kt human rights policy · 2018-06-14 · kt human rights policy in order to minimize negative human...

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.


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.


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.


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.


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.


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.


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.


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.


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.


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.


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.


· 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.


· 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.


· raise internal awareness regarding human rights respect and protection, and provide adequate training to

relevant staff.

12.


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.


· 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.


· 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

[email protected]

[email protected]

E-mail

Thank you

kt human rights policy · 2018-06-14 · kt human rights policy in order to minimize negative human...

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