.

The company sets up the Risk Management Committee to discuss potential risks, including human rights issues in its supply chain. However, the company does not explicitly state that the discussions are informed by the experiences of affected stakeholders and external human rights experts.

The company sets up the Sustainable Development Committee, to verify and validate the materiality assessment, including human rights issues, and ensure that the material topics are aligned with the impacts created by the Thai Union’s activities. The process of materiality assessment is informed by 12 stakeholders, including investors, suppliers, customers, end customers, employees, daily/migrant workers, communities, government, NGOs, international organizations, academia, and media.

A.2.4

Business model strategy and risks

The company provides incentives to the board, as executive compensation is tied to both financial and non-financial performance dimensions, including sustainability, social responsibility, and environmental responsibility. However, the company does not explicitly state that this compensation policy is linked to the implementation of human rights policy commitment.

The company conducts a materiality assessment through workshops to exchange opinions with relevant stakeholders, both internal and external. The aim is to identify and prioritize issues of utmost concern to them. This process helps pre-determine material topics, such as human rights and labor practices, to be further integrated into the company’s enterprise risk. The materiality assessment, which has been considered and approved by the Board of Directors, has contributed to the development of the 2030 Sustainability in Action initiative, which encompasses three pillars: Food Security, SelfSufficient Society, and Balance of Nature. Notably, human rights is an integral component of the SelfSufficient Society pillar.

The company conducts a materiality assessment by interviewing 80 stakeholders, both internal and external, to identify and prioritize issues of utmost concern to them. This process evaluates the impact on stakeholders within and outside the organization, helping predetermine material topics to be further integrated into the company’s enterprise risk. Human rights and employment practices emerge as the primary material concerns. The materiality assessment, which has been reviewed and approved by the Board-level Sustainable Development Committee, has contributed to the development of Thai Union’s SeaChange strategy, notably the “Safe & Legal Labor” pillar, aimed at providing safe, legal, and freely chosen employment in both facilities and supply chain.

CHRB Indicator Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Thai Union Group Public Company Limited

B.1.1

Responsibility and resources for day-to-day human rights functions

The company outlines the responsibilities of senior managers within the human resources unit in the grievance process, emphasizing their role in continuous monitoring and evaluation of performances to foster ongoing development and improvement across various sustainability dimensions, notably human rights. However, it does not clearly specify their responsibility reaches the ILO core labor standards at a minimum.

B.1.2

Incentives and performance management

B.1.3

Integration with enterprise risk management

B.1.4.a

Communication/ dissemination of policy commitment(s):

Workers and external stakeholders

The company provides incentives to all levels of employees, including senior managers, since executive compensation depends on both financial and nonfinancial performance dimensions, including sustainability, social responsibility, and environmental responsibility. However, the company does not explicitly state that this compensation policy is linked to the implementation of human rights policy commitment.

The company considers human rights and labor practices as one of the primary issues of materiality assessment.

The company communicates its human rights policy commitments, including adherence to the ILO core labor standards, to employees, and workers, via several channels including posters, brochures, training, website, Facebook, CPF Connect application, and e-mail, to ensure the understanding of their rights. Moreover, the company ensures that external stakeholders are informed by providing regular public disclosure, including annual report and sustainability report.

The company sets up the Risk Management Committee, which delegates the responsibility to the management team for regular identification of both internal and external risk factors and conducting assessments of their impacts on the company’s business. The risk management team systematically analyzes targeted risk factors to identify root causes and deliver effective countermeasures. However, it does not clearly specify their responsibility reaches the ILO core labor standards at a minimum.

The company considers human rights to be the issue with the highest materiality level in overall risk assessment.

The company communicates its human rights policy commitments, including adherence to the ILO core labor standards, to workers by requiring employees to sign a Code of Conduct prior to employment. Moreover, the company ensures that external stakeholders are informed by providing regular public disclosure, including annual report and sustainability report.

CHRB Indicator Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Thai Union Group Public Company Limited

B.1.4.b

Communication/ dissemination of policy commitment(s): Business relationships

The company communicates its human rights policies, including adherence to the ILO core labor standards, to its business relationships by demanding its partners adhere to the Sustainable Sourcing Policy and Supplier Guiding Principles before engaging in any collaboration with the company.

n.a.

