Human Rights and Labor Practices Policy

1 Importance

Qualitech Public Company Limited (the “Company”) recognizes the importance of respecting human rights equally and fairly, upholding human dignity and individual freedom without discrimination on the grounds of race, nationality, skin color, gender, age, language, religion, culture, social class, disability, gender identity, personal status, social status, non-job-related illnesses, political opinions, marital status, and other factors, in accordance with fundamental principles of international human rights laws.

2 Scope of Policy

This Human Rights and Labor Practices Policy applies strictly to Qualitech Public Company Limited, its subsidiaries, joint ventures, and controlled entities. The Company expects and encourages its business partners, suppliers, distributors, and any related individuals to support and implement this policy.

3 Definitions

3.1 “Company” refers to Qualitech Public Company Limited and all subsidiaries under its control.

3.2 “Human Rights” refers to human dignity, fundamental rights, inherent freedoms, and equality without discrimination based on race, religion, gender, skin color, language, ethnicity, or other statuses. (Source: National Human Rights Commission of Thailand)

3.3 “Forced Labor” refers to involuntary work performed under coercion, threats, or punishments, resulting in individuals working unwillingly or under conditions they cannot refuse. (Source: Department of Labor Protection and Welfare)

3.4 “Child Labor” refers to employment that deprives children of their childhood, hampers their potential and dignity, and harms their physical and mental development. It also includes work that is hazardous to children’s physical, mental, social, and moral well-being, hindering education and forcing them to leave school permanently or balance work with education in inappropriate conditions. (Source: Department of Labor Protection and Welfare)

3.5 “Value Chain” refers to interconnected activities creating added value for the Company throughout its business operations, resulting in a final beneficial product or service for customers.

3.6 “Stakeholder” refers to individuals or groups directly or indirectly affected by the Company’s operations, positively or negatively, such as employees, customers, business partners, suppliers, and society, community, and the environment.

4 Objectives

4.1 Prevent human rights violations and labor malpractice across all Company operations.

4.2 Prevent unfair labor practices, discrimination, and harassment, while promoting collaboration and equal personal development opportunities.

4.3 Promote human rights and fair labor practices among suppliers and stakeholders throughout the value chain in line with international standards and Company practices.

5 Human Rights Policy

The Board of Directors, executives, and employees at all levels must recognize and respect human rights across all business activities, strictly adhering to this policy as follows:

5.1 Treat all individuals fairly, equally, and with dignity without discrimination based on origin, race, nationality, gender, age, skin color, religion, expression of opinions, physical condition, status, or other differences.

5.2 Conduct business activities without directly or indirectly violating human rights.

5.3 Support and advocate human rights, ensuring Company operations are free from human rights violations.

5.4 Communicate, educate, raise awareness, establish guidelines, and monitor relevant parties throughout the value chain to ensure ethical business conduct respecting human rights.

5.5 Conduct regular Human Rights Impact Assessments (HRIA) and labor practice evaluations to identify and manage potential and actual human rights risks and impacts within the value chain, and implement appropriate risk management measures.

5.6 Ensure fairness and protection for whistleblowers and individuals cooperating in reporting human rights violations, following established Company procedures.

5.7 Continuously develop and implement human rights management processes to identify, assess, plan, mitigate, and prevent human rights violations, including monitoring, evaluation, and appropriate remedy mechanisms.

5.8 This policy covers rights of key stakeholders, including employees, customers, suppliers, business partners, society, community, and the environment, outlining specific operational guidelines:

5.8.1 Employee Rights: Provide fair employment conditions without discrimination, promote workplace diversity, offer employment opportunities to disabled and elderly persons, ensure safety and occupational health, prevent all forms of harassment, and continuously improve working conditions based on employee feedback.

5.8.2 Customer and Visitor Rights: Prioritize customer and visitor safety and health, conduct responsible and fair business practices without discrimination, respect personal privacy, and ensure secure personal data management systems.

5.8.3 Supplier and Business Partner Rights: Promote lawful, fair employment aligned with international labor standards, ensure fair working hours, wages, non-discrimination, safety, and occupational health, and prevent illegal or coerced labor practices.

5.8.4 Society, Community, and Environmental Rights: Operate responsibly with respect for community and environmental rights, prioritize community safety, manage environmental impacts, and facilitate community feedback and stakeholder engagement to maintain harmonious relationships.

6 Human Rights and Labor Practices

6.1 Forced Labor: The Company does not engage in nor support any form of forced labor, either internally or within its supply chain. It prohibits physical punishment, harassment, or other forms of physical, sexual, psychological, or verbal abuse as disciplinary or control measures.

6.2 Child Labor: The Company does not employ or support the employment of individuals below the legally mandated working age, neither within the Company nor in its supply chain. Additionally, it will not permit or endorse employing children in hazardous tasks or environments that could negatively affect their health, safety, and overall well-being.

6.3 Female Labor: The Company prohibits female employees from performing tasks deemed hazardous to their health or safety as per legal guidelines. The Company ensures pregnant employees work in environments that are safe and free from health risks. Furthermore, it strictly forbids dismissal, demotion, or any reduction in benefits due to pregnancy.

6.4 Disabled Labor: The Company promotes the rights and employment of persons with disabilities, providing suitable tasks, creating a supportive working environment, and ensuring compliance with all relevant legal requirements.

6.5 Migrant Labor: The Company ethically and lawfully manages the hiring process of migrant workers, without discrimination, actively preventing all forms of forced labor. It guarantees fair wages and benefits and regularly reviews migrant employment practices to ensure compliance with the legal frameworks of the countries where it operates.

6.6 Equal Opportunity: The Company ensures equal employment opportunities without discrimination. It does not discriminate in hiring practices, wages, compensation, welfare provisions, training and development opportunities, promotions, termination, or retirement based on race, nationality, religion, language, age, gender, marital status, disability, labor union membership, political affiliation, or personal beliefs.

6.7 Workplace Environment and Safety: The Company is committed to maintaining high standards in workplace safety and employment conditions. It ensures safe working environments to improve employee quality of life, adhering to high occupational health and safety standards to prevent accidents, injuries, and work-related illnesses. Regular reviews, development, and improvements ensure ongoing compliance and effectiveness.

6.8 Prevention of Violence, Harassment, and Abuse: The Company fosters a respectful workplace environment with strict measures to prevent all forms of harassment, violence, or abuse. Any form of unwanted power exertion or sexually suggestive behavior, whether verbal, physical, or otherwise, is strictly prohibited. Any violations are subject to stringent disciplinary actions under the Company’s employment regulations.

6.9 Compensation Practices: The Company provides wages, overtime pay, and employment benefits as mandated by law, at or above statutory minimum rates. Employees are regularly informed of their compensation and remuneration details for each pay period.

6.10 Working Hours: The Company ensures working hours do not exceed legal limits, including overtime and work performed on holidays. Standard working hours are clearly defined, including start and end times, scheduled breaks, meal times, annual leave entitlements, and holidays, in accordance with applicable laws.

6.11 Termination and Severance Practices: The Company strictly adheres to the Labor Protection Act B.E. 2541 and subsequent amendments regarding employer obligations and employee rights upon termination. Termination without justifiable cause is prohibited, and employees must receive advance notification and statutory severance pay.

6.12 Freedom of Association and Collective Bargaining: The Company respects employees’ rights to freely join or refrain from joining associations or groups, provided such activities are peaceful, non-violent, and do not impede productivity or customer service. The Company will not interfere with or restrict employees’ freedom of association except when necessary to protect public interests, maintain order, or comply with legal and ethical standards.

7 Human Rights Due Diligence (HRDD) Management and Practices

 The Company mandates human rights due diligence through its risk management process, guided by the five core principles of the United Nations Guiding Principles on Business and Human Rights, as follows:

7.1 Declaration of the Company’s policy and principles on respecting human rights: The Company places importance on respecting human rights and treating employees / stakeholders fairly by adhering to human rights principles and international labor standards, under labor laws and various regulations related to fair labor practices.

7.2 Evaluation of Actual or Potential Impacts from the Company’s Activities: All departments within the organization are required to assess the likelihood (or probability) and the impacts on human rights, the treatment of employees, and fair practices toward stakeholders arising from their participation or involvement in various activities. This evaluation considers both internal and external stakeholder groups that may be affected, such as employees, business partners, customers, consumers, and communities, among others.

