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Human Rights

Human Rights and Environmental Due Diligence

Management Policy

  • In response to the Corporate Sustainability Due Diligence Directive (CSDDD) passed by the EU on April 24, 2024, TCC Group Holdings proactively reviews and responds to the impacts on the value chain, incorporating the voices of stakeholders such as customers and community residents into decision-making considerations, and actively communicates and responds appropriately

  • TCC Group Holdings due diligence approach primarily references the United Nations Guiding Principles on Business and Human Rights, the Human Rights Due Diligence Training Facilitation Guide, the EU Corporate Sustainability Due Diligence Directive and its Annex, the OECD Due Diligence Guidance for Responsible Business Conduct, and the OECD Guidelines for Multinational Enterprises

  • TCC reviews overall human rights risks at least every three years. This year marks the first execution of human rights and environmental due diligence, with subsequent regular follow-ups

  • TCC 2024 Human Rights and Environmental Due Diligence Report

Human Rights and Environmental Due Diligence Process

  • Collect various human rights and environmental issues that may affect different rightsholders

  • This due diligence references guidelines and conventions from the United Nations, EU, OECD, and the International Labor Organization to compile relevant issues

  • Consult rightsholders to assess the risks to human rights and environmental matters. To effectively assess risk, prioritize the most significant risks based on their severity and likelihood

  • The rightsholders consulted in this due diligence include their employees, surrounding community residents, indigenous peoples, customers, etc

  • Cease adverse impacts and prevent potential adverse impacts. If adverse impacts persist, despite prevention measures, further mitigation is required

  • Periodically evaluate the effectiveness of measures to prevent or mitigate adverse impacts

  • Communicate with rightsholders and disclose all relevant information

  • Provide remedial measures for any adverse impacts that have occurred

  • Establish a company grievance mechanism

Investigation Target and Questionnaire Collection Status

RightsholdersScopeQuestionnaire Collection Status

Employees

Year 2023: 100% operational sites (including Taiwan, Mainland China, subsidiaries, affiliated enterprises) and joint ventures
Year 2024: Introducing CSDDD, TCC Headquarters, Suao Cement Plant, Hoping Cement Plant, Taiwan RMC Plants & business relationships (e.g. new business relations like joint ventures/acquisitions)

Since this is the first execution of human rights and environmental due diligence, and employees are vital rightsholders, the census method was used for the questionnaire distribution. The effective response rate was 94%

Supplier (Contractors included)

Year 2023: Through sustainability self-evaluation questionnaire, as well as written or on-site reviews, the implementation of supplier human rights protections is examined. It is announced at the Supplier Convention that a human rights due diligence investigation will be initiated in the following year
Year 2024: Expanded to contractors in Taiwan

The effective response rate was 96%

Community

Communities near cement plants and RMC plants in Taiwan

The effective response rate was 84%

Indigenous Peoples

Tribes near cement plants in Taiwan

The effective response rate was 86%

Customers

Customers in Taiwan

The effective response rate was 81%

Stakeholders Assessment

Employees

Female Employees

Community

Indigenous Peoples

Customers

Suppliers

According to the OECD Due Diligence Guidance for Responsible Business Conduct, gender factors must be incorporated into due diligence, as women may face different potential or actual human rights impacts compared to men. Therefore, the risk ranking of key issues for employees will be analyzed separately for all employees and female employees 
After analyzing the human rights and environmental risks for all employees, the key issues identified include whistleblower protection, training and education, bullying and harassment, collective bargaining, working hours, occupational safety and health, equal remuneration, wage and benefits, and forced labor/human trafficking

The analysis of human rights and environmental risks for female employees showed that key issues are generally similar to those for all employees. The difference is that female employees considered bullying and harassment as significant issues due to their severity when they occur. Additionally, privacy rights and discrimination are also important human rights issues for female employees

The analysis of human rights and environmental issues for the community residents highlighted that they prioritize environmental issues, including environmental degradation, waste management, land use, water resources, biodiversity, and climate change

The analysis of human rights and environmental issues for indigenous peoples identified key issues including indigenous rights, biodiversity, environmental degradation, waste management, land use, water resources, and climate change

The analysis of human rights and environmental issues for customers shows that key issues include fair trade/information disclosure and climate change

The analysis of human rights and environmental issues for suppliers identifies key risk issues, including occupational health and safety, bullying and harassment, climate change, working hours, environmental degradation/ waste/land use

Prevention/Mitigation of Key Human Rights and Environmental Issues and Remedial Measures for Existing Impacts

  • After assessing the risks of human rights and environmental issues through the aforementioned steps, preventive and mitigating measures are proposed for key human rights and environmental issues based on subsequent steps of the human rights and environmental due diligence process. Additionally, remedial measures are provided for existing impacts

  • Please refer to the table below for prevention, mitigation, and remediation measures for key issues. For detailed information, please refer to the 2023 TCC Sustainability Report.