B.1.5

Training on human rights

B.1.6

Monitoring and corrective actions

The company partners with the Labour Protection Network (LPN) to provide capacity building training on human rights and labor practices to employees, workers, contractors, and business partners. This initiative aims to ensure their understanding and recognition of human rights in alignment with Thai labor law and ILO standards.

The company monitors and evaluates the implementation of human rights policy across its operations and business relationships, using stakeholder engagement strategy, in order to correct and prevent human rights violations, as well as to improve the effectiveness of the existing measures. Additionally, the company respects and commits to the ILO core standards. For, stakeholder engagement channels, see detail at B.1.8.

The company publishes Supplier’s Business Ethics and Labor Code of Conduct as well as Vessel Code of Conduct (VCoC) and Vessel Improvement Program (VIP), as the guidelines to prevent its business partners from being involved in human rights violations. Moreover, its business partners are required to sign a letter of acknowledgment beforehand. Additionally, its human rights policies adhere to ILO core labor standards.

The company, together with its partners, including ILO and LPN, provides training on the Business Ethics and Labor Code of Conduct, which includes ILO core labor standards, to workers and suppliers for capacity building on human and labor rights.

The company monitors and evaluates the implementation of human rights policy across its operation and business relationships, to improve the existing measures by engaging with affected stakeholders. Additionally, it organizes an active dialogue with industry, government, and civil society to ensure lasting improvements in labor practices across the entire industry. Furthermore, the company respects and commits to the ILO core standards.

CHRB Indicator Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited Thai Union Group Public Company Limited

B.1.7

Engaging and terminating business relationships

B.1.8

Approach to engaging with affected stakeholders

The company takes human rights issues into consideration when considering mergers and acquisitions. Moreover, since its business partners are required to embrace the Sustainable Sourcing Policy and Supplier Guiding Principles documents, it implies that wrongdoings could lead to terminating business relationships.

In addition to the whistleblower channel, the company establishes various engagement channels with affected stakeholders, tailored to the specific needs of each stakeholder. For business partners, the company organizes , and online meeting. and offline meetings, seminars, and audits. For customers, the company conducts surveys, online meetings. site visits, and audits. For employees and families, the company organizes town halls, open dialogues, meetings, employee satisfaction surveys, and quarterly Welfare Committee, and Safety Committee meetings. For communities and societies, the company conducts surveys, field visits, and dialogue.

The company engages in a dialogue with local communities and other stakeholders to incorporate their opinions on its business operations.

The company mandates its business partners to sign a code of conduct that includes human rights practices, underscoring that non-compliance may lead to suspension unless prompt remedial actions are implemented.

B.2.1

Identifying human rights risks and impacts

The company conducts regular Human Rights Risk Assessments (HRRA) and Human Rights Impact Assessments (HRIA), to identify risks, assess potential impacts, and mitigate potential human rights impacts throughout its operations and value chains. This process incorporates stakeholder engagement.

The company conducts HRRA on both its business partners and its own operations. However, it does not mention stakeholder engagement within the process.

In addition to the whistleblower channel, the company establishes various engagement channels with affected stakeholders, tailored to the specific needs of each stakeholder. For suppliers, the company organizes regular meetings. For customers, the company organizes regular meetings and conducts satisfaction survey. For employee and daily/migrant workers, the company organizes town halls and employee engagement surveys. For communities, the company arranges communication through community development officers.

The company regularly conducts HRRA and HRIA, to identify risks, evaluate potential impacts, and address potential human rights concerns within its operations and value chains. Additionally, the company actively engages with both internal and external stakeholders to conduct sustainability risk assessments.

CHRB Indicator Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Thai Union Group Public Company Limited

B.2.2

Assessing human rights risks and impacts

B.2.3

Integrating and acting on human rights risks and impact assessments

The company assesses and prioritizes salient human rights risks and impacts in its own operations, in joint ventures under its management control, and among its suppliers. The process also incorporates active engagement with stakeholders.

The company provides appropriate risk management guidelines or control measures, of which all business units are in charge of ensuring that the risk management process, including its value chains, is fully implemented in their areas of responsibility.

B.2.4

Tracking the effectiveness of actions to respond to human rights risks and impacts

B.2.5

Communicating on human rights impacts

The company monitors and evaluates the implementation of mitigation measures with the aim of continuously improving them. This process includes conducting stakeholder engagement to effectively tackle potential human rights violations.

