Environmental and Social Assessment and Management System - Policy
RATCH has developed a sustainable development strategy and has put in place policies, procedures and an organization structure to implement the sustainable development strategy. Towards implementation of this strategy, RATCH has in place a code of conduct and among other aspects, have issued: (a) a Risk Management Policy that requires structured risk assessment and management taking into account commercial and reputation risks; (b) Employee Policy focused on employee working conditions and adherence to international standards; (c) Corporate Social Responsibility (CSR) Policy for community development and engagement with neighboring communities; (d) Safety, Occupational Health and Working Environment Policy to put in place a management system to adhere to applicable legal requirements and international standards related to occupational health, safety and work environment; (e) Energy Conservation Policy to develop and implement an energy management system; (f) Office Building Environment Management Policy to effectively manage impact on energy and resources as also physical environment in the buildings; and (g) Corporate Sustainability Policy that covers aspects including governance and transparency, economic sustainability, safety, employee rights, environment, biodiversity, climate change, community development, stakeholder engagement and disclosure.
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RATCH has in place a code of conduct, which all employees have to commit to adhere to. The code of conduct covers among other aspects commitment to: sustainable development; compliance with laws; treatment of stakeholder; safety, occupational health and work environment; drug prevention; security management; crisis management; human rights; non-discrimination; conservation of natural resources; climate change; and whistle blowing and complaints handling process.
Pursuant to these policies, RATCH required its subsidiary Ratchaburi Electricity Generating Company Limited (RGEN), which houses 3,645 MW of RATCH’s total generating capacity to implement an ESMS certified to ISO 14001:2015 and ISO 45001:2018. RATCH and RHIS will, as described at ESAP # 1, 2and 3, commit to and put in place an appropriate ESMS and a set of procedures to ensure that the project company in which IFC funds are deployed meets IFC PSs and aligns with good international industry practice (GIIP) as per applicable and relevant parts of the World Bank Group (WBG) Environmental Health and Safety (EHS) Guidelines.
Identification of Risks and Impacts
RATCH has formal processes in place to assess enterprise and project risk taking into account economic, social, health, safety and environmental aspects and has formal procedures for implementation of the E&S policies and the code of conduct it has articulated. RATCH’s subsidiaries or investee companies assess E&S risk as part of the national legal requirements and as part of their respective ESMS development to comply with RATCH’s E&S policies. Further, RATCH has procedures to: select, evaluate and screen eligible green projects it proposes to invest in; review and approve projects for investment; review the allocation of the proceeds annually; and to carry out an analysis of climate and environmental issues of relevance to RATCH operations
Management Programs
RATCH is implementing procedures to align with the requirements of Equator Principles and ADB Safeguards in its project feasibility studies, financing, construction and operation. Further, RATCH, through it’s subsidiaries, is in the process of implementing programs for: resource efficiency; greenhouse gas (GhG) reduction; emission and waste management; strengthening integration of E&S aspects in project development, construction and operation; safety management for employees, communities and supply chain; employee engagement; community development and engagement; supplier code of conduct and supplier E&S risk assessment; employee rights, non-discrimination and equal opportunity, prevention and redress of sexual harassment; occupational health and safety; drug prevention; security management; and crisis and emergency preparedness and response. Further, as mentioned at ESAP # 2, RATCH and RHIS will, for the project funded with IFC proceeds, put in place procedures to ensure that as part of the investment agreement between them and the project company, the project company and its subsidiaries are required to: (a) undertake their current operations and future projects in accordance with IFC PSs and implement an ESMS that meets IFC PS requirements; (b) implement the E&S action plan to meet IFC PSs; (c) only undertake future projects that are Category B projects as per IFC Sustainability Policy; (d) periodically provide relevant data, information and evidentiary documents to demonstrate compliance with (a) to (c) here-before; and (e) allow RATCH and their lender whose proceeds have been used for the project, to supervise these projects including as required site visits and access to relevant E&S information and documentation.
Organizational Capacity and Competency
The E&S governance structure at RATCH commences at sub committees of its Board of Directors including: (a) Risk Management Committee, which is responsible for oversight of enterprise and project-level risks considering economic, social and environmental aspects and identification of emergent risks; (b) Human Resources and Remuneration Committee which is responsible for oversight of human resource management including selection, nomination, recruitment, capacity building, career advancement, performance evaluation, remuneration and welfare, equal opportunity, individual rights and human dignity as per international labor standards covering Board Directors, management and employees; (c) Investment Committee which is responsible for investment decision taking into account adequacy of risks assessment with respect to projects’ impacts on the economy, environment, society and community rights, compliance with legal requirements and risks associated with projects’ significant business partners and suppliers; and Corporate Governance and Social Responsibility Committee which defines and oversees business ethics, stakeholder relations, social responsibility and sustainable development.
Boards directives are implemented by five management functions: business development is responsible for risk assessments; project development is responsible for impact assessment and mitigation in project design and construction; asset management is responsible for E&S risk and impact management during operation stage including oversight of subsidiaries operations; corporate administration is responsible for human resource management and oversight of sustainability strategy implementation and accounting & finance function is responsible for corporate financial plans and ensuring financial disclosure’s compliance with international standards.
For implementation of various procedures and programs, management committees are in place including: human resource management committee; safety, occupational health and work environment committee; environment social and governance working group; risk management working group; office building energy and environment management working group; and sustainable development department. The sustainable development department, which is part of the corporate administration function, is responsible for oversight of implementation of the sustainability strategy and disclosure of relevant information to the stakeholders. There are in all 23 dedicated staff for E&S work at RATCH corporate including three environmental staff, one occupational health and one safety staff, eight community relations staff and ten human resource professionals. A team of employees and outsourced O&M staff are trained ISO 14001 and ISO 45001 auditors.
Monitoring and Review
Monitoring activities are undertaken at each plant and subsidiary level. RATCH at group level obtains, compiles and monitors: status of implementation of the various E&S management programs and activities against identified milestones and targets; GhG emissions, emission reduction, sequestration and carbon credits earned; supplier qualification assessment; eco-friendly products procured; fuel consumption and efficiency; water consumption; volume of recycled water; emissions to air; wastewater quantity and quality; quantity and type of waste generated and mode of disposal; quantity of waste reused; lost time and total injury frequency rate; occupational illness; records of drills; internal and external training by themes and training hours; employee grievances; employee engagement survey results; community engagement and complaints; and CSR initiatives. Each project company undertakes periodic corporate audits of the E&S performance of each of its plants and subsidiaries. The analysis of information from the monitoring program, third party and internal audits informs project management review process. RATCH and RHIS will, as mentioned at ESAP # 3, develop and implement a procedure to commence monitoring the E&S performance of the project company funded by IFC proceeds including status of E&S action plan implementation.