  • The following key points will be the focus of the TCC GROUP HOLDINGS 2024 Human Rights and Environmental Due Diligence Report scheduled for release in the third quarter of 2024:

    1. Track the effectiveness of TCC's prevention, mitigation, and remediation measures for significant human rights and environmental issues

    2. Identify systemic human rights and environmental risks based on future scenario models from major domestic and international research reports. This includes assessing the impact of heat waves on TCC employee safety and evaluating the risk of labor shortages on TCC's human rights based on the population projection report by the National Development Council

    3. Implement management measures for human rights issues in the international supply chain

Summary of Prevention/Mitigation/Remediation Measures

Employees

Female Employees

Community

Indigenous Peoples

Customers

Suppliers (Migrant workers)

IssuePrevention/Mitigation/Remediation Measures
Whistleblower ProtectionPrevention

TCC provides employees with various channels to express their opinions. A dedicated committee, following the "TCC Group Employee Opinion Complaint and Handling Guidelines" and the "Anti-Discrimination and Anti-Harassment Policy," takes appropriate protective measures to safeguard the personal information and privacy of whistleblowers or complainants

Worker Training and EducationPrevention

TCC develops worker training and education projects such as Employee Development Programs and TCC Carbon Academy
For more details, please refer to pages 133-139 of the 2023 TCC Sustainability Report

Occupational Health and SafetyRemediation

In 2023, TCC reported 13 minor work-related injuries in Taiwan and Mainland China. 

  • Investigations led to enhanced inspections at high-risk sites, more frequent plant inspections, and additional education and training to prevent future incidents and aim for "zero work-related injuries

Prevention

Hazard Identification& Risk Assessment

  • Step 1: Identify all hazardous sources

  • Step 2: Identify hazards and consequences

  • Step 3: Confirm existing protective measures

  • Step 4: Access hazard risks and conduct risk classification and management

  • Step 5: Implement control measures to reduce risks

  • Step 6: Confirm the remaining risk after applying control measures

For more details, please refer to pages 145-146 of the 2023 TCC Sustainability Report

Collective BargainingPrevention

  • TCC holds labor-management meetings/union meetings with representatives and unions every quarter to exchange opinions on various issues and conduct thorough communication

  • Each plant has established union organizations, maintaining good interactive communication with the stance of integrity, openness, and respect. Collective agreements are signed based on principles of mutual trust and benefit, ensuring adherence

  • To protect the rights and interests of employees, the content of collective agreements or work rules applies to all employees. Employees are not treated differently based on any conditions or willingness to join the union. The Company ensures the freedom of employees to participate in assembly and association with a fair, just, and respectful approach

Working HoursRemediation

Labor working hours violations in Taiwan: 1 case

  • Strengthen training for employees to acquire the professional skills they need, emphasize the importance of physical and mental health, and enhance the immediacy of supervisors' concern and assistance in management and supervision. Additionally, pay attention to ensuring reasonable working hours for employees

Prevention

  • Implement overtime control and tracking mechanisms, and establish an overtime warning system. The TCC operations headquarters turns off the lights at 9:30 PM daily to reduce the possibility of excessive work hours

  • Prevent working hours risks at the source through manpower and resource allocation mechanisms, enhanced employee professional skills training, and management and supervision mechanisms

Wage and BenefitsPrevention

TCC develops wage and benefits projects such as Treasury Shares Program, Employee Savings Mutual Fund and Employee Stock Option Program
For more details, please refer to pages 140-141 of the 2023 TCC Sustainability Report

Forced Labor Human TraffickingPrevention

Annual human rights protection training

IssuePrevention/Mitigation/Remediation Measures
Bullying and HarassmentPrevention

  • Implement Anti-Discrimination and Anti-Harassment Policy

  • "Anti-Discrimination and Anti-Harassment Policy" are included in TCC's annual mandatory training

  • Include sexual harassment prevention in new recruit orientation

  • Specific grievance channels for discrimination and harassment prevention ensure employees' well-being and a harmonious work environment

Discrimination
Privacy
Equal remunerationPrevention

TCC Group Holdings adheres to the principle of sharing operational performance and has formulated a compensation policy where employee salaries are determined based on their performance, job responsibilities, and other comprehensive factors. Discrimination based on personal characteristics such as gender (including sexual orientation), race, class, age, marital status, language, ideology, religion, political affiliation, birthplace, appearance, facial features, or disabilities is strictly prohibited