The company publicizes the outcomes of its Human Rights Risk Assessments (HRRA) and Human Rights Impact Assessments (HRIA) through channels such as sustainability reports, annual reports, and the company’s website. In addition, various policy documents are published, and communication efforts are directed toward workers to enhance their awareness of existing policies. However, the company does not provide enough information to evaluate the adequacy of its responses to affected stakeholders.

The company assesses and prioritizes salient human rights risks and impacts in its own operations, in majority owned companies, and among its suppliers. The process also incorporates active engagement with stakeholders.

The company implements policies and measures aimed at preventing or minimizing the risks of human rights violations within its operations and value chain. These initiatives encompass various actions, including vessel audits and the strengthening of internal grievance mechanisms. Additionally, the company actively seeks assistance from external organizations such as welfare agencies, specialized CSOs, or local entities with expertise to ensure effective remedies when necessary.

The company monitors and evaluates the implementation of mitigation measures with the aim of continuously improving them. Additionally, it also collaborates with independent researchers to conduct evaluations on the effectiveness of its policies.

The company publicizes its findings of HRRA and HRIA through annual reports, sustainability reports, webpages, public forums, and other channels. In addition, various policy documents are published, and communication efforts are directed toward workers to enhance their awareness of existing policies. However, the company does not provide enough information to evaluate the adequacy of its responses to affected stakeholders.

CHRB Indicator Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Thai Union Group Public Company Limited

C.1

Grievance mechanism(s) for workers

C.2

Grievance mechanism(s) for external individuals and communities

C.3

Users are involved in the design and performance of the mechanism(s)

C.4

Procedures related to the grievance mechanism(s) are equitable, publicly available and explained

The company partners with the LPN to establish the Labor Voices Hotline for reporting complaints and allegations of human rights and labor rights violations. Additionally, it publicly commits to upholding employees’ rights to join or establish lawful associations and engage in collective bargaining, following legal procedures.

The company establishes two channels, one on the website and another via postal means, for workers to raise complaints to the independent body, the Audit Committee, for further investigation. Additionally, it publicly commits to upholding employees’ rights to join or establish lawful associations and engage in collective bargaining, following legal procedures.

The company sets several channels for workers to raise complaints, including town hall, Speak Out platform (reporting hotline), email, telephone, informal conversation during Employee Relations Patrol, Welfare committee, and NGO partners’ hotline and outreach. Additionally, it publicly commits to upholding employees’ rights to join or establish lawful associations and engage in collective bargaining, following legal procedures.

The company establishes several channels including email, letters, website, and whistleblower channels for many stakeholders, including external individuals, and communities to raise complaints, or report human rights misconducts.

The company establishes two channels, one on the website and another via postal means, for external stakeholders to raise complaints to the independent body, the Audit Committee, for further investigation.

n.a.

The company outlines the process for handling grievances through the LPN center. Additionally, all reported cases will be made publicly accessible on a bulletin board, providing detailed information to keep workers affected stakeholders informed.

The company outlines the complaint management process, stating that after receiving a complaint, the chair of the Audit Committee will instruct the secretary to forward it to the specific body implicated in the complaint for investigation. Subsequently, the findings will be reported back to the board committee.

The company sets several channels, including email, post, and whistleblower channel for individuals and communities to raise complaints, or report human rights misconducts.

The company sets up consultation process between the human resource and the affected individuals to ensure that their perspectives are taken into account in designing and monitoring the effectiveness of remedies.

The company outlines the complaint management procedure on the website. Additionally, it publishes the Guidelines for Remediation to Affected Individuals, which is accessible on the website as well.

CHRB Indicator Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Thai Union Group Public Company Limited

C.5

Prohibition of retaliation for raising complaints or concerns

The company publishes a whistleblowing policy, in a bid to protect whistleblowers, including employees, business partners, third parties, and other external stakeholders, from any threats, including dismissal, suspension, change in position, or disciplinary punishment. However, the company’s whistleblowing policy does not extend beyond whistleblowers to anyone who raises complaints or concerns in relation to human rights issues. n.a.

