Human Rights in Supply Chain

Management Approach

The company recognizes the importance of respecting the human rights of stakeholders in all activities throughout the supply chain. Therefore, it conducts business in accordance with international practices related to respecting the human rights of stakeholders, including rights concerning natural resources and the environment. This ensures that the company's operations are conducted with careful consideration and prudence, treating all stakeholder groups equally and without discrimination based on gender, race, religion, or different opinions, while avoiding any actions that may lead to direct or indirect human rights violations.

The company has established a Labor and Human Rights Working Group consisting of 9 members from relevant departments, chaired by the Executive Vice President of Organizational Development. This working group is responsible for overseeing and monitoring operations related to labor, such as compliance with labor laws and human rights principles, employment practices, working conditions, health and safety, as well as human resources development. Additionally, the working group plays a role in conducting comprehensive human rights due diligence (HRDD), providing advice and recommendations to establish measures for mitigating or preventing risks per set objectives. It also disseminates and communicates information on human rights both internally and externally to foster a correct understanding throughout the organization. The working group holds regular monthly meetings to monitor ongoing operations and reports to the Corporate Sustainability Development Committee and the Corporate Governance and Sustainability Committee at least once per quarter

The company has developed a framework for human rights operations that aligns with the United Nations Guiding Principles on Business and Human Rights (UNGP) to serve as a guideline for the Board of Directors, executives, and employees at all levels as follows:

Human Rights Policy

The company has established a Human Rights Policy and a Human Rights Practices Handbook that align with the United Nations Guiding Principles on Business and Human Rights (UNGP), the OECD Due Diligence Guidance for Responsible Business Conduct, the Universal Declaration of Human Rights (UDHR), as well as relevant laws in Thailand and abroad concerning business operations. These documents serve as guidance for the Board of Directors, executives, and employees at all levels to treat all stakeholder groups in all activities throughout the supply chain in accordance with human rights principles and to respect human dignity, rights, and freedoms equally.

Learn more about Human Rights Policy and a Human Rights Practices Handbook at www.nerubber.com or scan QR Code

Labor Rights Practices Guidelines
1.Treatment of Employees and Workers	Treat employees and workers equally without discrimination. Support diversity among employees. Promote equal opportunities for women and persons with disabilities. Prohibit and do not tolerate physical punishment, physical and psychological harassment, or verbal abuse.
2. Employment Practices	Promote diversity and equal opportunities in employment. Hire under terms and conditions that comply with local laws and established practices.
3. Labor Utilization	No use or support for child labor (individuals under the age of 18). No use or support for forced labor or human trafficking in any form. No forcing of employees to work overtime without their consent.
4. Wages and Benefits	Provide fair and equal wages and benefits for all employees. Compensate appropriately according to the salary structure and market conditions, meeting at least the minimum wage requirements set by the country. Respect the rights to rest and ensure reasonable working hours.
5. Workplace Safety	Provide a safe and hygienic working environment and facilities that are accessible to everyone, including persons with disabilities.
6. Freedom of Association and Collective Bargaining	Respect the rights and freedoms of employees to join associations and engage in collective bargaining. Support the establishment of welfare committees to develop benefits that are beneficial and suitable for employees' needs.

Human Rights Risk Assessment

The company mandates a comprehensive Human Rights Due Diligence (HRDD) at least once a year to identify and evaluate risks, as well as to establish corrective and preventive measures against human rights violations across all business activities, including the operations of stakeholders throughout the supply chain. The operational processes align with the United Nations Guiding Principles on Business and Human Rights (UNGP) and the principles of Free, Prior, and Informed Consent (FPIC) for Indigenous Peoples. The comprehensive Human Rights Due Diligence process includes the following steps:

2024 Performance

In 2024, the company conducted a comprehensive human rights risk assessment covering 100% of its operational areas. The assessment scope extended to the supply chain and related business activities through business relationships, such as activities of raw material suppliers. The company identified human rights risk issues by integrating them into the risk assessment process undertaken by various departments in line with their responsibilities. This included analyzing environmental impacts and addressing environmental issues according to the standards of the Environmental Management System (ISO 14001:2015) and assessing safety risks in accordance with the Occupational Health and Safety Management System (ISO 45001:2018) Covering 100% of the company's operating area in Buriram Province.

