Corporate Governance

We are committed to achieving a high standard of corporate governance to ensure the sustainability of the our businesses and performance. The following codes and policies provide a framework for corporate fairness, transparency, accountability and the protection of shareholder interests.

1. THE BOARD OF DIRECTORS

1.1 The board should meet regularly, retain full and effective control over the company and monitor the executive management.

1.2 There should be a clearly accepted division of responsibilities at the head of a company, which will ensure a balance of power and authority, such that no one individual has unfettered powers of decision. Where the chairman is also the chief executive, it is essential that there should be a strong and independent element on the board, with a recognised senior member.

1.3 The board should include non-executive directors of sufficient calibre and number for their views to carry significant weight in the board’s decisions.

1.4 The board should have a formal schedule of matters specifically reserved to it for decision to ensure that the direction and control of the company is firmly in its hands.

1.5 There should be an agreed procedure for directors in the furtherance of their duties to take independent professional advice if necessary, at the company’s expense.

1.6 All directors should have access to the advice and services of the company secretary, who is responsible to the board for ensuring that board procedures are followed and that applicable rules and regulations are complied with. Any question of the removal of the company secretary should be a matter for the board as a whole.

2. NON-EXECUTIVE DIRECTORS

2.1 Non-executive directors should bring an independent judgement to bear on issues of strategy, performance, resources, including key appointments, and standards of conduct.

2.2 The majority should be independent of management and free from any business or other relationship which could materially interfere with the exercise of their independent judgement, apart from their fees and shareholding. Their fees should reflect the time which they commit to the company.

2.3 Non-executive directors should be appointed for specified terms and reappointment should not be automatic.

2.4 Non-executive directors should be selected through a formal process and both this process and their appointment should be a matter for the board as a whole.

3. EXECUTIVE DIRECTORS

3.1 Directors’ service contracts should not exceed three years without shareholders’ approval.

3.2 There should be full and clear disclosure of directors’ total emoluments and those of the Chairman and highest-paid director, including pension allowances. Separate figures should be given for salary and performance-related elements and the basis on which performance is measured should be explained.

3.3 Executive directors’ pay should be subject to the recommendations of a remuneration committee made up wholly or mainly of non-executive directors.

4. REPORTING AND CONTROLS

4.1 It is the board’s duty to present a balanced and understandable assessment of the company’s position.

4.2 The board should ensure that an objective and professional relationship is maintained with the auditors.

4.3 The board should establish an audit committee of at least three non-executive directors with written terms of reference which deal clearly with its authority and duties.

4.4 The directors should explain their responsibility for preparing the accounts next to a statement by the auditors about their reporting responsibilities.

4.5 The directors should report on the effectiveness of the company’s system of internal control.

4.6 The directors should report that the business is a going concern, with supporting assumptions or qualifications as necessary.

HTOO Group requires all members of the group as well as its subsidiaries and their directors, officers and employees to observe high standards of integrity and honesty, and to act with care, diligence and fairness in all our business activities.  All our interactions with stakeholders and wider society should be conducted in an ethical and proper manner.

HTOO Group’s code of conduct applies to all full- and part-time directors, officers, employees and other temporary staff of the group and its subsidiaries.

CONFIDENTIALITY

We are committed to maintaining the highest degree of integrity in all our dealings with potential, current and past clients, both in terms of normal commercial confidentiality, and the protection of all personal information received in the course of providing the business services concerned. We extend the same standards to all our customers, suppliers and associates.

ETHICS

We always conduct our own services honestly and honourably, and expect our clients and suppliers to do the same. Our operations, strategic assistance and the methods imparted through our training, take proper account of ethical considerations, together with the protection and enhancement of the moral position of our clients and suppliers.

DUTY OF CARE

Our actions and operations will always conform to relevant law, and we believe that all businesses and organizations, including this company, should avoid causing any adverse effect on the human rights of people in the organizations we deal with, the local and wider environments, and the well-being of society at large.

CONFLICT OF INTEREST

Due to the sensitive nature of some of our business operations, we will not provide a service to a direct competitor of a client, and we generally try to avoid any dealings with competitor companies even after the cessation of services to a client.