The company publishes a non-reprisal policy to prohibit all forms of retaliation against any whistleblowers including employees, officers, directors, or any external person (ex. consultant, client, supplier, contractor, or family member of an employee), while simultaneously ensuring the confidentiality of whistleblowers’ identities and confidential investigation. However, the company’s non-reprisal policy does not extend beyond whistleblowers to anyone who raises complaints or concerns in relation to human rights issues.

C.6

Company involvement with statebased judicial and non-judicial grievance mechanisms

C.7

Remedying adverse impacts

The company commits to providing reasonable remedies in cases of violations, monitoring, and reporting performance, and regularly reviewing policy commitments to maximize effectiveness in human rights management. However, for the year 2022, as no human rights violation cases were reported, there were no remediation measures deemed necessary or undertaken.

The company publishes the Guidelines for Remediation to Affected Individuals, to ensure the effectiveness of the remedial action and preventive measures.

CHRB Indicator Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Thai Union Group Public Company Limited

C.8

Communication on the effectiveness of grievance mechanism(s) and incorporating lessons learned

The company discloses information regarding its operation of the grievance mechanism, Labor Voices Hotline. Thus far, a total of 15 calls were made between 2018 and 2022 by both Thai and migrant workers but there is no case related to human rights violation. The company also describes its management process, including developing procedures for greater efficiency in preventing future errors. However, the company does not provide clear information on receiving feedback for Improving the function of the grievance mechanism.

The company reports that no complaints were filed in the year 2022. However, the company does not provide clear information on receiving feedback for Improving the function of the grievance mechanism.

The company reports that two complaints related to business and policy misconduct were filed. However, it does not disclose any further results of the ongoing cases.

The company has responded publicly to the allegation

E.2

The company has investigated and taken appropriate action

E.3

The company has engaged with affected stakeholders to provide for or cooperate in remedy(ies)

CHRB Indicator Charoen Pokphand Foods Public Company Limited (CPF)

Kiang Huat Sea Gull Trading Frozen Food Public Company Limited

Thai Union Group Public Company Limited

A.1.1

Table 9 Policies of top 5 maize companies in Myanmar compared with CHRB’s criteria

Among the top 5 maize companies in Myanmar, only CPP Myanmar and Myanmar Awba Group disclose human rights-related policies that are aligned with some or all of CHRB criteria. Corteva Agriscience (Myanmar), East West Seed Myanmar, and Limagrain Myanmar do not disclose any human rightsrelated policies that are aligned with CHRB.

Details of human rights-related policies at CPP Myanmar and Myanmar Awba Group are summarized in the following table:

Note: = partial alignment with CHRB, = complete alignment with CHRB and n.a. = not disclosed

Commitment to respect human rights

A.1.2.a

Commitment to respect the human rights of workers: ILO Declaration on Fundamental Principles and Rights at Work

The company commits to respecting human rights and expanding the scope of labor practices across its operations of employees, customers, business partners, and stakeholders in the supply chain. This commitment aligns with globally recognized principles, including the United Nations Universal Declaration of Human Rights (UDHR), the Ten Principles of the United Nations Global Compact (UNGC), UN Guiding Principles on Business and Human Rights (UNGPs), the International Labor Organization’s (ILO) Declaration on the Principles and Fundamental Rights at Work, and local labor laws in each country where the company operates.

The company commits to respecting human rights and expanding the scope of labor practices across its operations of employees, customers, business partners, and stakeholders in the supply chain. The company states guidelines for respect of human rights that align with ILO core conventions as follows:

• Any restrictions on freedom of expression and freedom to participate in political activities are not allowed

• Employees are entitled to rests during working days, working hours that do not exceed local labor laws, and remuneration during public holidays.

• Do not engage in or support forced labor in all operations.

• Non-discrimination in respect of employment and occupation.

• Salaries, wages, and benefits are to be paid on time, in compliance with legal requirements.

• Respect the right of assembly and association.

The company commits to respecting human rights in its operations aligns with global labor standards including the UDHR, the ILO Declaration on Fundamental Principles and Rights at Work, and the UNGC.

