Human Rights

Human Rights Policy Statement

1. Our Foundational Commitment

Nustaf recognises and respects human rights as universal, indivisible, and interdependent. Our commitment is rooted in the fundamental responsibility of all business enterprises to respect human rights, as articulated in the UN Guiding Principles on Business and Human Rights (UNGPs).

We are committed to respecting internationally recognised human rights as set out in the International Bill of Human Rights (comprising the Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR), and the International Covenant on Economic, Social and Cultural Rights (ICESCR)).

This Policy is also guided by:

  • The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, covering the eight core conventions.
  • The OECD Guidelines for Multinational Enterprises, particularly the chapters on Human Rights and Employment and Industrial Relations.

Where national law differs from or falls below the level of internationally recognised human rights standards, we will seek ways to honour the international standards to the greatest extent possible while still complying with local law.

2. Scope and Applicability

This Policy applies to all of Nustaf’s employees, officers, and directors in all global locations. We further expect our business partners, suppliers, contractors, and joint venture partners to uphold these principles and to implement their own policies consistent with this commitment throughout their own operations and value chains.

3. Core Human Rights Commitments

We are committed to preventing, mitigating, and addressing adverse impacts related to the following specific human rights, among others:

A. Labour and Workplace Rights (ILO Standards)

We adhere to the ILO core conventions, specifically upholding:

  • Forced and Compulsory Labour: Prohibiting all forms of forced, bonded, compulsory, or trafficked labour, including the withholding of identity documents, charging recruitment fees, or imposing debt bondage.
  • Child Labour: Prohibiting the employment of children below the minimum legal age for employment in the country of operation or below the age of 15, whichever is higher, except as provided for by ILO exceptions.
  • Non-Discrimination: Ensuring equal opportunity and non-discrimination in all aspects of employment, including recruitment, compensation, training, promotion, and termination, based on factors such as race, colour, sex, religion, political opinion, national extraction, or social origin.
  • Safe and Healthy Working Environment: Providing a safe, clean, and healthy working environment for all employees.

B. Community, Land, and Security Rights

  • Community and Stakeholder Engagement: Engaging in meaningful consultation with affected stakeholders, particularly local communities and Indigenous Peoples, regarding potential impacts of our operations.
  • Land Rights: Respecting the land and resource rights of local communities and Indigenous Peoples, applying the principle of Free, Prior, and Informed Consent (FPIC) in specific, high-risk situations involving traditional territories.
  • Security and Privacy: Ensuring that our security arrangements are conducted in accordance with the rule of law and with respect for human rights, and upholding the rights to privacy and data protection for all individuals in line with relevant covenants.
4. Operationalizing Responsibility: Human Rights Due Diligence (UNGPs Pillar II)

To meet our corporate responsibility to respect human rights, we implement an ongoing process of Human Rights Due Diligence (HRDD) consistent with the UNGPs and the OECD Guidelines for Multinational Enterprises. This process includes:

  1. Assessing Actual and Potential Impacts: Systematically identifying and assessing actual and potential adverse human rights impacts that our operations, products, or services may cause, contribute to, or be directly linked to through our business relationships.
  2. Integrating and Acting: Integrating the findings of impact assessments into relevant internal functions (e.g., procurement, supply chain management, security) and taking appropriate action to prevent or mitigate potential negative impacts.
  3. Tracking Effectiveness: Tracking the effectiveness of our actions to ensure that adverse impacts are being addressed.
  4. Communication: Reporting and communicating how we address our human rights impacts to our stakeholders, particularly those potentially affected.
5. Grievance and Remediation Mechanisms (UNGPs Pillar III)

Nustaf is committed to providing access to effective remedies for individuals and communities who believe they have been adversely affected by our activities or those of our business partners where we have caused or contributed to the impact.

We maintain effective operational-level grievance mechanisms that are:

  • Legitimate: Engendering trust from the stakeholder groups for whose use they are intended.
  • Accessible: Known to all stakeholder groups, providing adequate assistance for those who may face barriers to access.
  • Predictable: Providing clear procedures and timelines for each stage.
  • Equitable: Ensuring that victims have access to information, advice, and expertise necessary to engage in a fair process.
  • Rights-compatible: Ensuring that outcomes and remedies accord with internationally recognised human rights.

We will cooperate in legitimate judicial and non-judicial remediation processes established by the state and will use our leverage to encourage our business partners to provide effective remediation where appropriate.

6. Policy Governance and Review

This Policy will be reviewed and updated quarterly to reflect changes in our business context, operating environments, and emerging best practices in line with international standards.