CONTRACTS

Our contract will usually be in the form of a detailed proposal, including aims, activities, costs, timescales and deliverables. The quality of our service and the value of our support provide the only true basis for continuity. We always try to meet our clients’ contractual requirements, and particularly for situations where an external funding provider requires more official parameters and controls.

FEES

Our fees are always competitive for what we provide, which is high quality, tailored, specialised service. As such we do not generally offer arbitrary discounts; generally a reduction in price is only enabled by reducing the level or extent of services to be delivered. That said, we always try to propose solutions which accommodate our clients’ available budgets and timescales. Wherever possible we agree our fees and basis of charges clearly in advance, so that we and our clients can plan reliably for what lies ahead, and how it is to be achieved and financially justified.

PAYMENT

We aim to be as flexible as possible in the way that our services our charged. Some clients prefer fixed project fees; others are happier with retainers, and we try to fit in with what will be best for the client. We make no attempt to charge interest on late payments, so we expect payments to be made when agreed. Our terms are generally net monthly in arrears.

INTELLECTUAL & MORAL PROPERTY RIGHTS

We retain the moral rights in, and ownership of, all intellectual property that we create unless agreed otherwise in advance with our clients. In return we respect the moral and intellectual copyright vested in our clients’ intellectual property.

QUALITY ASSURANCE

We maintain the quality of what we do through constant ongoing review with our clients, of all aims, activities, outcomes and the cost-effectiveness of every activity. We encourage regular review meetings and provide regular progress reports. This consultancy has been accredited under a number of quality assurance schemes. Further details are available on request.

PROFESSIONAL CONDUCT

We conduct all of our activities professionally and with integrity. We take great care to be completely objective in our judgement and any recommendations that we give, so that issues are never influenced by anything other than the best and proper interests of our clients.

EQUALITY AND DISCRIMINATION

We always strive to be fair and objective in our advice and actions, and we are never influenced in our decisions, actions or recommendations by issues of gender, race, creed, colour, age or personal disability.

OUR COMMITMENT TO ANTI-CORRUPTION

HTOO Group and its subsidiaries (collectively, “HTOO Group” or the “Company”) are committed to complying with all applicable laws in their operations. Further, our Company intends not to just comply with those legal requirements, but to conduct its business in accordance with a high level of honesty and integrity.

Each officer, director, employee and business associate of the Company is expected to act in good faith and with integrity in the performance of his or her responsibilities on behalf of the Company and in compliance with all applicable laws, rules and regulations.

All employees are expected to report appropriately any indications of illegal or improper conduct.

This policy shall be reviewed regularly and may be updated from time to time without prior notice.

SCOPE

This policy statement applies to all operations of the Company, including the Company’s vendors, suppliers, representatives, contractors, subcontractors and agents.

POLICY AGAINST BRIBERY AND CORRUPTION 

It is the policy of HTOO Group to prohibit bribery and other corrupt conduct in any form. Bribery and kickbacks involving government officials, customers, suppliers and other counterparties in the commercial marketplace are specifically prohibited.

Accordingly, neither HTOO Group nor any Company Representative may, directly or indirectly, offer, promise, pay, give or authorize any financial or other advantage, or anything else of value, to any other person or organization, with the intent to exert improper influence over the recipient, induce the recipient to violate his or her duties, secure an improper advantage for HTOO Group or improperly reward the recipient for past conduct.

No person subject to this policy will suffer adverse consequences for refusing to offer, promise, pay, give or authorize any such benefit, advantage or reward, even if this results in the loss of business to HTOO Group.

In addition, no HTOO Group director, officer, employee, agent or other representative may request, agree to receive, or accept anything of value from any other person as an inducement or reward for violating his or her duties to HTOO Group or in exchange for an improper benefit.

