kt human rights policy · 2018-06-14 · kt human rights policy in order to minimize negative human...
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KTHuman Rights Policy
Table of ContentsKTHuman Rights Policy
1. Preamble
2. Objective
3. Policy
4. Definition of Human Rights
5. Glossary
Annex
A. Due Diligence Methodology
B. Partnership for Remediation
1.
KT Human Rights Policy
1. Preamble
“Whereas recognition of the inherent dignity and of the equal and inalienable rights of all members
of the human family is the foundation of freedom, justice and peace in the world.”
- Universal Declaration of Human Rights Preamble
Through the KT Human Rights Policy, KT Corp. (hereafter ‘KT’) aims to grow into a sustainable company while fulfilling its
social responsibilities and roles for protecting and promiting human rights, by preventing human rights violations through-
out its business and the value chain.
In every region it operates business, KT aims to fulfill and achieve the human right respect and protection responsibility
of the highest level. KT believes its commitments can not only contribute to the business but have a potential to improve
the work and living environment of employees and customers in the value chain, and further contribute to achieving a
sustainable world.
Under the approval of the Board of Directors in 2008, KT signed the UN Global Compact that is the ten principles including
human right protection. Through Communication On Progress (COP), KT proclaims its support for the Compact every year. KT
human rights policy has been written based on the Universal Declaration of Human Rights, ILO Conventions, UN Global Com-
pact, KT Code of Ethics Guideline, Green Procurement Guideline, Labour Standards Act and Occupational Health and Safety
(OHS) Act.
2. Objective
The purpose of this policy is to operate its business domestic and international under the strictly established human rights
principles as a global corporation, at the same time, actively implement human rights protection and promotion through
its business. Our human rights policy aims to achieve sustainable business success based on the customer and public trust.
2.
KT Human Rights Policy
Commitment
KT officially endorses and adheres to the following international human rights and labour standards, founded on
the The Universal Declaration of Human Rights and The International Labour Organization.
KT will conduct business activities without any breaches of the principles below, in any time and any place.
ㆍThe Universal Declaration of Human Rights (International Bill of Human Rights included)
ㆍILO’s Declaration on the Fundamental Principles and Rights at Work
ㆍILO Conventions
ㆍOECD Guidelines for Multinational Enterprises
ㆍUN Guiding Principles on Business and Human Rights
ㆍUK Modern Slavery Act
Scope
KT respects the dignity of others. It is required to comply with the above international standards regarding human
rights and labour within the entire value chain (upstream) such as employees, subsidiaries, suppliers, sub-con-
tractors and joint ventures. Furthermore, KT expects the similar level of compliance to the entire value chain
(downstream)that maintains business relationships with us, including all customers, partners, service distribution,
logistics.
Implementation
KT, as an UN Global Compact signatory company, established and implementing governance, operating structure,
monitoring, correction and internal/external reporting process in accordance to the procedures regulated by the
ten principles and UN Guiding Principles on Business and Human Rights.
Responsibility
The sustainability management committee in the Board of Directors, takes the overall responsibility with monitor-
ing KT’s human rights management activities, including human right policy.
3. Policy
3.
KT Human Rights Policy
4. Definition of Human Rights
In order to contribute in respecting and promoting human rights through the business, KT defines the
following human rights based on the subjects, scope, nature and business impacts of human rights.
Founded on the human rights definitions below, KT minimizes adverse human rights impacts by pro-
actively identifying issues that have potential to breach human rights within its own operations and
the entire value chain. In the meanwhile,KT strives to make contribution in maximizing positive human
rights impacts through its own business.
4.1 Basic Human Rights
KT fully support the human rights responsibilities stated in The Universal Declaration of Human Rights. KT defines
and commits to implement the basic human rights such as guarantees equality of individual, realization of freedom
and dignity of human., which are rights that every human being should be guaranteed.
4.1.1 Guarantee Equality · Prohibition of Discrimination
KT do not allow any type of discrimination based on gender, age, nationality, race, religion, education level
and disability.
4.1.2 Realization of Freedom · Prohibition of Forced Labour
We do not allow any form of forced labour and service.
4.1.3 Human Dignity · Prohibition of Child Labour
We do not employ any person below the age of 18 or applicable higer legal minimum age.