The company commits to respecting human rights in its operations aligns with global labor standards including the UDHR, the ILO Declaration on Fundamental Principles and Rights at Work, and the UNGC. Additionally, the company has developed the Workplace Rights Policy, which is aligned with international human rights standards. The policy includes the following components

• Freedom of Association and Collective Bargaining

• Forced Labor

• Child Labor

• Discrimination

• Work Hours and Wages

• Safe and Healthy Workplace

• Workplace Security

• Community and Stakeholder Engagement

CHRB Indicator Indicator name

CPP Myanmar

Myanmar Awba Group

A.1.2.b

Commitment to respect the human rights of workers: Health and safety and working hours

The company states that employees are entitled to rests during working days, working hours that do not exceed local labor laws and remuneration during public holidays. However, the company does not state the number of working hours according to the ILO standard.

A.1.4

Commitment to remedy

n.a.

The company states that it compensates employees competitively relative to the industry and local labor market. It operates in full compliance with applicable wage, work hours, overtime, and benefits laws. It also offers employees opportunities to develop their skills and capabilities and provide advancement opportunities where possible.

Work Hours

a. Working hours for office staff

• From Monday to Friday: 9 am to 5pm

• Saturday: 9 am to 12 Non

b. Working hours for factory staff

• From Monday to Friday: 8 am to 5 pm, Lunchtime: 12 Non – 1 pm

• Saturday: 8:00 am to 12 Non

Overtime

a. The overtime could be worked with the agreement between employer and employee in accordance with the provisions of law.

b. The overtime pay shall be calculated and paid according to the specifications of the relevant law.

However, the company does not state the number of overtimes according to the ILO standard.

The company commits to engaging with stakeholders in its supply chain and community. The company states that it has been listening to the opinions of the community regarding the impact of the company’s operations on the community. Although the company discloses the guidelines for stakeholder engagement, it does not state that it commits to providing for or cooperating in remediation for affected individuals, workers, and communities through legitimate processes.

A.2.1

Commitment from the top

B.1.1

Responsibility and resources for day-to-day human rights functions

The company states that the board of directors is responsible for ensuring that the human rights and labor practices policy and guidelines are in place to prevent violations of human rights in all business activities, including in its business value chains and joint ventures.

The company states the roles and responsibilities of managers, which include establishing the procedures of human rights as appropriate to the company context, ensuring the presence of the organizational structure and related functions, and monitoring the effective implementation of policies, guidelines, and regulations.

Additionally, the company defines the Human Rights Department to be responsible for human rights operations, which include communicating concepts and building up knowledge of human rights for employees and stakeholders throughout the supply chains, completing the human rights due diligence process, and reporting the company’s compliance of human rights and labor practices to the board of directors or management at least once annually.

The company states that the board is responsible for validating, reviewing, and overseeing the implementation of the workplace rights policy and human rights policy.

B.1.4.a

Communication/ dissemination of policy commitment(s): Workers and external stakeholders

B.1.4.b

Communication/ dissemination of policy commitment(s): Business relationships

The company sets up the Human Rights Department to communicate its human rights policy commitments, including adherence to the ILO core labor standards, to employees, and workers to ensure the understanding of their rights. Moreover, the company ensures that external stakeholders are informed by providing public disclosure, including the document of policy on the website and sustainability reports.

The company communicates its human rights policies and labor practices, based on the UNGC, the ILO core labor standards, and local labor laws, to business partners through demanding its partners to adhere to the Supplier Code of Ethics before engaging in any collaboration with the company.

B.1.6

Monitoring and corrective actions

C.1

Grievance mechanism(s) for workers

The company states that it monitors the operations of its own organization and business relationships to align with human rights policies. However, the company does not state that it monitors business relationships to ensure compliance with ILO standards.

C.2

Grievance mechanism(s) for external individuals and communities

The company provides channels for receiving complaints from employees through email, letters, and websites ( https://grc. cpgroupsustainability.com/GRC/Whistle blower/WBForms/GlobalWB ). The company has specified the scope of receiving complaints in 4 topics follows:

1. Behaviors related to any outright illegal activity, including corruption, misappropriation of assets, and bribery.

2. Behaviors related to fraudulent activity or producing fraudulent financial statements intended to deceive others by showing falsified information or concealing information that should be disclosed.

3. Behaviors related to maintaining transactions that violate the law, the Code of Conduct, rules, and regulations.

4. Behaviors related to discrimination, harassment, and unethical practices.

The company has established channels for receiving complaints from employees through the supervisor, head of human resources, group chief financial officer, or the labor union. The company has specified the scope of receiving complaints as follows:

• unlawful acts or orders that lead to violation of a law, gross wastage, mismanagement, abuse of authority, substantial and specific dangers to public health or safety

• failures to comply with statutory obligations or regulatory requirements

• fraud and corruption

• breach of Code of Conduct

• coercive practices

• collusive practices

• any other activities that undermine the operations, mission, and reputation.

