Human rights

Renewable energy projects may trigger environmental and social impacts. We endeavour to minimise our negative impacts, maximise local benefits and ensure constructive dialogue with all project stakeholders. In all our work, we pay special attention to the human rights we are at risk of impacting and to the most vulnerable groups.

Management approach

Policy and governance
Our human rights policy is aligned with the United Nations (UN) Guiding Principles on Business and Human Rights to prevent, address, and remedy human rights abuses committed in business operations. The policy confirms that Scatec’s responsibility to respect human rights applies to our business enterprises wherever we operate and pay special attention to the human rights risks of certain groups, such as indigenous people, minorities, women, children, migrant workers and other vulnerable groups.

In addition, Scatec’s Code of Conduct sets out the essential requirements for ethical business conduct within our company, which applies to all employees, hired consultants and directors, including our subsidiaries, joint ventures and affiliates. In addition, we do not enter any contractual relationship with a third party without appropriate integrity due diligence.

Due diligence
We follow standardised processes in all our projects to identify, mitigate and monitor our environmental and social (E&S) risks and impacts including human rights under the IFC Performance Standards (PS) framework. We conduct human rights due diligence as part of our overall E&S due diligence process. Project risk registers, Environmental and Social Impact Assessments (ESIA), Environmental and Social Due Diligences (ESDD), Environmental and Social Action Plans (ESAP), Environmental and Social Management Plans (ESMP) contain human rights aspects. When initial assessments point to potential human rights risks, focused Human Rights due diligence assessments are conducted to gather deeper understanding of the risks the development of project can trigger and mitigation measures.

Salient human rights risks
Scatec engaged a third party to conduct a gap analysis of our alignment to the Transparency Act, related to human rights due diligence, external reporting on human rights as well as responding to requests for information from the public. Key findings include:

Human rights impacts and risks are continuously assessed and managed in Scatec’s project development and supplier management
Assessments should be more specific and management of risks more systematic within the organisation
Reporting on human right risks is found in annual and quarterly ESG reports, with an adequate level of detail
Further comprehensive reporting on significant risks and impacts should be published and signed by the Board in June 2023
Information should be gathered and requests responded to within set deadlines (when such requests are posed to Scatec)

In Q4 2022, an in-dept saliency assessment was undertaken where human rights risks, across 25 specific operational and value chain areas, were identified and categorised according to severity and likelihood. Refer to the below summary:

Indigenous peoples’ rights
Displacement / Loss of livelihood
Forced, compulsory and child labour
High-risk raw materials
Access to water
Right to a healthy environment
Protection of human rights defenders
Abuse of force – security
Health and safety
Freedom of association and collective bargaining

Access to remedy
Scatec has both a whistleblowing channel and grievance mechanism in place in line with the IFC PS and UN Guiding Principles on Business and Human Rights.

The whistleblower function is available to all employees, suppliers, partners and customers of the company through internal channels and our corporate website. The function is operated by an independent third party and available in eight languages. All whistleblowers have the option to be anonymous.

Our grievance mechanism is targeted towards individuals, communities and companies who have feedback or concerns regarding our projects. It is a channel to present issues to the administration of the projects and is directly supervised by our global sustainability unit. Each grievance is logged in our system, allocated to the responsible person and systematically processed according to our grievance procedures. We aim to have a response time and initiate action to resolve the grievance in a maximum of 15 working days. The mechanism is available at each local project site and in five different languages on our website: English, Arabic, Spanish, Portuguese and Ukrainian. The mechanism provides a valuable platform for engaging with communities.

We report on the number of grievances received and resolved, as well as whistleblowing reports received and outcomes after investigations aligned to our internal processes. Refer our Ethics and compliance and Local value creation reporting on our corporate website for more information.

Although there are no specific cases relating to human rights in 2022 to date, summaries of the resettlement processes we carried out in line with the IFC Performance Standards in 2022, are presented here.

Labour compliance in accordance with IFC Performance Standards and key International Labour Organisation (ILO) conventions is a contractual requirement for all engineering, procurement and construction (EPC) contractors.

GRI disclosures

GRI 410-1

GRI 410-1: Security personnel trained in human rights policies or procedures

Scatec’s human rights training programme for security personnel was launched in 2020. All Scatec facilitators were trained by a third party with international best practice human rights experience to be able to present this training to the security guards at their respective locations. The training is provided to third party security service providers and staff based on Scatec’s project sites. In 2022, all new security service providers were trained in addition to 55% of security guards who we trained in 2021 in all projects where Scatec has operational control.

In addition, the interactive corporate training for all employees provides background to human rights and focuses on business and human rights and the specific role human rights play within Scatec and its operations.

Resettlement processes in line with the IFC Performance Standards in 2022

Sukkur project (150 MW) under construction, Pakistan

Scatec completed the physical resettlement process in Pakistan of 81 households, other structures and cultivated land.

During the year, we completed the physical resettlement process 81 households, other structures and cultivated land
Affected households comprised members of different tribes and detailed consultations were held
Approvals for plans were given by each tribe, at household level and from female household members
Tailored resettlement approaches and action plans were thereafter developed and implemented for each household
The completion of resettlement process was in full alignment with the principle of informed consultation and participation
The achievement of Broad Community Support per IFC’s Sustainability Policy¹⁾ was verified by third party experts engaged by the project financiers early 2023
A Gender Action Plan (GAP) was developed for the project in partnership with UN Women
The GAP addresses gender aspects of project’s construction and operation activities in a comprehensive and coherent manner and present management measures, including a wide range of initiatives:
- equal ownership rights to replacement land of men and women
- special allowances to women head of households for income generation activities
- training programs for Scatec and contractor employees to address gender-based violence and harassment

¹⁾ The policy states the projects with potentially significant, adverse impacts must have “broad community support” in order to receive IFC financing.

Mendubim project (531 MW) under construction, Brazil

Scatec completed the resettlement actions of 2 households.

Resettlement actions covered 2 households and assistance was provided according to the needs of each Affected Household to improve or restore their livelihood
A detailed socio-economic diagnosis of each household was made identifying their current livelihood, relationship with the respective land as well as their aspirations and interests
Household 1
- The family had no relation with agricultural activities and their interests were focused on job and study opportunities available in the city of Assu
- Alternative housing options were presented in Q1 2022 and was secured in Q3 2022 based on the decision made by the family with immediate move-in.
- The family leader is currently working on the Scatec Mendubim project as technical staff member of the electromechanical subcontractor.
Household 2
- The socio-economic diagnosis identified a strong relationship with the land and farming activities
- The process required an extensive search for a house and land that would allowing the family to maintain their livelihood
- Options were presented in Q1 2022 of which a 30 ha plot of land, including a full house renovation, was provided prior to occupation in Q4 2022

Methodology

Scatec reports on the percentage of operations with environmental and social (E&S) assessments including human rights, as well as the percentage of security guards trained in all projects where we have operational control. All ESIA / ESDD / E&S baseline studies performed include a review of environmental and social risks that are linked to human rights, within the following areas: socio-economic, land acquisition or restriction on land use, stakeholder engagement, grievance mechanism, labour force, third party contractors, health and safety, emergency preparedness, supply chain, security, indigenous people and cultural heritage. Key definitions used in our reporting:

E&S impact assessments: Environmental and Social Impact Assessments (ESIAs), due diligence or baseline studies to identify potential environmental and social risks and impacts of our activities (in accordance with the IFC Performance Standards and Equator Principles).

Security guards: Personnel of companies appointed by Scatec to provide security services to the project site.