4.2 Labour Rights
KT fully support labour rights stated in ILO’s Declaration on the Fundamental Principles and Rights at Work and ILO
Conventions. KT ensures voluntary work and complies with all applicable laws and regulations regarding employ-
ment contract, employee rights, working condition, fair compensation and health & safety.
4.2.1 Freedom of Association · Right to Collective Bargaining
We ensure all employees are free to form and join unions for the protection of individual and collective in-
terests.
4.2.2 Fair Compensation · Compliance with Labour Standards
We ensure fair compensation and full compliance with relevant Labour Standards Act, regarding working
conditions such as working hour, wage etc.
4.2.3 Ensure Health & Safety
We ensure full compliance with all applicable laws regarding health and safety within its organization.
4.
KT Human Rights Policy
4.3 Promotion of Human Rights
KT believes that human rights policy of corporates shall act beyond the traditional way of protecting human
rights and take a big step towards promises and commitments to promote human rights. Based on the corporate
mission, KT accomplishes the world that every human being is freely enjoyable the innovative modern conveni-
ences and pursues happiness through ICT, while contributing in economic development, social advancement and
human life improvement.
4.3.1 Freedom of Expression
We promote the right of our customers to hold and freely share opinions, and to access the information.
Moreover, we strive to protect children from harmful content within the communication service.
4.3.2 Personal Information and Privacy Protection
KT respects customers’ privacy and strives to protect personal information stringently. Hence, minimize the
recording and storing of personal information, conduct technical/managerial protection action in order to
prevent information leakage and make the utmost effort to guarantee the rights of private entities.
4.3.3 Pursuit Happiness Through Innovation
Leading innovation and technology development through GIGA network and ICT services, KT will concentrate
our effort on promoting benefit and happiness of customers. We will focus on supporting customers for
innovative service experience and pursuit happiness regardless of their location, social class or disability.
5.
KT Human Rights Policy
5. Glossary
· UN Global Compact: UN affiliated specialized agency to encourage corporates to participate in bal-
anced sustainable development and to improve the international social ethics and international en-
vironment. With over 8,700 corporate participants and other stakeholders such as organization and
NGO etc., from over 130 countries. UN Global Compact is founded on The Ten Principles of human
rights, environment, labour and anti-corruption.
· COP(Communication On Progress): UN Global Compact Communication on Progress.
· The Universal Declaration of Human Rights: Declaration adopted by consensus by the 3th UN General
Assembly in December 1948, also known as UN human right declaration. After that, it founded other
international human rights treaties including International Covenants on Civil and Political Rights.
· ILO’s Declaration on the Fundamental Principles and Rights at Work: Declaration of labour rights,
adopted by the International Labour Conference in 1998. Established the following four fundamental
principles; freedom of association, elimination of all forms of forced or compulsory labour, abolition
of child labour and elimination of discrimination.
· ILO Conventions: Agreements adopted by the International Labor Organization defining detailed is-
sues related to labour rights. Major conventions related to human rights include the Equal Renumer-
ation Convention (No. 100, 1951), the Discrimination Elimination Convention (No. 111, 1958), the
Minimum Wage Convention (No. 131, 1970), the Minimum Age Convention (No. 138, 1976) and the
Occupational Safety and Health Convention (No. 155, 1981).
· OECD Guidelines for Multinational Enterprises: In 1976, OECD member countries and participant
countries have adopted the Code of Business Ethics standards required by multinational corporates
operating within the country. Suggest principles and standards in various field including human rights,
employment and union-management relations.
· Ruggie Framework: It is a framework that proposed in 2008, by the Special Representataive for Busi-
ness and Human, Professor John Ruggie. After 3 years, the framework became the foundation of the
“UN Guiding Principles on Business and Human Rights” adopted in 2011.
· UN Guiding Principles on Business and Human Rights: It is human rights principles that adopted by
the 17th UN Human Rights Council, in June 2011. The guide line provides preemptive approaches
to protect human rights and prvention of human rights violations in business aspect, thus, providng
practical framwork for company due diligence.
· UK Modern Slavery Act: It is a human rights legislation, passed by the British government in October
2015. It became mendatory to conduct due diligence regarding the labour/human rights and report
to the government for those company with annual gross worldwide revenues of KRW 50 billion or
more each year. It significantly affects to the law system in Europe/North America .