The company states that stakeholders, including directors, management, staff, suppliers, and business partners, are allowed to report if they encounter behaviors involving corruption, fraud, legal violations, discrimination, harassment, and unethical practices. However, the company does not state that individuals and communities who may be adversely impacted by the company can raise complaints or concerns.

C.4

Procedures related to the grievance mechanism(s) are equitable, publicly available and explained

The company discloses a process for receiving complaints and informing the complainant, starting from the process of collecting complaints, screening, and reporting the results to the complainant. However, the company does not clearly state the provision of technical, financial, or advisory support to ensure equitable access to and participation in its grievance mechanism.

The company discloses its whistleblowing handling process as follows:

1. Promptly upon receipt of a whistleblowing report, the supervisor should report the incident to the Head of Human Resources who will advise the Chief Financial Officer and Group CEO. The Chief Financial Officer and Group CEO shall assess the severity of the alleged misconduct. If the matter is assessed to be minor or frivolous and does not warrant further investigations, they shall resolve the matter as they deem fit.

2. If the report warrants further investigation, the Group CEO will convene an Inquiry Committee comprising independent persons that may include senior employees from the management team, internal and external auditors, or consultants as may be appropriate.

3. All documentation pertaining to the complaint including but not restricted to the investigation report, corrective action taken, and evidence will be maintained for a period of not less than 3 years from the date of disposal of the Complaint.

However, the company does not disclose any process for handling human rights-related complaints.

A.1.1

Commitment to respect human rights

Table 10 Policies of top 5 sugar companies in India compared with CHRB’s criteria

Among the top 5 sugar companies in India, we find that all companies do disclose their commitment to respecting human rights, however, none goes beyond high-level commitment and references to the UN conventions. Therefore, such high-level statement of commitment is the only disclosure that we find to be at least in partial alignment with CHRB criteria.

Details of such human rights-related policies at all companies are summarized in the following table:

Note: = partial alignment with CHRB, = complete alignment with CHRB and n.a. = not disclosed

The company publicly commits to respecting human rights as enshrined in the Constitution of India, national laws, and policies, as well as the International Bill of Human Rights guidelines. However, it does not explicitly state its adherence to the principles of internationally recognized human rights frameworks, including the Universal Declaration of Human Rights (UDHR), the United Nations Guiding Principles on Business and Human Rights (UNGP), and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work.

The company publicly commits to respecting the human rights of all individuals it interacts with, both directly and indirectly. However, it does not clearly articulate its adherence to internationally recognized human rights frameworks, including the UDHR, UNGP, and ILO Declaration on Fundamental Principles and Rights at Work.

The company publicly commits to respect and promote human rights in its relationship with employees and people involved in value chain. However, the company does not clearly specify that it respects the principles of internationally recognized human rights such as the UDHR, UNGP, and ILO Declaration on Fundamental Principles and Rights at Work.

The company publicly commits to comprehending the human rights provisions within the Constitution of India, national laws, and policies, as well as the guidelines of the International Bill of Human Rights. It acknowledges the inherent, universal, indivisible, and interdependent nature of human rights. However, it does not explicitly specify its respect for the principles outlined in key internationally recognized human rights documents, such as the UDHR, UNGP, and ILO Declaration on Fundamental Principles and Rights at Work.

The company publicly commits to respect the rights and dignity of all individuals and upholds the principles of human rights. The company’s commitment to human rights and fair treatment is set out in its code of conduct. The policy provides conduct of operations with honesty, integrity, and openness with respect for human rights and interests of employees. However, the company does not clearly specify that it respects the principles of internationally recognized human rights such as the UDHR, UNGP, and ILO Declaration on Fundamental Principles and Rights at Work.

CHRB Indicator Uttam Sugar Mills Limited K.P R. Mill Limited

E.I.D. Parry India Limited Triveni Engineering & Industries Limited

The Andhra Sugars Limited

A.1.2.b

Commitment to respect the human rights of workers: Health and safety and working hours n.a.