Definitions
For purposes of this policy:

o “Company Representative” means any Company director, officer, shareholder, member, manager or employee, or any agent, consultant, representative or other intermediary acting for the Company, and any supplier, vendor, distributor or teaming, alliance or joint-venture partner;

“Public Official” means any officer or employee of a government or any department, agency or instrumentality thereof, including, but not limited to, an employee of a state-owned or -controlled company, an employee of a public international organization, a political party, a party official or candidate for office, and anyone working in an official capacity for or on behalf of a government or any department, agency or instrumentality thereof, as well as anyone who exercises a public function for or on behalf of a country, public agency or public enterprise. Some examples of Public Officials include: employees of national oil companies or other state-owned enterprises, members of royal families, members of the military, employees of state- owned universities, employees of the World Bank, the United Nations, the European Union and the International Monetary Fund, and immigration and customs officials. Public Officials include all levels and all ranks of government officials, whether at the federal, state, provincial, county, municipal or other level;

“a financial or other advantage, or anything of value” and similar references in this policy include not only cash and cash equivalents, but also gifts, entertainment, travel expenses, accommodations and anything else of tangible or intangible value; and

“obtaining or retaining business or securing an improper advantage” includes, but is not limited to, preferential treatment in a bid, a reduction in taxes or customs duties, a favorable change in regulations, tolerance of non-compliance with local rules or other favors or preferential treatment. The business to be obtained or retained or the improper advantage need not involve a contract.

  • Examples of Prohibited Conduct 

All Company Representatives are strictly prohibited at all times from:

(a) offering, promising or giving a financial or other advantage to another person intending to:

(1) induce a person to improperly perform a function or activity, or

(2)  reward a person for the improper performance of a function or activity,

(3)  when the function or activity is either:

(i)  of a public nature,

(ii)  connected with a business,

(iii)  performed in the course of a person’s employment, or

(iv)  performed by or on behalf of a body of persons (whether corporate or unincorporated);

(b)  requesting, agreeing to receive or accepting a financial or other advantage from another person or company as:

(1)  an inducement to perform or not perform a function or activity, or

(2)  a reward for the improper performance (whether by the Company Representative himself or herself or another person) of a relevant function or activity,

(3)  when the function or activity is either:

(i)  of a public nature,

(ii)  connected with the Company’s business,

(iii)  performed in the course of employment or engagement by the Company or any of its affiliates, agents, representatives or business partners, or

(iv)  performed by or on behalf of the Company or any of its affiliates, agents, representatives or business partners; or

(c)  offering, promising or giving a financial or other advantage, whether directly or indirectly through a third party:

(1) to a Public Official, or

(2) to another person at the request or with the knowledge of a Public Official, in order to obtain or retain business and/or gain a business advantage.

  • Books and Records 

Each Company Representative shall keep and maintain books, records and accounts in reasonable detail that accurately and fairly reflect transactions in or related to the Company’s business, including, but not limited to, accurately and fairly recording the purpose of any payment received or made.

The Company has adopted a system of internal accounting and operating controls and procedures to which all Company Representatives must adhere in providing financial and business transaction information in the Company’s business and affairs, so that all underlying transactions are properly documented, recorded and reported.

  • Training 

All Company personnel will receive and participate in training to understand and implement the Anti-Corruption Policy. Senior management and Company Representatives engaged in areas of heightened risk (discussed further below) will receive focused training on compliance with this policy. Such training will include, but not be limited to, an initial orientation session supplemented by reinforcement training as necessary.

  • Audits

Compliance with this policy is subject to audit. All Company Representatives shall cooperate in such audits as requested.

  • Reporting 

If any Company Representative is asked to give or accept any financial or other advantage referred to above, becomes aware of the offering, giving, provision or acceptance of the same by a Company Representative, or has any related concern or complaint, he or she should promptly report the same to his or her supervisor, any member of management, the Human Resources, Compliance, or Legal Department. A Company Representative may also report such concerns or complaints through anonymous reporting mailbox which may be accessed twenty-four hours a day, seven days a week at HTOO Group Head Office or by calling the telephone number provided during office hours. An operator will assist Company Representatives making a telephone report.

AREAS OF HEIGHTENED RISK 

  • Generally 

Known areas of heightened risk of bribery and corruption include:

(i) transactions in which intermediaries, such as brokers, sales representatives, finders and agents, act between commercial parties or between those parties and the public sector;

(ii) gifts and entertainment, particularly where strong traditions of gift-giving and hospitality extend to commercial relationships and

(iii) numerous areas where HTOO Group operates, where perceived levels of corruption are high. Company Representatives must be especially sensitive to these heightened risks, and refuse and report any invitation to participate in prohibited conduct.

