Trimegah Bangun Persada

Human Rights Due Diligence

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In the pursuit of upholding human rights principles, PT Trimegah Bangun Persada Tbk (TBP) engaged in human rights due diligence in partnership with the Foundation for International Human Rights Reporting Standards (FIHRRST), starting in September 2023.

As incorporated in the executive summary of our human rights due diligence, we evaluated and addressed potential impacts throughout our operations, supply chain, and engagement with stakeholders, ensuring that human rights considerations remained paramount in our business approach. The assessment has highlighted notable strengths and areas of improvement in TBP's commitment to and practice of human rights.

Taking into account stakeholders' concerns regarding labor conditions in Nickel Mining in Indonesia, we also summarized the findings of the human rights due diligence regarding labor within TBP's operations here

Executive Summary

In September 2023, PT. Trimegah Bangun Persada Tbk. or "The Company" or "TBP" invited the Foundation for International Human Rights Reporting Standards (FHIRRST) to undertake a Human Rights Due Diligence (HRDD) process. The purpose of the HRDD was to: 

  1. Assess the level of compliance of the Company’s policies, procedures and performance with international human rights standards and best practices for business operations; 
  2. Identify human rights actual and potential impact areas within and across the various business units of TBP; 
  3. Rank the severity and prevalence level of each impact.

FIHRRST’s Human Rights Due Diligence (HRDD) process refers to operational principles of the United Nations Guiding Principles on Business and Human Rights/UNGPs (Principles 17 to 21 and 24) to identify, prevent, mitigate and account for potential and actual adverse human rights impacts related to a company’s business operations, created either through its activities or as a result of its business relationships.

At the time of the HRDD, the Company had developed four business units and affiliated companies, namely PT Gane Permai Sentosa (GPS), PT Megah Surya Pertiwi (MSP), PT Halmahera Persada Lygend (HPAL), and PT Halmahera Jaya Feronickel (HJF) – which are nickel & cobalt mining and ore processing units.

Unit-level management teams, factory workers and other key personnel were actively engaged during HRDD process. Other stakeholders, such as trade union representatives, government authorities, community representatives, local NGOs and other business partners, were consulted during the assessment process.

During HRDD activities, stakeholder engagement is considered a cross-cutting component for every phase of an HRDD process, since human rights risks may be associated with a company’s business activity.

Overall, the Company has shown adherence to both nationally and internationally recognized and regulated human rights standards, internally and externally. The assessment identifies significant strengths and areas of improvement in TBP's commitment to and practice of human rights.

First, the Company had embarked on a comprehensive journey towards implementation of safety and health best practices. Clearly defined measures to protect workers' health and safety are stipulated in the Company’s occupational health, and safety and environmental policies, and practices.

Some business units had already received ISO450001 & SMK3 certification and others were moving towards achieving these certifications, emphasizing the importance of this area to the company. ISO45001, is an international standard that specifies requirements for an occupational health and safety (OH&S) management system, while SMK3 (Sistem Manajemen Keselamatan dan Kesehatan Kerja) is a widely recognized Indonesian health & safety certification.

However, there is still room for improvement in health & safety-related practices. For example, the establishment of collaboration with contractors and communities would make the company’s health & safety programme more inclusive and cohesive.

Internally, the Company has demonstrated best practices regarding labor-related issues. Protection of workers' rights is ensured by providing written and understandable employment contracts detailing wages, working hours, rest time, benefits, as well as terms and conditions of the employment relationship.

Housing facilities for workers on the operational site are adequate, and additional services, like entertainment and sports facilities are provided. Yet, some areas of concern emerged from business partners and contractors. Consequently, collaboration with contractors and business partners is considered crucial.

Second, externally, the Company has conducted an Environmental Impact Assessment and communicated the results to the community. The Company offers medical services in local villages and keeps track of the health of the community, on issues related to resettlement and environmental protection. Similarly to the health & safety programme, these efforts can be enhanced by strengthening the Company’s engagement with the community, especially in determining remedy measures.

Furthermore, the company's touch points with the community have evolved and already include a grievance system (Saluran Aspirasi Masalah/SALAM) with dedicated grievance forms and community interaction procedures (Sarana Komunikasi Masyarakat/Sarakia), which are both managed by dedicated staff engaging regularly with local villagers. Therefore, the Company is well informed about the community’s needs and concerns, which enabled the development of a positive relationship.

Yet, there is a need to make engagement with key stakeholders more inclusive, and create joint environmental monitoring activities that are conducted in partnership between the company and communities.

The issues of community health and safety, resettlement, and environmental protection are prominent in the Kawasi and Soligi villages that are located near the Company’s operations.

Concerning the planned resettlement of Kawasi, the Company should strengthen the engagement and consultation with the community to determine a fair remedy scheme. In addition, community health and safety issues are rooted in improper in-migration management.

As the Company will expand its operations, the Company must collaborate with the government in spatial planning and housing management in light of increasing transmigration of population from surrounding areas looking for employment and earning opportunities.

Additionally, the assessment highlights the importance of inclusive stakeholder engagement and joint environmental monitoring activities between the Company and communities in Kawasi and Soligi Villages.

This is crucial to ensure environmental protection and to address any rumors that could potentially harm the community and Company's reputation.

Third, the HRDD also evaluated how adverse human rights impacts are addressed and tracks the Company’s responses to prevent and mitigate any future impacts. An example of a result of this assessment was that, although the Company has developed policies and standards to implement respect for human rights in its supply chain, much work is still needed to establish effective monitoring of the human rights performance of suppliers.

Examples of recommended improvement measures in this area include building a cross-functional supply chain management system, dedicated human rights training for procurement-related activities, awareness raising for business partners, among other measures.

In sum, this report has resulted in a time-bound action plan for the Company to address both potential and actual human rights impacts.

However, it is important to emphasize that the Company should conduct annual assessments to ensure that the risks and impacts are effectively addressed according to the proposed action plan.

This ongoing evaluation process is essential to adapt to changing circumstances, monitor progress, and continuously improve the Company's approach to human rights management.

To increase transparency about our working conditions, we also published the full labor rights section from the due diligence.

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