PS1: Assessment and Management of Environmental and Social Risks and Impacts
CPN has a corporate sustainability strategy encompassing environmental, social and governance aspects, which will be implemented in the Project Assets as well. Under the sustainability strategy, the Company: implements an ISO14001 (international standards) certified environmental management system (EMS) which commits to meeting national requirements; requires its staff to comply with a code of conduct (CoC); undertakes stakeholder engagement; and implements a supplier CoCcovering all vendors, contractors and service providers. Its EMS, CoC, Supplier CoC, human rights policy and their respective procedures, which cover regulatory compliance, environmental, health & safety, labor/employee working conditions and supply chain aspects, forms CPN’s environmental and social management system (ESMS). CPN undertakes Environmental Impact Assessment and Environment and Health Impact Assessment, for all projects in accordance with national regulations and undertakes human rights due diligence every two years.
Audit and Corporate Governance Committee of the Board oversees the sustainability strategy implementation. Responsibility for implementation of the sustainability strategy is with management committees comprised of executives from relevant corporate functions including committee for: Corporate Governance and Sustainable Development; Climate Change and Environment; Occupational Health, Safety and Environment; Creating Shared Value; and People Development. Day to day management of environmental, health and safety and social (EHSS) aspects is undertaken at each development/branch by teams including for: safety, security, health and environment; energy management and carbon footprint; creating shared value and corporate social responsibility; welfare committee and human capital.
CPN will, per ESAP # 1, for each of the Project Assets undertake a third party E&S due diligence (ESDD) to assess adequacy of its ESMS with respect to the IFC Performance Standards (PSs) requirements and develop an action plan to full fill the gaps (if any). The review and action plan will among other aspects also include (but not limited to); (i) a review of the land purchase process for the Project Assets and legacy issues (if any) related to the land; (ii) a review of its human resource policies and procedures, including those that relate to GBVH, to assess conformance with IFC PS2 provisions; (iii) evaluation of its air and noise emissions versus national regulations and applicable WBG EHS Guidelines guidance values; and (iv) assessment of the effluent quality of the treated wastewater that is discharged to surface water to meet WBG General EHS Guideline guidance values. The Company will, as mentioned at ESAP # 2, implement the updated ESMS for the Project assets that meets the PS and the action plans developed under ESAP # 1.
CPN has a corporate Emergency and Crisis Management Plan which is adapted for each development.CPN has procedures to monitor the EHSS performance parameters and publishes a third party assured sustainability report.
CPN has purchased land for the Project Assets on a willing seller-willing buyer basis. CPN will, as per ESAP # 1, undertake review of the land purchase process for the Project assets, identify legacy issues (if any) related to the land and develop a plan to address the issues.
PS2: Labor and Working Conditions
CPN had in all almost 5,700 employees in 2023 with 50% each male and female. In addition, CPN’s projects and operations require deployment of a large workforce of contract labor. CPN has a code of conduct and human rights policy that requires all employees to adhere to national laws and human rights principles including those related to prevention of child labor, forced labor, non-discrimination and equal opportunity, prevention of violence. Harassment and sexual harassment. The code of conduct includes: an OHS Policy that commits the Company to meeting national law requirements; and treatment of employee policy that commits to providing a fair, transparent, safe and healthy working conditions and environment. As part of the ESAP # 1, for the Project Assets, CPN will, undertake a review of its human resource policies and procedures, including GBVH ,to assess conformance with IFC PS2 provisions and develop an action plan to close identified gaps (if any).
While CPN has no workers union representing its employees but human rights policy commits CPN to freedom of association and it has reported that all employees are covered under collective bargaining agreements. The Company establishes welfare committees at each branch and there is an annual employee engagement survey. CPN has policies that commit to compliance with legal requirements on working conditions for all employees including migrant foreign workers.
CPN has a whistleblowing and complaints system in place for external and internal stakeholder including for employees and contractors. The whistleblower system provides for filing anonymous complaints, commits to confidentiality protection and non-retribution, provides multiple channels for filing complaint and CPN records and reports employee complaints received and resolved.
The Company has an occupational health safety and environment committee at corporate level and safety, security, health and safety teams at branch. CPN undertakes risk assessment, has standard operating procedures for safety and provides training on OHS to employees. The Company monitors and reports fatalities, lost time injuries, lost time injury frequency rates covering both employees and contract workers.