  • Payments under Duress 

If a Company Representative perceives an imminent threat to the life, health, safety or liberty of himself or herself or those around them, he or she may take steps reasonable under the circumstances to avoid that risk, including, if necessary, making a payment that is demanded in connection with the threat. The Company Representative should report the payment as soon as reasonably possible as provided under the Reporting heading above. Any such payment must be properly documented and recorded as provided under the Books and Records heading above.

  • Political Contributions

No direct or indirect political contribution may be made on behalf of HTOO Group or with HTOO Group funds unless authorized by HTOO Group’s Board of Directors, through the Audit Committee. These restrictions apply not only to cash donations, but also to donations in kind, such as free meals, offering a client list for a political purpose, providing materials or services, or paying for a research project.

All donations must be accurately recorded in the Company’s Books & Records heading above. These expenses must be booked in the package “Political Contributions”.

Employees will not be reimbursed for political contributions. Employees’ jobs will not be affected by their choices in personal political contributions.

  • Facilitating Payments 

In certain regions, payments to secure the performance of routine official functions, such as connecting utilities, providing police protection and processing visas, are common. These payments are sometimes referred to as “facilitating” or “grease” payments. Therefore, in order to comply with applicable law and promote adherence to the highest ethical standards in its business and affairs, HTOO Group policy generally prohibits such payments in its business and affairs; and provides for approval of such payments only under certain limited circumstances and after appropriate review and approval. 

For any such payment to be considered, it must be reviewed by relevant management and the Legal Department. Only a General Manager or more senior officer of the Company, with the advice and consent of the General Counsel or his or her designee, may authorize such a payment. Any such payment must be properly documented and recorded as provided under the Books and Records heading above.

PENALTIES AND SANCTIONS 

Violations of anti-corruption laws may result in severe fines, imprisonment and other sanctions, such as loss of export privileges and debarment from government contracting. In addition, other consequences may follow, including damage to reputation, loss of share value, termination of employment, career damage and legal expense.

Appropriate action will be taken by the Company against any Company Representative who violates this policy, up to and including dismissal or equivalent action.

HTOO Group will not pay fines or penalties assessed against Company Representatives for the violation of anti-corruption laws.

LOCAL CUSTOMS AND PRACTICES 

All Company Representatives must follow this policy, even if it conflicts with local customs or practices. For example, the fact that the giving, offering or acceptance of payments, gifts, entertainment or other things of value is perceived as usual, expected or customary does not make it permissible under this policy or applicable anti-corruption laws. Gifts and entertainment may be offered, given, provided and accepted only as set forth in the Code of Conduct. Where there is a conflict between applicable laws or regulations, Company Representatives should consult the Legal Department.

NO EXCEPTIONS 

No Company Representative has authority to violate this policy or any applicable anti- corruption laws or to authorize anyone else to do so.

FURTHER INFORMATION 

Anti-corruption laws around the world can be complex and far reaching. This policy is not intended to be an explanation of all the specific provisions of those laws or an exhaustive list of activities or practices which could affect the reputation and goodwill of the Company’s business. This policy should be read in conjunction with the Company’s other policies governing employee conduct, and any questions addressed to the Legal Department.

GENERAL PRINCIPLES

We aim to provide a fair, equitable and productive work environment for all employees. This policy seeks to support the achievement of this goal by providing a transparent and consistent process for resolving grievances.

Negotiated solutions will aim to address the key issues and be acceptable to all individuals or parties involved without ascribing blame, victimisation or discrimination. Complainants will not suffer any disadvantage, victimisation or discrimination as a result of raising a grievance, with minimum stress and maximum protection for all concerned.

Every manager and employee has a responsibility to comply with this policy and to treat everyone who works here with dignity and respect. Seeking redress of a trivial or vexatious issue through a grievance procedure will not be tolerated and may result in disciplinary action.

DEFINITIONS

Grievance – A wrong or hardship suffered (real or perceived), which is the grounds of a complaint.

Complaint – An expression of grievance, dissatisfaction or concern.

Victimise – To act or omit to act towards a person in a way which is intended to cause disadvantage to that person because they have made a complaint, or may make a complaint, or may be or are the subject of a complaint.