Related Human Rights Risk Issues

The company has identified human rights issues related to its operations throughout the supply chain, as follows:

Labor Rights	Community Rights	Supplier Rights	Customer Rights	In Supply Chain
Discrimination in the workplace and violations of personal rights Unfair employment Freedom of expression and association Health and safety of employees Employee data privacy and security	Health and safety of communities Community environmental management	Supplier discrimination Supplier data privacy and security	Customer data privacy and security	The use of forced labor or child labor by suppliers Health and safety of suppliers’ workers

Assessment of Salient Human Rights Risks

Human Rights Risk Management

The company identified one high-level human rights risk issue, which is the health and safety of its employees, as well as four medium-level risk issues. Consequently, the company has established management measures to mitigate impacts and prevent future occurrences, along with appropriate remediation for the affected individuals. This process involves collaboration with stakeholders who have been or may be directly affected, such as employees, suppliers, customers, and local communities, to determine effective, appropriate, and sufficient measures. The company has implemented the following various measures:

Scope	Salient Human Rights Risk	Affected Stakeholder Group	NER’s Corrective, Preventive & Remedial Action
Activities in the company’s operations	Labor Rights:
	Discrimination in the workplace and violations of personal rights	Employee	Establish a human rights policy and practices that ensure equal treatment and non-discrimination for employees. Train employees to be aware of and respect rights related to equality and non-discrimination. Provide whistleblowing channels, including an effective complaint management process and appropriate remedies.
	Unfair employment	Employee	Set a clear employment policy and practices that offer equal opportunities. Establish a remuneration and benefits structure that is appropriate and complies with legal minimums.
	Freedom of expression and association	Employee	Support the formation of a welfare committee with members elected by employees, who meet with management to improve benefits and propose suggestions that are beneficial to employees.
	Health and safety of employees	Employee	Conduct risk assessments and Job Safety Analysis (JSA) to identify causes and proactively prevent accidents. Provide appropriate and sufficient personal protective equipment. Improve the workplace environment and occupational health within the organization, such as installing adequate clean drinking water stations for the workforce. Conduct safety training throughout the organization. Organize activities to campaign for reducing workplace accidents to zero. Foster a safety culture within the company and promote a Safety DNA to instill employee awareness and engagement in assessing and managing work risks, such as daily safety morning talk and Kiken Yoshi Training (KYT) before starting work to prepare for safe operations.
	Employee data privacy and security	Employee	Establish a policy and practices regarding the protection of employees' personal data. Develop a secure information technology system and conduct regular testing. Raise awareness about cybersecurity, the confidentiality and security of information. Monitor and track incidents of personal data breaches.
	Community Rights
	Health and safety of communities	Community	Establish a policy and practices regarding social responsibility and environmental stewardship that may impact the community. Monitor and assess the effects on surrounding communities, and develop measures to remediate, prevent, and mitigate environmental impacts in collaboration with the community. Promote health care and provide annual health check-ups for the community. Install a complaint box at the front of the factory or allow submissions through the security team at the factory entrance.
	Supplier Rights
	Supplier discrimination	Supplier	Establish a policy and a procurement manual as guidelines for engaging with suppliers for company employees. Treat suppliers with equity, fairness, transparency, and non-discrimination. Train employees and monitor compliance with the procurement policy and manual. Provide complaint channels and an effective complaint management process, along with appropriate remedies.
	Supplier data privacy and security	Supplier	Establish a policy and practices regarding the protection of suppliers' personal data. Develop a secure information technology system and conduct regular testing. Separate the management system for the protection of suppliers' personal data from employee data to prevent breaches of business confidentiality. Define levels of confidentiality and access rights to the data.
	Customer Rights
	Customer data privacy and security	Customer	Establish a policy and practices regarding the protection of customers' personal data. Develop a secure information technology system and conduct regular testing. Define levels of confidentiality and access rights to the data.
Activities in the supply chain	Labor Rights in the Supply Chain
Activities in the supply chain	The use of forced labor or child labor by suppliers	Workers of raw material suppliers, suppliers, and contractors	Require suppliers to strictly comply with labor laws and regulations. Communicate policies and the supplier code of conduct related to human rights, as well as procurement practices that include labor practices, ensuring that suppliers are informed and adhere to these regulations rigorously. Verify the labor licenses of suppliers and contractors before conducting transactions with the company. Conduct regular assessments of labor practices, including self-assessments and on-site audits at the premises or rubber plantations of raw material suppliers, suppliers, and contractors.
	Health and safety of suppliers’ workers	Workers of raw material suppliers, suppliers, and contractors	Communicate the safety-related policies and ethical standards to suppliers, ensuring their awareness and strict adherence to regulations. Provide safety training to contractors before the start of each project. Verify the readiness of equipment and the health of contractors providing labor before each type of work. Conduct regular safety assessments, including self-assessments and on-site audits at the establishments or rubber plantations of raw material suppliers, suppliers, and contractors.
	Community Rights
	Health and safety of communities	Community	Require suppliers to strictly comply with safety laws and regulations. Monitor the operations of suppliers and contractors regarding labor and environmental practices to prevent human rights violations. Mandate that suppliers and contractors implement measures to prevent and be accountable for potential impacts arising from human rights violations. Oversee that suppliers and contractors have appropriate remedies in place in cases where their actions lead to human rights violations against the community.
	Community environmental management	Community	Require suppliers to strictly comply with environmental laws and regulations. Monitor the operations of suppliers and contractors regarding environmental management to prevent adverse impacts on the community.