Supply Chain and Third Party Worker: CPN has a Supplier CoC that covers contractors, vendors and service providers. The supplier CoC requires them to commit to: prevention of forced labor and child labor; nondiscrimination; prevention of sexual harassment; provide wages, benefits and working conditions as per law; meet occupational health and safety requirements of the law; undertake environmentally responsible operations; and provides access to the whistleblower system. The Company has procedures for E&S evaluation of supplier prior to selection/registration and E&S performance review during delivery of goods and services.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: CPN has corporationwide programs and targets to: reduce greenhouse gases (GHG); reduce energy consumption; increase share of renewables in its energy mix; reduce water consumption; and reduce waste sent to landfill. CPN assess and reports gross consumption of energy and water as well as consumption intensity per gross leasable area (GLA) to public through its sustainability reporting. Resource efficient initiatives includes rooftop solar panels installations and energy management audits. Total scope 1, 2 & 3 GhG emissions of the Company in 2023 was 688,079 tCO2e as reported in the Sustainability Report.
Water consumption: CPN has water management policies and programs. Accordingly, the Company monitors and reports gross water consumption and consumption intensity.
Pollution Prevention: For the Project Assets, emission sources are limited to back up generators and boilers for heating purposes. As part of ESAP#1, the company will also evaluate its air and noise emissions versus national regulations and applicable WBG EHS Guidelines guidance values.
Wastewater: CPN’s facilities have wastewater treatment plants that have either just primary treatment or include secondary treatment with sequential batch reactors and deep shaft systems. Secondary treated water is discharged to surface water and primary treated water is discharged to municipal treatment ponds. In 2023, about 68% of all wastewater discharged was after secondary treatment. CPN has policy to monitor treated wastewater quality prior to discharge. The Company will, as mentioned at ESAP # 1, for the Project Assets, assess the effluent quality of the treated wastewater that is discharged to surface water to meet WBG General EHS Guideline guidance values, in addition to the limits set by the national authorities.
Wastes: CPN has policies and procedures for segregation, handling, storage and disposal of wastes. The Company has programs in place to promote recycling, reuse and reduction of wastes. CPN categorizes wastes as hazardous, electronic, infectious, general, incinerable for energy (e.g. refuse derived fuel), recyclable (plastic, paper, metal, can glass) and food/food preparation related. Company has a program to divert waste from landfill and disposal. The Company will, as mentioned at ESAP # 2, for the Project Assets, implement a duty of care procedure for disposal of hazardous wastes management.
Hazardous materials: CPN’s facilities store and handle hazardous materials like diesel, LPG, gasoline and oil. The Company will, at the Project Assets, as mentioned at ESAP # 3, put in place policies, procedures and facilities like: gas leak sensor, sensor activated alarm systems, and automatic fire extinguisher systems in gas storage; double walled storage for diesel (if underground tank) with procedures for periodic leakage checking; and procedures for pesticides and chemicals used for pest control to meet national and PS requirements.
CPN’s performance on these aspects is available in its sustainability reports at https://www.centralpattana.co.th/en/sustainability/sustainability-reporting-library
PS4: Community Health, Safety and Security
CPN’s buildings are built and certified to national standards of Thailand, have emergency escape plans and periodic fire drills. The Company undertakes periodic third party audits that cover safety and life and fire safety. The Company will, as mentioned at ESAP # 4, for the Project Assets provide relevant documents to demonstrate that: stability/safety of building are designed built, assessed and verified periodically and certified by competent professionals as per regulations; there is periodic inspection, testing and maintenance program, inline with national requirements and good international industrial practices. The assessment will include (but not be limited to) evaluation of equipment like roof mounted, monorail jib crane system; lifts; escalators; other lifting tools and tackles; and electro-mechanical equipment, entry and exit gates and their placement considering traffic impacts on the local road network; provision for pedestrians and universal access within premises; parking; and measures/procedures for traffic and heavy vehicle movement management in peak and non-peak hours.
Life and Fire Safety (LFS) Management: CPN’s facilities are designed to meet LFS standards of Thailand. The Company will, as mentioned at ESAP # 5, for each of the Project Assets: (a) undertake independent risk-based review of current conditions of the structure, LFS infrastructure and systems, maintenance of LFS infrastructure, emergency response plan & training for conformance to an international standard (such as US NFPA, UK BS, EU code, Fire Code of Singapore); (b) identify gaps with the selected standard and develop an action plan to close the gaps. CPN will, as mentioned at ESAP # 6, implement the LFS action plan developed at ESAP # 6 at each of the Project Assets.
CPN’s facilities, as part of the loss prevention department, have a fire prevention, detection and control team comprised of qualified firefighting professionals. Procedures defining roles and responsibility of the firefighting team are in place.
Security Personnel: CPN engages unarmed security personnel through outsourced security agencies. The Company will, as mentioned at ESAP # 7, for the Project Assets put in place procedures: to undertake security risk assessment; for recording, investigation and corrective action after security incidents; security awareness training for all employees and contract workers; to ensure that past records of security personnel are screened; for disciplinary action against security personnel who violate standard operating procedures; ensure that security personnel are trained in avoidance of human rights violations; and there is a grievance mechanism for aggrieved members of community, customers or employees in the event of a violation of the code for security personnel.