RIGHTS & RESPONSIBILITIES

All persons have the right to:

  • make a complaint to their direct manager or another member of the company at an appropriate level
  • be treated with respect and impartiality and provided with support throughout the process
  • have the principles of natural justice and procedural fairness observed. This means:
    • complaints must be fully described by the person with the grievance
    • the person who is the subject of concern must be informed of all the allegations in relation to his/her behaviour
    • the person who is the subject of concern must have a full opportunity to put forward their case
    • all parties to the complaint must have the right to be heard
    • all relevant submissions and evidence must be considered
    • irrelevant matters must not be taken into account
    • the decision-maker must be impartial, fair and just
  • investigations and proceedings that are conducted honestly, fairly and without bias.
  • no undue delay in investigations and proceedings.

It is the responsibility of all parties involved in a grievance to participate fully in the resolution process in good faith. Confidentiality must be respected and maintained at all times within the constraints of the need to fully investigate the matter, subject to any legal requirements for disclosure and consistent with the principles of natural justice.

FOUR LEVEL RESOLUTION GUIDE

  1. The employee attempts to resolve the complaint as close to the source as possible, generally a direct communication.  This is quite informal and verbal.  Should the employee not feel confident in this, they should proceed to Level 2.
  2. The employee notifies their manager (in writing or otherwise) as to the substance of the grievance and states the outcome sought. Discussion should be held between the employee and any other relevant party. This level will usually be informal but either party may request written statements and agreements.Should the person who is the subject of the complaint be the employee’s manager, the employee should notify another manager, or another member of the company at an appropriate level. This level should not exceed one week.If the matter is not resolved, proceed to Level 3.
  3. The manager must refer the matter to the top management. A grievance taken to this level must be in writing from the employee. The manager will forward any additional information thought relevant. The top management will provide a written response to the employee. The top management also communicates with any other parties involved or deemed relevant. This level should not exceed one week.If the matter is not resolved, proceed to Level 4.
  4. The employee will be advised of his/her rights to pursue the matter with external authorities if they so wish.

OBJECTIVES
HTOO GROUP and its subsidiaries  have implemented the policy on “Whistleblowing” in order to:

  • To provide avenues for employees to raise concerns and define a way to handle these concerns.
  • To enable Management to be informed at an early stage about acts of misconduct.
  • To reassure employees that they will be protected from punishment or unfair treatment for disclosing concerns in good faith in accordance with this procedure.
  • To help develop a culture of openness, accountability and integrity.

SCOPE

This Policy governs the reporting and investigation of improper or illegal activities at HTOO Group, as well as the protection offered to the “Whistleblowers”. This Policy DOES NOT apply to or change the Company’s policies and procedures for individual employee grievances or complaints relating to job performance, terms and conditions of employment, which will continue to be administered and reviewed by HTOO Group’s Human Resources Department.

Protection

This policy is designed to offer protection to those employees of the Company who disclose such concerns provided the disclosure is made:

  • in good faith
  • in the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety and if they make the disclosure to an appropriate person (see below). It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure. In an extreme case malicious or wild allegations could give rise to legal action on the part of the persons complained about.

Confidentiality

The Company will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

Anonymous Allegations

This policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the discretion of the Company.

In exercising this discretion, the factors to be taken into account will include:

  • The seriousness of the issues raised
  • The credibility of the concern
  • The likelihood of confirming the allegation from attributable sources

Untrue Allegations

If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious or vexatious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.

PROCEDURES FOR MAKING A DISCLOSURE

  1. Any person may report allegations of suspected serious misconduct or any breach or suspected breach of law or regulation that may adversely impact the Company, the Company’s customers, shareholders, employees, investors or the public at large.
  2. Acts of misconduct may be disclosed in writing, telephonically or in person. However, all reports are encouraged to be made in writing, so as to assure a clear understanding of the issues raised.
  3. Individuals are recommended to self-identify, though it is not a requirement of the policy.
  4. All reports should be sent directly to any of members of the Whistleblower Committee. Contact information of the Whistleblower Committee members are as follows:
    1. Chairman: U Htay Lwin | Executive Director Chairman’s Office (Mobile: +959 5122924, Email: htaylwin@htoogroup.com)
    2. Members: U Aung Htwe | Executive Director (Mobile: +959 43176226, Email: aunghtwe.ed@htoogroup.com), U Soe Naing | Executive Director (Mobile: +959 421005519, Email: soenaing@htoogroup.com), Daw Ei Mon Khine | Executive Director (Mobile: +959 5011388, Email: emk@htoogroup.com)
  5. In case of reports sent through e-mail, it is recommended to mark the subject as ‘HTOO Group Whistleblower’ for easy identification.
  6. Although the whistleblower is not expected to prove the truth of an allegation, he / she needs to demonstrate to the person contacted that there are sufficient grounds for concern.