6.
KT Human Rights Policy
In order to minimize negative human rights impacts, KT proactively identifies the potential issues re-
garding human rights breaches within its business operations or the entire value chain. Hence, we have
established and implemented an organization, operation structure, monitoring, correction and internal/
external reporting process in accordance with the human rights due diligence process defined by the
UN Guiding Principles on Business and Human Rights.
A.1 Human Rights Due Diligence Principles
Principle of due diligence of KT is founded by the three core principles of Ruggie Freamewok; ‘Protect’, ‘Respect’
and ‘Remedy’. The framework is introduced by Professor John Ruggie, the UN Special Representative for Business
and Human Rights, and this also founded the UN Guiding Principles on Business and Human Rights adopted by the
17th UN Human Rights Council in 2011.
In order to comply with the principles of due diligence, KT strives to respect human rights, prevent human rights
breaches and actively eliminate factors that adversely impact on human rights.
A.2 Human Rights Due Diligence Methodology
Based on the UN Guiding Principles on Business and Human Rights, KT has developed and operated a due diligence
process that excavates potential human right issues, defines vulnerable groups in the aspect of human rights, and
executing mitigation measures and monitoring.
A.2.1 Human Rights Risk Exposure Assessment
In 2013, for accurate human right risk analysis, KT developed “KT Human Rights Assessment Framework” aimed for
quantitative identification of human right exposures of UN Guiding Principles on Business and Human Rights. As
defined in ‘the Ruggie Report’, the framework allows us to analysis corporate human right activities into 3 areas as
followings:
1) Policy Commitment
a. Human right policy: Corporate human right policy, Human right management
b. Awareness & training: Training on human rights, Supply chain policy
2) Operational Requirements
a. Supply chain: Procurement from high-risk countries, Procurement from violent conflict countries
b. Business: Sales operations on high-risk countries, Active operations on violent conflict countries
c. Service: Business associated with human rights problem, providing services to high-risk countries,
providing services that could affect human rights, Association with human rights violation cases
3) Remediation
a. Reporting: Violation reporting channel at HQ, Violation reporting channel at sites, Multilingual reporting
b. Organization: Responsibility on human right monitoring
c. Investigation: Investigation processes & procedures
Annex A. Due Diligence Methodology
7.
KT Human Rights Policy
Based on the framework above, KT conducts regular human rights exposure analysis in order to iden-
tify potential human rights risks within its business operation and supply chain. Moreover, the analysis
results are disclosed through the integrated report every year.
[In 2018]
The quantitative business areas and data for regular human rights exposure evaluations are following:.
ㆍAnnual revenue by countries (FY2017) ㆍAnnual product procurement per suppliers (FY2017)
ㆍAnnual revenue by projects (FY2017) ㆍAnnual service procurement per suppliers (FY2017)
A.2.2 Supplier ESG Risk Assessment
KT promises to do the best to proliferate the significance and culture of respecting human rights to main stake-
holders under KT’s influence such as subsidiaries and strategic partners. Therefore, KT established the KT Sustain-
ability Guideline for Suppliers based on international human right policies and standards including UN Guiding
Principles on Business and Human Rights; the annual supplier ESG risk assessment is conducted for encouraging
the execution of the Guideline. As defiend in the supplier ESG risk assessment, the framework allows us to anal-
ysis into 4 areas as followings:
1) Management principles
a. Corporate governance, b. Ethical management, c. Sustainable management,
d. Sub-contractor management
2) Environmental management
a. Environmental management systems, b. Environmental performance evaluation,
c. Climate change, d. Toxic substance management, e. Water f. Waste & recycling
3) Corporate social responsibility and role
a. Labour, b. Human rights, c. Safety management, d. Voluntary disclosure & External communication
4) Product sustainability
a. Product safety, b. Product footprint, c. Product efficiency, d. Product recycling
Based on the framework above, KT conducts regular human rights analysis within the supply chain in
order to identify potential human rights risks within its supply chain. Moreover, the analysis results
are disclosed through the integrated report every year.