7.3 Integrating policies into assessments, including internal and external control mechanisms: All departments must identify human rights risk events and risk factors related to their activities, which are the Company’s business operations. The risk assessment should be conducted using the criteria of Likelihood and Impact Level, such as employee rights, local community or social rights, consumer or customer rights, business partner rights, and shareholder rights. This is to manage the risks that arise and to establish comprehensive prevention, mitigation, or remediation measures to control the risks within the acceptable Risk Appetite, preventing impacts on the departments and the organization.

7.4 Monitoring and Reporting: The Company requires regular quarterly monitoring and reporting of the results to the Risk Management Committee, following the organization’s risk management process. The Company also discloses its human rights performance annually through the 56-1 One Report. The Internal Audit Department is tasked with auditing the adequacy of preventive measures, the completeness of guidelines, and the accuracy of reporting. Additionally, each department within the organization is required to conduct training and communication to raise awareness and understanding among employees regarding human rights management and the fair treatment of employees / stakeholders, both within the department and with external parties with whom the Company has business dealings, such as partners, customers, communities, and other individuals.

7.5 Remedial Actions and Mitigation / Remediation Measures

7.5.1 In the event of human rights violations and the treatment of employees / stakeholders, the Company provides channels for reporting clues or complaints regarding human rights, including other issues that violate the law, for employees and other stakeholders. There are mechanisms to protect employees and whistleblowers in accordance with the Company’s regulations and working procedures, including access to information limited to relevant personnel only.

7.5.2 If any department head, officer, employee, or person responsible for any particular operation neglects, omits, or fails to perform any duty or responsibility, or is the perpetrator, resulting in a violation of human rights and the fair treatment of employees / stakeholders, the Company considers it a disciplinary offense according to the regulations and working procedures. The Company will take immediate action according to the Company’s procedures and will consider disciplinary action in accordance with the Company’s regulations and working procedures. If such action results in a violation of the law, legal action will be taken in accordance with the relevant laws.

7.5.3 In cases where individuals are affected by violations or discriminatory practices, the Company shall designate a representative from the organization who has no conflicts of interest in handling the matter. This representative will be responsible for negotiating, monitoring, and reviewing the outcomes of the investigation conducted by the relevant investigation committee or government agency (if applicable), and for providing necessary and urgent assistance to the affected individuals during the review process to help them return to normal life. Any additional entitlements due to the affected individuals will be determined based on the findings of the investigation, taking into account the nature and severity of the incident, the extent of the damages incurred, and the possibility of further remedial measures as deemed appropriate and/or as prescribed by applicable law.

8 Training

The Company provides communication and dissemination of its human rights and labor practices policies through appropriate training, meetings, or other relevant activities. These initiatives target directors, management, employees, and external stakeholders, including suppliers, business partners, joint ventures, and the general public throughout the value chain. Additionally, the effectiveness of each training session is evaluated systematically.

9 Whistleblowing

Employees and stakeholders are encouraged to report or provide information regarding any observed actions believed to violate this policy and its guidelines. Reporting procedures must adhere to the Company’s whistleblowing policy and procedures. Whistleblowers will be protected, and all information provided will be kept confidential, ensuring no adverse effects on their employment status during or after the investigation process.

Channels for complaints and whistleblowing include:

  1. Complaint box or postal mail addressed to the Company.

  2. Direct reporting to the Board of Directors, Executive Committee, or relevant departments.

  3. Electronic mail (email) to the Company Secretary, Human Resources Department, or Internal Audit Department.

  4. Company website via the whistleblowing or complaint section.

10 Disciplinary Measures

In the event of an investigation, all employees must fully cooperate with both internal and external investigating units. Should executives or employees violate or fail to comply with this policy, either directly or indirectly, disciplinary actions will be considered according to the Company’s internal work rules and regulations.

11 Policy Review

The Good Corporate Governance and Sustainable Development Working Group, together with the Human Resources Department, will review this policy at least once a year.

This policy is effective from May 15, 2024 onwards.

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