PROCEDURES FOR AN INVESTIGATION

  1. The Whistleblower Committee member who receives a report will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days.
  2. The Committee Members shall meet to discuss about the action / investigation on the reports received from whistleblowers. The Committee may also exclude from its meetings any persons it deems appropriate, depending on the nature of the complaint.
  3. The Committee Members have the responsibility to conduct investigations. In addition, other parties may also be involved in the investigations. 
  4. The Committee Members will ensure investigations are carried out using appropriate channels, resources and expertise.
  5. Some concerns may be resolved by agreed action without the need for an investigation. Concerns about allegations which fall within the scope of specific procedures of HTOO Group will be referred for consideration under those procedures.
  6. The Committee Members will report to the Committee Chairman on a periodic basis about the reports received and actions taken.
  7. The Management reserves the right to make any decision based on the findings by the Committee.

OUR COMMITMENT

HTOO GROUP is committed to conducting business in an ethical and responsible manner. We respect and support international principles aimed at protecting and promoting human rights, as described in the United Nations’ Universal Declaration on Human Rights and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work. In our business operations, HTOO Group seeks to operate in compliance with all applicable laws wherever we do business.

While the government have the primary responsibility for protecting and upholding the human rights of their citizens, HTOO Group recognizes its responsibility to respect human rights in its operations. In addition, we recognize that we have an opportunity to promote human rights where we can make a positive contribution. This includes, among other things, opposing human trafficking and the exploitation of children.

COMPANY WORKPLACE POLICIES 

We strive to foster safe, inclusive and respectful workplaces wherever we do business. HTOO Group and its subsidiaries’ workplace policies and practices include commitments to non-discrimination and freedom from harassment, and require that the company refrain from knowingly entering into relationships that, directly or indirectly, expose cast members and employees to undue health and safety risks, or that use child, prison or forced labor, or other similarly exploitative practices. These policies are detailed in our Code of Conduct. Disney provides its Standards of Business Conduct to employees and periodically provides training to employees on topics covered within the Standards.

HUMAN RIGHTS WITHIN OUR REACH

We also strive to foster safe, inclusive and respectful workplaces wherever our business operations are. We expect the same commitment from business associates, partners, sub-contractors and vendors regards to labor standards and working conditions. The principles embodied in our Code are designed to be consistent with the ILO Declaration on Fundamental Principles and Rights at Work.

THE RIGHTS OF CHILDREN AND THE YOUNG 

The well-being of children is of the utmost importance to HTOO Group. We are committed to combating the exploitation of children and therefore prohibit any use of child labor in our business operations. Children’s safety is also of paramount importance to our group. The extensive safety and security management systems, programs and practices in areas of our operations include a range of elements designed to meet the specific needs of protecting children.

BRINGING THESE POLICIES TO LIFE

  • Our commitment to respect human rights is a core value of all businesses within The Group, and we take active steps to reflect that commitment in our everyday activities:
  • We report on our principles and performance in periodic reports to our Board of Directors and in our periodic Reports to shareholders and the public.
  • We expect and encourage employees throughout our business operations to make these principles and practices a part of their everyday work, and hold our employees accountable for adhering to our Standards of Business Conduct.
  • We train employees , monitor working conditions, and implement facility improvement plans when necessary.
  • Our Executive Management Committee group oversees our policies and practices in all of these areas, with support from Human Resources, Legal and other functions as needed.
  • We keep our policies and practices relating to human rights under continuous review, recognizing the need to stay vigilant in a rapidly changing and challenging world.