Communication and Training on Human Rights

Human Rights Training for Employees

The orientation training program in 2024 included a total of 289 new employees, all of whom (100%) completed the training. In addition, a human rights awareness session was provided to employees from every department, with a total of 308 participants, accounting for 32.73% of the total 941 employees.

Human Rights Training for Suppliers

A total of 61 suppliers participated in the training, representing 22.85% of the company’s total 267 critical suppliers.

Internal Communication on Human Rights

Information on human rights is communicated through various channels, such as newsletters, intranet, and posters. Activities are also organized to encourage participation, such as training workshops, panel discussions, and human rights seminars.

Establishment of a Welfare Committee

A Welfare Committee has been established within the company, consisting of employee representatives who can raise opinions and concerns or act as spokespeople on behalf of employees in developing welfare policies. This ensures transparency and appropriateness of employee welfare measures.

Occupational Health and Safety Training and Development for Employees

Employees are trained on human rights and occupational safety, including health risk awareness, workplace practices, and compliance with safety regulations. Training also covers the proper use of equipment and tools suitable for each job type. Additionally, occupational health and safety services are provided.

Collaboration on Labor and Human Rights with External Organizations

The company also collaborates with external organizations, such as participating in the “Road Safety Upgraded” project organized by the Office of Disaster Prevention and Mitigation (DDPM), Buriram Province.

Promotion of Diversity, Equity, and Inclusion (DEI)

The company places great importance on promoting diversity and treats all employees with respect and equity in every aspect of its operations. It is committed to creating a fair and discrimination-free working environment, focusing on employment, skill development, and providing opportunities for career advancement. The company has implemented the following concrete practices:

Policy	Approach
1. Fair Employment and Management	The company conducts employment, compensation, training, promotions, and termination of employment in an equitable manner, free from discrimination based on race, religion, nationality, gender, disability, or any other personal status. Selection and compensation considerations are based primarily on abilities and suitability for the positions, adhering to principles of equality. This includes equal pay for equal work, regardless of gender or age.
2. Respect for Personal Rights and Freedoms	The company respects the personal rights of employees to practice their beliefs, faith, or personal needs, such as race, religion, or gender differences, as long as such activities do not affect their job responsibilities, colleagues, or the organization.
3. Prevention of Harassment and Exploitation	Any form of expression or behavior that constitutes oppression, intimidation, sexual harassment, or exploitation of employees is prohibited. Additionally, actions that violate organizational ethics are not permitted, with disciplinary sanctions for violations specified in the company's work regulations.
4. Support for Women's Labor Rights	There is no requirement for women to undergo pregnancy tests or contraceptive measures, and the company provides care for pregnant women in accordance with legal requirements, creating a work environment that supports equal labor rights.
5. Capacity Development and Career Advancement Promotion	The company establishes career paths and supports the development of all employees' capacities equally by providing individual development plans and opportunities for diverse training and skill development. This includes learning, training, and preparation for changes or new responsibilities in the future, along with transparent performance evaluations, such as assessing performance, competencies, and appropriate behaviors.

Monitoring and Evaluation

The company requires a review of human rights risk issues to be conducted regularly, at least once a year, as the human rights risks associated with the company’s business operations may change due to different activities and stakeholder groups. Additionally, the company monitors and evaluates the effectiveness of corrective and preventive measures by establishing indicators to serve as tools for tracking and assessing the effectiveness of the risk management measures employed. The details are as follows:

Human Rights Issues	Indicator	2024 Target	2024 Performance
Labor Rights	Percentage of employees trained on human rights.	100%	32.73%
	Number of complaints or lawsuits related to labor rights violations for which the organization is at fault.	0	0
	Lost Time Injury Frequency Rate (LTIFR).	0	2.93
	Rate of fatalities or disabilities due to work-related accidents (Major Accidents).	0	0
	Turnover rate of employees caused by human rights violations.	0	0
Community Rights	Number of significant complaints from the community related to human rights violations.	0	0
Supply Chain	Percentage of suppliers signing to acknowledge the company’s Supplier Code of Conduct.	100%	100%
Supply Chain	Percentage of critical tier-1 suppliers who have received training on human rights.	100%	12.32%

Complaints and Whistleblowing

The company has monitored human rights risks by providing accessible complaint channels for all stakeholder groups. These include feedback boxes in various areas of the company, an online complaint system via Red QR Code, email, intranet, Line Chat Group, complaints through representatives of the welfare committee, or human resources management staff. External stakeholders can submit complaints via written letters, the company’s website, social media channels, a complaint box installed at the front of the factory or directly submit documents to the security team at the factory entrance, or through community representatives.

The company has established a systematic and fair process for reviewing complaints and mechanisms for remedying affected individuals in the event of human rights violations, as outlined in the human rights practice manual, as follows: