Human Rights

Central Pattana Public Company Limited is committed to conducting business in alignment with international human rights principles. The Company’s Human Rights Policy has been in effect since 2020 and is reviewed at least every three years—the most recent update took place in 2024—to ensure alignment with evolving business contexts and stakeholder expectations.

Human rights practices cover all stakeholder groups, including employees, partners, subcontractors, customers, tenants, and communities. A dedicated Human Rights Working Team and Internal Audit Department oversee compliance, operating within the frameworks of the UN Guiding Principles on Business and Human Rights (UNGPs), the United Nations Global Compact (UNGC), and Thailand’s National Action Plan on Business and Human Rights.

Human Rights Due Diligence (HRDD) is conducted every two years, with a comprehensive assessment every four years, following methodologies from the UNGPs, Danish Institute for Human Rights (DIHR), and the HRIA Toolkit. In 2024, ten risk issues were identified, including three classified as Salient Issues. In response, the Company established preventive measures, remediation plans, and systematic monitoring mechanisms.

In addition, Central Pattana provides annual employee training on business ethics and human rights, and offers guidance to partners through handbooks and corporate communication channels to foster awareness and risk prevention across the supply chain.

Human rights grievances can be submitted via www.centralpattana.co.th/th/whistle-blowing, which ensures confidentiality and protection from retaliation. The Company monitors and reports grievance outcomes to the Audit and Corporate Governance Committee quarterly. In 2023, two human rights-related complaints were received and resolved within the designated timeframe.

Overall, the Company’s human rights strategy focuses on risk prevention, remediation for affected individuals, and the promotion of a corporate culture that respects everyone’s rights—raising standards to international levels and delivering long-term value to all stakeholders.

Respecting human rights in business promotes workplace equality and nurtures a work environment and culture of diversity, inclusion, respect and non-discrimination. This commitment enhances the well-being of employees, tenants and suppliers, and reduces human rights risks across the supply chain that, if unaddressed, could lead to resistance from employees, suppliers and customers, potentially causing business disruptions, reputational harm and a loss of stakeholder trust.

1. Operate in accordance with the Respect of Law and Principles of Human Rights Policy and embed respect for human rights into company policies including Treatment of Employees Policy, Supply Chain Management Policy, Treatment of Customers Policy, Occupational Health and Safety Policy, Public Relations and Marketing Policy as well as in our Code of Conduct and Corporate Governance Policy and Code of Conduct for Suppliers.

Our policies comply with applicable laws and regulations in all countries where we operate and align with international frameworks including the UN Guiding Principles on Business and Human Rights, United Nations Global Compact (UNGC), Universal Declaration of Human Rights (UDHR) and International Labor Standards (ILO) standards.

2. Create a safe and healthy work environment where everyone is treated fairly, equally and appropriately. Uphold the human rights of employees and stakeholders including customers, employees, tenants, tenant employees, suppliers, supplier employees, business partners and vulnerable groups, while remaining vigilant in ensuring that our business is not complicit in human rights violations and strictly adhering to all applicable laws, rules and regulations.

3. Carry out human rights due diligence (HRDD) every four years and human rights risk assessment (HRIA) every two years. Human rights risks are categorized and analyzed along the value chain including acquisition, design, construction, operations, and vulnerable groups. Each assessment cycle is guided by the Company’s policies and Code of Conduct, with adjustments made based on organizational context and feedback from previous assessments.

4. Impact classification and approach to mitigation and remediation

5. Review and assess human rights risks in operations across all business units and throughout the supply chain including during merger, acquisition, acquisition of shares, joint venture and other investment processes. This is fully integrated into the ESG assessment and embedded within the due diligence framework for mergers and acquisitions.

6. Adapt and apply globally accepted tools and frameworks in alignment with the UN’s Protect, Respect and Remedy framework, with reviews conducted annually to ensure ongoing compliance.

1. We adopted the Human Rights Due Diligence (HRDD) for Listed Companies framework, developed by the Securities and Exchange Commission (SEC) in collaboration with the Faculty of Law, Chulalongkorn University, for the 2024-2025 assessment cycle. The assessment was conducted in two stages: small groups of experts identified significant human rights risks, which were then incorporated into an online questionnaire. The target population of the survey was defined as: all employees (including subsidiaries, joint ventures and affiliated companies), as well as outsourced workers (sampled). The assessment criteria and analytical framework were developed based on the UNDP - United Nations Guiding Principles on Business and Human Rights, the DIHR- Danish Institute for Human Rights, the Community Insights Group and HRIA Toolkit. A total of 23% of employees participated in the survey, achieving 230% of the target set.