In support of all of these efforts, we place special value on our ongoing collaboration with a broad range of interested constituencies, including socially responsible investors, governmental, inter-governmental and non-governmental organizations; advocacy groups and concerned individuals. This broad engagement helps keep us sensitive to the potential impacts — positive and negative — of our products, services and operations on the rights, interests and well-being of our employees, guests, customers and communities around the country.

OBJECTIVES

HTOO GROUP and its subsidiaries  have implemented the policy on Land Acquisition in order to:

  • Promote greater awareness of proper land acquisition process in all of its operations;
  • Enhance its capabilities to identify and manage adverse impacts from all business activities; and
  • Respect landownership rights and avoid involuntary resettlement wherever possible

OUR COMMITMENT

Withe reference to International Finance Corporation’s (IFC) Performance Standards five, seven and eight, the Asian Development Bank’s (ADB) Safeguard policy and local land acquisition legislation, the Group is required to safeguard the proper land acquisition process by:

  • Making specific reference to this Land Acquisition Policy in the Group’s standards, policies, procedures;
  • Conducting land acquisition due diligence reviews of ongoing activities and new business opportunities to avoid adverse impacts to the communities in which we operate;
  • Advocating to avoid, minimise and reduce adverse resolution of disputes involving land use or ownership rights;
  • Avoiding and minimising involuntary resettlement by exploring alternatives;
  • ensuring livelihood restoration plans are in place with full disclosure of information, including monitoring and resettlement progress programmes.

IMPLEMENTATION OF THIS POLICY

  • Promoting land  acquisition  guidelines,  procedures  and  principles  of  Free,  Prior  and  Informed  Consent  (FPIC)
  • Monitoring, reporting and improving of applicable procedures and performances (where required) regularly; and
  • Disseminating Land Acquisition policy to all employees, contractors, suppliers and business partners.

This policy implies to all employees, contractors, suppliers and business partners.

HEALTH AND SAFETY OBLIGATIONS

HTOO Group’s Management is firmly committed to a policy enabling all work & business activities to be carried out safely, and with all possible measures taken to remove (or at least reduce) risks to the health, safety and welfare of employees, business associates, partners, sub-contractors and vendors, authorised visitors, and anyone else who may be affected by our operations.

HEALTH & SAFETY RESPONSIBILITIES

0 Management

Will provide and maintain as far as possible:

  • a safe working environment
  • safe systems of work
  • plant and substances in safe condition
  • facilities for the welfare of workers
  • information, instruction, training and supervision that is reasonably necessary to ensure that each employee is safe from injury and risks to health
  • a commitment to consult and co-operate with employees in all matters relating to health and safety in the workplace
  • a commitment to continually improve our performance through effective safety management.

0 Employees

Each employee has an obligation to:

  • comply with safe work practices, with the intent of avoiding injury to themselves and others and damage to facilities and equipment
  • take reasonable care of the health and safety of themselves and others
  • wear personal protective equipment and clothing where necessary
  • comply with any direction given by management for health and safety
  • not misuse or interfere with anything provided for health and safety
  • report all accidents and incidents on the job immediately, no matter how trivial
  • report all known or observed hazards to their supervisor or manager.

ENVIRONMENTAL POLICY

HTOO Group and its subsidiaries are committed to reducing the impact on the environment. We will strive to improve our environmental performance over time and to initiate additional projects and activities that will further reduce our impacts on the environment.

Our commitment to the environment extends to our customers, our staff, and the community in which we operate. We are committed to:

  •   Comply with all applicable environmental regulations;
  •   Prevent pollution whenever possible;
  •   Train all of our staff on our environmental program and empower them to contribute and participate;
  •   Communicate our environmental commitment and efforts to our customers, staff, and our community; and
  •   Continually improve over time by striving to measure our environmental impacts and by setting goals to reduce these impacts each year.

Furthermore, we undertake our social responsibilities more actively together with our CSR arm of the Group, HTOO Foundation.

APPLICATION OF THIS POLICY

We seek the co-operation of all employees, business associates, partners, sub-contractors and vendors, authorised visitors. We encourage suggestions for realising our health, safety and environmental objectives to create a safe working environment with a zero accident rate with minimal impact on the environment.

This policy applies to all business operations and functions, including those situations where workers are required to work off-site.