· Conduct annual supply chain risk assessment: Annual sustainable management assessment carried out for sup-
pliers. This evaluation includes major human rights issues such as labour, human rights, health & safety index.
· Apply to supplier selection process: In order to improve the status of human rights in the supply chain, the as-
sessment results influence significant impacts on the annual evaluation in suppliers re-contract or nominating
best suppliers.
[In 2018]
In FY2017, Carried out supplier ESG assessment for all suppliers.
- Product suppliers total 133 companies (100%)
- Information communication suppliers total 267 companies (100%)
8.
KT Human Rights Policy
A.2.3 Business Risk Assessment
Potential human rights risks may arise in a case of entering into new market or overseas due to economic, social
or cultural differences. This, furthermore, may bring adverse impacts to the corporate; such as delay or cancella-
tion of business, complaints from the local communities, cancellation of business licenses or difficult in acquiring
the business license. Therefore, for a successful business operation, risks are to be identified in advance to the
business through <Business Check List>, KT developed. The <Business Check List> includes the following indica-
tors to identify and act against human rights risks.
1) Customer analysis: consider cultural characteristics
2) Stakeholder analysis: analyze suppliers and consortium
3) Contract: confirmation of dispute adjustment method and existence of Foreign Corrupt Practices Act
4) Law: Conduct legal review
5) Business structure: order contract, review sub-contract, review payment calculation method and
review sub-contract act.
6) Supplier: sub-contract structure, supplier selection and renewals.
7) Task: conduct due diligences.
[In 2018]
In FY2017, the scope of business risk evaluation using the Business Check List is following:
- Risk assessment rate of overseas projects: 100% (FY2017)
A.2.4 Prior Risk Review before Launching Service and Product
In order to proactively prevent risks arising from products or services produced by KT, we setup a
<Prior Risk Review Conference> in 2014. Thus, all products and services are conducted pre-launch
risk assessment through the conference. The professional departments participate in the <Prior Risk
Review Conference> and evaluate the following four risks and determine whether it is possible to
release. The release will be postponed if the problematic issues are unresolved:
1) Conduct legal review
2) Fair competition
3) Information security
4) Other risks: Environmental risks and Human rights risks are included
[In 2018]
In FY2017, the scope of risk assessments on products and services by the <Prior Risk Review Conference>
is following:
- 100% of products and services scheduled for launch in 2017
9.
KT Human Rights Policy
A.2.5 Personal Information Protection Measure
Privacy protection is considered one of five core risks that can threaten company operations and is
thoroughly controlled under the company’s risk management system, thus, protecting personal in-
formation acquired during the business activities and prevent possible human rights violations. Fur-
thermore, in 2013, KT was certified by the ISMS(Information Security Management System) program
that is officially recognized by the Korean government; the re-verification is being conducted every
year enabling the management system of customer information protection based on the national
standards. Moreover, we will intensify our technical/administrative protection for customer informa-
tion through regular security status inspection for systems and suppliers, which hold the customer
information.
1) Technical protection method
Integrated Control System to monitor suspicious behavior that seems to be hackers’ attack
Enhancement of the approval and authentication process of the Access Control System
Establishment of Firewall/Invasion Detection System/Access Control System
Encryption of privacy
DRM (Digital Right Management), DLP (Data Loss Prevention) Solutions
Further application of DB Access Control System and enhancement of privacy control
Response to APT attacks
2) Administrative protection method
Secure Coding required in the software development
Compliance with security review process before launching a service
Destruction of social security number gathered
Regular inspection and improvement of loopholes
Simulation tests for infringement accidents with relevant organizations such as the government
Information destruction of customers not using KT’s service for more than 1 year
Destruction of personal information on PC
[In 2018]
In FY2017, following privacy protection activities were carried out:
· Personal information protection online training for employees: 100% - 22,981 (first-half) / 23,170 (second-half)
· Personal information protection online training within the supply chain
· Simulation hacker to the website by the “White Hacker”
10.
KT Human Rights Policy
In order to minimize negative human rights impacts while maximizing positive human rights impacts
throughout the value chain, it is necessary for suppliers, sub-contractors and business partners to
cooperate with KT based on mutual trust.
KT will actively apply the best practices and share knowledge across the entire value chain, aimed for
human rights protection and promotion.
