Privacy and Human Rights

Published May 15, 2024               Implemented on 15 May 2024

1. Purpose

To establish and maintain a working environment that respects and safeguards the human rights of all stakeholders, with a particular focus on consultation with local residents, ensuring their rights are fully respected and protected.

2. Scope

This policy applies to all employees of the company, including full-time, part-time, and contract workers, as well as all external partners, suppliers, and clients involved with the company, especially local residents and other community members affected by the company's activities.

3. Responsibilities and Organization

Human Resources Department is responsible for developing and updating this management system, organizing related training, and overseeing its implementation.

Community Relations Department is specifically responsible for communication and consultation with local communities to ensure their rights are fully respected.

Department Managers are responsible for ensuring their departments comply with this policy and for addressing employee complaints and feedback in a timely manner.

Employees must understand and comply with this policy and actively report any human rights violations.

4. Rights Protection

4.1 Equal Opportunities

The company is committed to providing equal employment opportunities and prohibits discrimination based on gender, age, race, religion, sexual orientation, or other factors. All employees should be fairly evaluated based on their abilities and performance, ensuring the transparency and fairness of the evaluation process.

4.2 Respect and Dignity

The company is dedicated to creating a workplace that respects every individual, and will not tolerate any form of insult, humiliation, or abuse. Employees are encouraged to respect one another, and the company applies a zero-tolerance policy for any behavior that disrespects others.

4.3 Safe Working Environment

The company takes necessary measures to prevent occupational injuries and health issues, including providing essential safety training and equipment. A Health and Safety Committee, consisting of employee representatives and management, regularly reviews and improves the company’s health and safety policies.

5. Consultation with Local Residents

5.1 Establishing Communication Channels

A community liaison office will be set up in each area where the company operates, serving as a bridge for communication with local residents. Quarterly community meetings will be held at least once per quarter, inviting local residents, community leaders, and company representatives to discuss security activities and related matters.

5.2 Free, Prior, and Informed Consent (FPIC)

Through the community liaison office, local residents will be provided with complete and transparent information regarding the company's security arrangements, storage, and use of weapons and communication equipment. Feedback from local residents will be solicited through surveys, focus groups, etc., to ensure they are involved in the decision-making process.

5.3 Participation in Decision-Making

A Community Advisory Committee will be established, composed of local residents, community leaders, and company representatives, to review the company’s proposed security plans and ensure they align with the community's interests and needs. The company will regularly report on the progress of security activities and any potential or actual impacts to the committee to make necessary adjustments and optimizations.

5.4 Preventing and Mitigating Adverse Impacts

Before implementing any new security measures, a detailed risk assessment will be conducted to identify potential negative impacts on local residents' safety and other human rights. Based on the risk assessment results, appropriate mitigation measures will be developed and implemented to minimize the negative impacts of the company's activities on local residents.

5.5 Training and Advocacy

The company will provide local residents with education about its business and human rights protection efforts to enhance their understanding and support. Employees, particularly those who interact directly with local communities, will receive training to ensure they understand and respect the rights and needs of local residents.

6. Prevention of Excessive Use of Force by Security Personnel

6.1 Clear Use of Force Policy and Procedures

The company will establish clear policies governing the use of force, specifying the circumstances under which security personnel may use force and the level of force that is acceptable. Regular training will be conducted for all security personnel on the use of force, emphasizing the principles of minimum necessary force and the importance of adhering to laws and regulations.

6.2 Strengthening Supervision and Accountability Mechanisms

Video surveillance systems will be deployed at operational sites to monitor the behavior of security personnel in real-time, ensuring compliance with policies. Security personnel who violate the use of force policy will be disciplined according to the company's disciplinary procedures, with the results of disciplinary actions made public.

6.3 Establishing Effective Complaint Mechanisms

Accessible complaint channels, including hotlines, emails, and on-site complaint points, will be established for external stakeholders to report misconduct. The company commits to responding quickly to complaints and conducting thorough investigations.

6.4 Enhancing Communication with External Stakeholders

Through the community liaison office, the company will maintain regular communication with affected local and indigenous residents, gathering their opinions and suggestions. The company's use of force policy and complaint handling procedures will be publicly disclosed to external stakeholders to increase transparency.

7. Remediation

7.1 Immediate Corrective Action

Upon receiving a complaint about excessive use of force by security personnel, immediate action will be taken, including suspending the involved personnel from their duties to prevent further harm. Temporary protective measures, including medical assistance and safety shelter, will be provided to affected external stakeholders.

7.2 Thorough Investigation

An independent investigation committee will be established to conduct a thorough investigation of the complaint, ensuring fairness and transparency. On-site evidence, including surveillance footage, witness testimony, and other relevant materials, will be collected to establish the facts.

7.3 Corrective Action and Compensation

Based on the results of the investigation, appropriate disciplinary action will be taken against security personnel who violated policies, including warnings, fines, termination, etc. The company will publicly apologize to the victims and take necessary measures to prevent similar incidents from occurring again. Affected parties will be provided with appropriate compensation, including medical expenses and compensation for emotional distress.

8. Training and Advocacy

All employees will receive regular training on human rights awareness and anti-discrimination, ensuring that each employee understands the importance of respecting human rights.

Local residents will be provided with education about the company's business and human rights protection measures to enhance their understanding and support of the company’s activities.

9. Complaints and Investigation Procedures

Multiple complaint channels, including anonymous complaints, will be established to ensure that affected stakeholders can easily and safely report violations of their rights. The Community Relations Department will immediately investigate any complaints and take necessary corrective actions based on the results of the investigation.

10. Disciplinary Actions

Employees who violate this policy will be subject to disciplinary actions according to the company's disciplinary procedures, with the severity of the punishment determined based on the severity of the violation. For serious human rights violations, the company will publicly disclose the handling results to serve as a warning and educational measure.