2. The ten human rights risk issues identified from the online survey were analyzed together with the findings from the HRDD assessment, which highlighted eight issues (grouped by category). These were finalized as salient issues, outlined as follows:

1. Human rights: Management of occupational safety, health and environment
2. Labor rights and human rights: Respect, protection and promotion of equity, equality and non-discrimination, along with preventing the abuse of power.
3. Labor rights: Freedom of association, collective bargaining and negotiation including the right to advocate for welfare and to report unfair labor practices

Human Rights Issues	Implementation and Preventive and Corrective Action Plans
Occupational safety, health and environment	Conducted Environmental & Safety Compliance Assessments (ESCA) across 17 shopping center and community malls in operation. Implement appropriate mitigation measures to address, resolve and remediate the issues identified. Require all contractors to provide workplace safety training for all workers, and submit safety reports along with Safety Improvement Requests (SIR) within the expected timeframe to ensure timely updates on the implementation of corrective actions when issues are identified.
Human rights and labor rights	In collaboration with Baan Dek Foundation, we encouraged the contractor for a new project, Powerline Engineering Public Co., Ltd., to participate in the Building Social Impact Initiative and conducted a quality-of-life survey within the construction site accommodations. The survey covered aspects including living conditions, safety improvements, waste management systems, access to clean water, sanitation and hygiene. In addition to social activities and safe spaces for children, support was also provided in areas such as overall well-being, health, access to vaccines, basic health measures, and children’s access to education both in and out of school. Established a task force to work with external consultants in reviewing human rights and labor policies and practices. This ongoing review, planned for the 2024-2025 period, covers company employees, joint ventures, subsidiaries, contractors and outsourced workers. The Corporate Governance Communication and Sustainable Development Working Group introduced a process for approving special leave requests for occasions such as same-sex marriage, paternity leave and caregiving leave, which employees can apply for through the standard leave procedure, with each request evaluated on a case-case-basis. Regular spot checks of labor documentation are conducted at construction sites by consulting teams hired by Central Pattana and provincial employment offices to ensure compliance with labor registration and undocumented worker inspection measures. All migrant workers are required to be legally registered and reported to the project manager at their respective sites. In 2024, migrant workers employed by 4 contractors (double counted) were legally registered at the construction sites. Of these, 22% were Cambodian, 39% were Myanmar nationals and 39% were Thai. Introduced the People Help Desk, a 24/7 online communication channel for employees to inquire about welfare and other concerns. Expanded employee access to healthcare online via Tops Care Telehealth, allowing those with mild illnesses to consult doctors remotely and pick up medication at a convenient Tops Care branch.

In 2023, the Company conducted a human rights risk assessment for the 2023–2024 cycle, covering employees across all business units, subsidiaries, joint ventures, and subcontractors. The assessment was conducted through an online random sampling survey, with a response rate of 70% from the target sample group. The assessment identified nine human rights risk issues, three of which were classified as high-risk (Salient Issues). The Company developed risk mitigation plans as well as measures for prevention, monitoring, investigation, correction, and remediation in cases of rights violations. These processes were overseen by the Corporate Governance and Sustainability Communications Taskforce, the Occupational Health and Safety Working Group, and relevant responsible departments, ensuring compliance with the Company’s established procedures for investigation, prevention, resolution, communication, and follow-up. 

The Company continues to rigorously enforce and randomly inspect legal employment documentation at construction sites through its consultants and provincial labor offices, in accordance with the official labor registration and inspection procedures. All foreign workers must be legally registered and reported to each project’s management team. In 2023, foreign workers were registered at sites operated by 28 contractors (duplicate counts included), consisting of 17% Cambodian, 37% Myanmar, and 1% Lao nationals, while Thai workers accounted for 45% of the total workforce across all sites.

3. We structured our action plan into two parts: (1) mitigation actions to address salient human rights issues — specifically safety concerns in high-risk projects, which account for 28% of all shopping center and community mall projects; and (2) remediation actions for labor rights and human rights risks across the organization including high-risk supply chains, as identified through our assessments.

4. Oversight is provided by the Corporate Governance Communication and Sustainable Development Working Group, the Occupational Safety, Health and Environment Working Group, and other units responsible for audit and inspection. These teams ensure compliance with the Company’s procedures and protocols for investigation, prevention, resolution, communication and monitoring.