B.1 Standards
KT is committed to
· applying the highest standards on human rights to its own operations. Thus we will cooperate with suppliers
to comply with prohibition on forced labour, child labour and discrimination.
· applying the highest standards on labour rights to its own operations. Thus we will cooperate with suppliers
to comply with employment contract, employee rights, working conditions and fair compensation etc.
· applying the highest standards on safety management. Thus we will cooperate with suppliers to comply with
applicable laws and regulations regarding safety on employees and its operations.
KT’s suppliers are expected to
· comply with human rights standards such as prohibition on forced labour, child labour and discrimination.
· comply with laws and regulations related to the employment contract, employee rights, working conditions
and fair compensation.
· comply with applicable laws and regulations regarding safety of employees and its operations
· be removed from the business relationship with KT, in a case of serve breach of human rights, labour rights,
safety management standards or unfair employments.
B.2 Co-operation
KT is committed to
· working in collaboration with suppliers in the pursuit of implementation of, and compliance with, principles
of human rights respect.
· welcoming and rewarding rather than penalizing if suppliers voluntarily identify areas where human rights
systems are not yet in compliance with best practices.
KT suppliers are expected to
· collaborate with KT (or its representatives) on the above standards.
Annex B. Partnership for Remediation
11.
KT Human Rights Policy
B.3 Evaluation & Monitoring
KT is committed to
· providing a fair human rights risk evaluation based on systematic criteria
· continuously improving its own methodologies based on learning experiences and supplier feedback.
· considering supplier’s own human rights standards or systems than do not exactly match the best practices
contained in this policy as a reasonable alternative where suppliers are already working towards this alter-
native.
KT suppliers are expected to
· provide information regarding their sustainability activities – such as human rights, labour rights and safety
management - through the supplier sustainability evaluation questionnaire.
· provide adequate access to relevant staff and facilities within their organisations if required.
· provide its employees covered by human rights standards with a confidential means to report the supplier
failure to observe the human rights standards contained in this document.
B.4 Information Sharing
KT is committed to
· sharing knowledge to improve supplier performance on human rights respect and protection.
KT suppliers are expected to
· provide information regarding human rights, labour rights and safety issues through the supplier sustainability
evaluation questionnaire.
· provide adequate access to relevant staff within their organisations if required.
· share best practices in respecting and protecting human rights and relevant experiences from their own opera-
tions.
B.5 Raise Awareness
KT is committed to
· raising internal awareness regarding human rights respect and protection, and providing relevant background
training to staff in the procurement divisions.
· providing training and other background materials for human rights respect and protection to suppliers and
business partners.
KT suppliers are expected to
· raise internal awareness regarding human rights respect and protection, and provide adequate training to
relevant staff.
12.
KT Human Rights Policy
B.6 Continuous Improvements
KT is committed to
· continuously improving internal human rights standards and the supplier human rights standards based on new
trends and learning experiences.
· applying a continuous improvement approach in agreeing schedules for improvement plans with suppliers not
currently meeting the standards contained in this policy.
· establishing base improvement plans on individual case circumstances.
KT suppliers are expected to
· commit to internal improvements relating to respect for human rights, protect human rights, and other issues
contained in this policy.
· define and implement internal improvement plans based on these best practice standards and feed-
back from KT.
· Adhere to agreed plans and time-frames.
B.7 Commitment
KT is committed to
· making a positive difference for itself, our value chain and the wider society through pursuing respect for basic
human rights, labour rights protection and human rights promotion based on company competencies.
KT suppliers are expected to
· Encouraged to pursue the same goal.
[CONTACT]
KT is operating 24 hours hotline system in order to create business climate to respect and promote hu-
man rights. In a case of report regarding any breaches of human rights against our human rights policy
and principles within our value chain, we will actively take action and the identity of the reporters will
be protected. As a responsible global corporate, KT will take the lead in fulfilling its social responsibili-
ties, and to respect and promote human rights.
Website
Address
Tel
Fax
https://corp.kt.com/html/sustain/transparent/ethics_03.html
KT Sustainability Management Unit, 178 Sejong-daero,
Jongno-gu, Seoul, Korea, 03154
080-713-6262
02-3495-4027
sustainability@kt.com
ethics@kt.com
Thank you
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