The company offers competitive compensation to its employees, aligning with industry standards and the local job market, while adhering to the conditions set by relevant collective bargaining agreements. It guarantees adherence to laws governing wages, working hours, overtime, and employee benefits. The India Factories Act (1948) mandates that workers under the Factory Act must not be made to work more than 48 hours a week, and the maximum allowed overtime, according to the Factories Act, is one hour daily, with the entire day, including breaks, not exceeding 12 hours.

CHRB Indicator Uttam Sugar Mills Limited K.P R. Mill Limited

E.I.D. Parry India Limited

Triveni Engineering & Industries Limited

The Andhra Sugars Limited

A.1.1

Table 11 Policies of top 5 rice companies in Cambodia compared with CHRB’s criteria

Among the top 5 rice companies in Cambodia, only Signatures of Asia and Golden Rice (Cambodia) disclose human rights-related policies that are aligned with some CHRB criteria. Green Trade Company, Soma Trading, and Baitung (Kampuchea) do not disclose any human rights-related policies that are aligned with CHRB.

In addition, both Signatures of Asia and Golden Rice (Cambodia) only disclose high-level and blanket commitment to respecting human rights, without any reference to relevant UN conventions or standards such as the UNGPs. Details of such human rights-related policies at both companies are summarized in the following Table:

Note: = partial alignment with CHRB, = complete alignment with CHRB and n.a. = not disclosed

Commitment to respect human rights

The company discloses that all contract farmers must abide by a set code of conduct. It addresses human rights concerns in some areas, such as prohibiting child labor. This involves enforcing a policy that prohibits minors from being involved in any aspect of the cultivation process. However, the company’s policy lacks reference to internationally recognized human rights principles.

The company states its commitment to international human rights principles. However, there is no explicit reference to specific human rights conventions or standards, e.g. UN human rights conventions or UNGPs.

A.1.2.a

Commitment to respect the human rights of workers: ILO Declaration on Fundamental Principles and Rights at Work

n.a.

The company states its commitment to international labor rights principles. However, there is no explicit reference to ILO core conventions.

CHRB Indicator

Signatures of Asia Co., Ltd.

Golden Rice (Cambodia) Co., Ltd.

Table 12 Policies of top 5 medicinal plant companies in Myanmar compared with CHRB’s criteria

Among the top 5 medicinal plant companies in Myanmar, we find that only SGS Myanmar Limited disclose commitment to human rights, although no company goes beyond high-level commitment and references to ILO conventions. Sein Wut Hmon Co., Ltd., Pacific- AA Group Limited, Shan Maw Myae Co., Ltd., and FAME Pharmaceuticals Industry Co., Ltd. do not disclose any human rights-related policies that are aligned with CHRB.

Details of human rights-related policies at SGS Myanmar Limited are summarized in the following Table:

Note: = partial alignment with CHRB, = complete alignment with CHRB and n.a. = not disclosed

Indicator

A.1.1

Commitment to respect human rights

SGS Myanmar Limited

The company publicly commits to respecting the International Bill of Human Rights and the International Labor Organization (ILO)’s Declaration on Fundamental Principles and Rights at Work, including its eight core conventions.

A.1.2.a

Commitment to respect the human rights of workers: ILO Declaration on Fundamental Principles and Rights at Work

A.1.2.b

Commitment to respect the human rights of workers: Health and safety and working hours

The company embraces and follows the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, along with its eight core conventions, all of which it respects.

The company adheres to international human rights and labor standards, ensuring worker safety and fair working conditions. It provides safe workplaces and takes measures to prevent workrelated injuries and illnesses. Working hours are kept reasonable, following local laws. According to the Myanmar Factories Act of 1951, workers are limited to 44 to 48 hours per week, depending on the job, with no more than one hour of overtime per day and a maximum 12-hour workday, including breaks.

Chapter 5

Notable human rights policies and policy gaps of companies

Based on our comparison of companies’ relevant human rights policies and Corporate Human Rights Benchmark (CHRB) summarized in the previous chapter, we found that none of the top 5 companies in the following supply chains disclose any human rights-related policies:

● Cashew supply chain in Cambodia

● Mining supply chain in Myanmar

● Rubber supply chain in Cambodia

Several top 5 companies in rice supply chain in Cambodia, sugar supply chain in India, and medicinal plant supply chain in Myanmar disclose their commitment to human rights. However, these companies disclose only high-level and blanket commitment to respecting human rights, with some failing to reference relevant UN conventions or standards such as the UNGPs. We did not find any disclosures beyond high-level commitments from these companies in both supply chains.

Among other supply chains, we could highlight some notable policies and the lack thereof as follows:

Note: all headers in italics denote the relevant CHRB indicator.

Seafood supply chain in Thailand

A2.1

Commitment from the top

Although Charoen Pokphand Foods (CPF), Kiang Huat Sea Gull Trading, and Thai Union Group all specify that they have established a specific committee to formulate sustainability strategy and/or risk management, including human rights issues, none specify human rights-related competencies and skills as qualification criteria for board or committee members.

A2.2 Board responsibility

Although CPF, Kiang Huat Sea Gull Trading, and Thai Union Group all specify that they have established a specific committee to formulate sustainability strategy and/or risk

management, only Thai Union specifies that the process of materiality assessment is informed by 12 stakeholders, including daily/migrant workers and NGOs, which implies that the process is probably “informed by the experiences of affected stakeholders or external human rights experts” as stipulated in this CHRB criteria.

A2.4 Business model strategy and risks

Among top 5 seafood companies in Thailand, Thai Union provides the clearest description of its materiality assessment process, stating that it “[interviews] 80 stakeholders, both internal and external, to identify and prioritize issues of utmost concern to them. This process evaluates the impact on stakeholders within and outside the organization, helping to predetermine material topics to be further integrated into the company’s enterprise risk. Human rights and employment practices emerge as the primary material concerns. The materiality assessment, which has been reviewed and approved by the Board-level Sustainable Development Committee, has contributed to the development of Thai Union’s SeaChange strategy, notably the “Safe & Legal Labor” pillar, aimed at providing safe, legal, and freely chosen employment in both our facilities and supply chain.”

B1.4b Communication/dissemination of policy commitment(s): Business relationships

Both CPF and Thai Union disclose that they demand their business partners, including suppliers, to adhere to the supplier code of conduct and/or guiding principles, which include human rights. In addition, Thai Union publishes the Vessel Code of Conduct (VCoC) and Vessel Improvement Program (VIP) to prevent its business partners from being involved in human rights violations.

B2.3 Integrating and acting on human rights risks and impact assessments

Although both CPF and Thai Union disclose that they integrate findings from human rights risks/impact assessments into their own operations and value chains, only Thai Union announces that the company actively seeks assistance from external organizations such as welfare agencies, specialized CSOs, or local entities with expertise, to ensure effective remedies when necessary.

C4 Procedures related to the grievance mechanism(s) are equitable, publicly available and explained

CPF outlines the process for handling grievances through the Labour Protection Network (LPN) center. Additionally, all reported cases will be made publicly accessible on a bulletin board, providing detailed information to keep affected stakeholders informed.

Thai Union outlines the complaint management procedure on its website. Additionally, it publishes guidelines for Remediation to Affected Individuals, which are accessible on the corporate website as well.

Maize supply chain in Myanmar

Among the top 5 maize companies in Myanmar, only CPP Myanmar (part of CP Group from Thailand) and Myanmar Awba Group disclose human rights-related policies that are at least partially aligned with CHRB criteria. Some notable policies include the following:

C2 Grievance mechanism(s) for external individuals and communities

It is worth noting although CPP Myanmar is part of the CP Group from Thailand, the company does not explicitly state that individuals and communities who may be adversely impacted by the company can raise complaints or concerns through its grievance mechanisms. Overall, the grievance mechanism of CPP Myanmar as disclosed by the company is much less clear and inclusive than CPF, another large CP Group company (human rights policies for which we covered in the “seafood supply chain in Thailand” section of this report).

C4 Procedures related to the grievance mechanism(s) are equitable, publicly available and explained

CPP Myanmar discloses the process for receiving complaints and notifying the complainant, starting from the process of collecting complaints, screening, and reporting the results to the complainant. However, the company does not clearly state its involvement through the provision of technical, financial, or advisory support to ensure equitable access to and participation in its grievance mechanism.

Myanmar Awba Group discloses its whistleblowing handling process in some detail but does not extend the process to handle human rights-related grievances.

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