IssuePrevention/Mitigation/Remediation Measures
Water resourcePrevention

  • TCC cement plants and RMC plants in Taiwan and Mainland China have 100% ISO 14046 certification, with Taiwan's plants also certified to ISO 46001. In May 2024, Hoping Plant (Hualien) and Suao Plant (Yilan) received the highest Platinum level from the Alliance for Water Stewardship (AWS) after thorough evaluation

  • TCC is enhancing water efficiency by constructing recycling systems, optimizing pipelines and equipment, and installing water-saving devices. The future water supply was assessed based on the WRI’s Aqueduct Water Risk Atlas

  • For more details about water resources, please refer to pages 74-75 of the 2023 TCC Sustainability Report

WasteRemediation

Waste Disposal Act violations in Taiwan: 1 case 

  • The penalty was issued due to incorrect waste reporting data. To prevent similar incidents in the future, the waste reporting process has been improved

Prevention

  • TCC DAKA Renewable Resource Recycling Center (RRRC) to process Hualien's domestic waste. As Taiwan's first to use cement kilns for local waste co-processing, the RRRC possess a daily capacity of 200 metric tons

  • For more details about resource recycling, please refer to pages 74-75 of the 2023 Taiwan Cement Sustainability Report

Environmental DegradationPrevention

  • TCC Nature Action is based on the frameworks and methodologies of TNFD, SBTN, and WBCSD, and conducts assessments in accordance with the SBTN Company Guidance for Nature Positive

  • TCC is engaged in indigenous species ecosystem restoration projects and soil research programs in its mines

  • For more details, please refer to pages 112-130 of the 2023 TCC Sustainability Report and the Nature & Biodiversity Report-TNFD Pilot Program

Biodiversity
Land Use
Climate ChangePrevention

  • TCC unveiled the new " Net Zero Pathways for Cement and Concrete Business Units Worldwide"

  • TCC aims to revise its 2030 SBT to meet the 1.5°C target by 2024

  • Concurrently, TCC will commit to 2050 net-zero goals and join the SBTi validation pilot, ensuring consistent carbon reduction monitoring

  • For more details, please refer to pages 63-88 of the 2023 TCC Sustainability Report and the TCFD Report

IssuePrevention/Mitigation/Remediation Measures
Indigenous PeoplesPrevention

  • TCC established the Hoping Sustainability Charity Foundation to offer sustainable support to the tribe. The foundation operates on a tribal consensus model

  • led by the village leader and three tribal chairs. Additionally, the Hoping Emergency Relief Fund was created to ease financial hardships of the needs

  • TCC DAKA Open Eco-Factory (TCC DAKA) enhances industry-society dialogue. Since its 2020 launch as a non-profit, regular contribution from the month surpluses of 7-ELEVEN Lienhe Store and Starbucks are directed to the Hoping Sustainability Charity Foundation. Additionally, income from DAKA Eco-Tour Itinerary and DAKA Market stall fees finance the Hoping Environmental Education Project

  • TCC DAKA launched the Home Repair Service Center, employing two locals and suppliers' staff as electricians and engineers, with the Hoping Plant supplying basic parts for free

  • Since 2022, the Hoping Village Care Bus, equipped with an automatic lift, has facilitated access for individuals with disabilities. The bus transports Heping villagers to and from downtown Hualien for business, medical needs, and grocery shopping

  • For more details, please refer to pages 150-154 of the 2023 TCC Sustainability Report

IssuePrevention/Mitigation/Remediation Measures
Fair Trade / Information DisclosureRemediation

Anti-competition or anti-trust: 1 case(Legal remedies filed)

  • The "Code of Fair Trade and Anti-trust Compliance" has been formulated

  • In employee education and training, this case serves as a teaching material to remind employees of being vigilant in discussing sensitive information with competitors and refusing to attend occasions involving any of the above. How to report and keep evidence while clients demanding the same price is emphasized to protect the Company’s interests

  • For more details, please refer to pages 54-55 of the 2023 TCC Sustainability Report

IssuePrevention/Mitigation/Remediation Measures
Occupational Health and SafetyPrevention

  • Suppliers are required to sign the Supplier Code of Conduct. With the aim to ensure the work safety, the protection of the environment, and the dignity of the employees (including the contractors) on the entire supply chain and the manufacturing process, as well as the compliance with the laws and regulations relating to occupational safety and health and the signing of the Letter of Undertaking of Health, Safety and Environment

  • For more details, please refer to pages 56-58 of the 2023 TCC Sustainability Report

Bullying and Harassment
Climate Change
Working Hours
Environmental Degradation / Waste / Land Use