Human Rights_EN.pdf

The purpose of the Human Rights Due Diligence model is to ensure that our actions are aligned with our principles and values, which is why we have established a process to proactively identify and evaluate potential vulnerabilities, impacts, and risks related to respect for Human Rights.

Components of the Human Rights Due Diligence Model of TGI S.A. ESP.

For more information on the scope of the Human Rights Due Diligence Model, please click on the following link

Evaluating social risks and impacts is one of the most relevant activities of the Human Rights due diligence process in TGI. In 2021, TGI started the evaluation of risks and impacts, reaching 100% of the areas of direct influence of its Operational Centers, including the Gas Compressor Stations.

The evaluation has the purpose of favoring the adequate management of risks and impacts in TGI's operation, in the follow-up of business practices, in the evaluation of its results, and even in the closing of some projects developed with its stakeholders. In this sense, the main purpose of the risk evaluation is to ensure effective management of the impacts that may be adverse to people and communities, according to their nature and magnitude, and following the hierarchy of risk mitigation in human rights established by TGI.

Due Diligence Risk Model applied.

Objectives of the risk and impact evaluation:

• Identify risks and possible adverse impacts that may be generated in TGI's operation areas.
• Identify adverse impacts that alter good management practices and prevent the proper development of operations.

For the analysis, it was important to estimate whether the impacts are:

• Direct: caused by TGI's operation and arise contemporaneously at the site;
• Indirect: they arise later or at a greater distance than the direct impact,
• Cumulative: an addition to the impacts of other past, present, and reasonably foreseeable events, as well as unplanned but predictable activities in operation and could occur later or in a different location.

The evaluation of risks and impacts on Human Rights was carried out in 100% of the Operation Centers (8 operating infrastructures) and Gas Compressor Stations (16 operating infrastructures) under two methodologies, the first with on-site visits complemented with virtual meetings as shown in the following table:

List of Intervention Zones in the Risk Evaluation:

This intervention covered internal and external stakeholders who are directly or indirectly related to TGI SA ESP; where it is important to highlight:

1. Contractors and Subcontractors: correspond to the group of contractors that perform activities for the organization or through contractors that are routed from a central level.
2. Local government: initially represented by the first local authority (mayor) but with a strategic "thermometer" such as the Personero, due to his role as interlocutor between the company, the community, and other related stakeholders.
3. Community Area of Direct Influence: the community of the area of direct influence corresponding to communities and owners that are close to the Right of Way, the operational center, or the gas compressor station.

During the risk and impact assessment process, it was identified that TGI has not caused or contributed to any violation of Human Rights in its operations. 

RESULTS VULNERABILITIES.

A total of 107 violations were consolidated, grouped into eight (8) risks

Characterization and Grouping.

The negative vulnerabilities identified were grouped under the risk parameters in the triple bottom line by the impact they may represent in the economic, social, and environmental spheres and their corresponding convergences.

The vulnerabilities were consolidated into eight (8) major risks that, contrary to what is commonly found, are related. The following table shows how the risk is contextualized in the sector and how it directly affects TGI.

Risks and Strategic Objectives

After an exercise against each risk, an element was structured that, together with the actions, allows the organization to face it correctly.

Human Rights Risk Matrix

TGI has been working on 4 fronts:

1. Strategic elements in Human Rights
2. Matrix analysis of impacts and mitigation measures
3. Annual Human Rights Action Plans
4. Remediation mechanisms

Strategic Elements in Human Rights

There are three (3) elements that must be transversal to the execution of the actions to achieve the suggested strategic objectives. These elements are framed in the global principles of Human Rights through its various declarations and the associated institutional framework

4. Transversal Actions to Strategic Objectives.

According to the Guiding Principles Interpretation Guide, human rights risks are defined as "the potential adverse human rights impacts of the company's activities. Potential impacts should be responded to with prevention or mitigation measures, while actual impacts - those that have already occurred - should be remedied (Principle 22)".

In the case of Potential Impacts, TGI has established an analysis matrix of potential impacts and for each activity, the management and mitigation measures are established in 24 mitigation plans which are listed in the attached matrix Link.

1. Human Rights Action Plan

The action plan aims to strengthen human rights management by following best practice benchmarks and managing identified human rights risks. The proposed activities, the areas involved, and the proposed times for their execution are presented in detail in the following

Plan de acción en DDHH.pdf

Overall Objective

Contribute to the positioning, genuine relationship, and preservation of TGI's reputation through the adoption of best practices of Human Rights management following international standards on the subject and its traceability to its internal and external stakeholders, with a double perspective aligned with the objectives and strategy of Sustainable Development: (i) The consolidation of human rights due diligence for preventive management and control of human rights risks associated with the activities of the Company and its value chain. (ii) Adding value by contributing to the conditions for fulfilling human rights in the operating environments.

Following the results of the risk evaluation, TGI established strategic objectives to address and minimize the identified vulnerabilities:

Remediation Mechanisms

As part of the duty of protection, due diligence, and prevention against possible human rights violations within the framework of the business activity, the company seeks to take appropriate measures to manage and guarantee effective and efficient mechanisms and measures of reparation in terms of prevention and attention to human rights.

Our progress and best practices in Human Rights must be extended to our relations with the Supply Chain, ensuring the coherence of actions in the relationship between our suppliers' and contractors' collaborators, as well as between them and the communities.

To this end, we have carried out the following activities:

1. In-depth workshop on Human Rights certified by Pacto Global for the Supply Chain of TGI's critical suppliers.

20 employees from 10 TGI's supplier companies received a training workshop on human rights:

The companies that attained the training are: ​​

Application of a diagnostic tool for evaluating human rights performance and ESG criteria for suppliers and contractors.

The tool corresponds to a self-evaluation of 64 questions covering the four (4) aspects evaluated by the Pacto Global principles.

Agreement with Universidad Externado de Colombia for the First Steps in Corporate Social Responsibility for the Supply Chain Program.

TGI, in alliance with Universidad Externado de Colombia and Pacto Global Red Colombia, started the First Steps in Corporate Social Responsibility Program, whose purpose is to work with the Supply Chain to incorporate and strengthen ESG criteria in suppliers and contractors.

The program consists of a free consultancy to suppliers to identify the current situation of the company concerning ESG criteria and environmental conditions and to propose actions that contribute to improving and strengthening the company's sustainability criteria.

The main aspects worked on under the program are:

1. Economic impact
2. Environment
3. Labor practices
4. HUMAN RIGHTS
5. Community
6. Transparency
7. Goods and services

The program is already underway, and although there are limited spaces for companies to enroll, we got one of our suppliers to join and start the program this year.  The company that is already receiving the consultancy is PREMAC S.A.

Human Rights Compliance Clauses in TGI Contracts

GUIDING PRINCIPLES ON BUSINESS AND HUMAN RIGHTS - UNGPs

Principle 13. The responsibility to respect human rights requires that companies: (...9 b) Seek to prevent or mitigate adverse human rights impacts directly related to operations, products, or services provided by their business relationships, even when they have not contributed to generating them.

Therefore, one of the opportunities identified to work on this aspect focuses on contractual requirements, which in the case of contracting processes, the following compliance clauses were included in the acts of all contracts.

• THE CONTRACTOR acknowledges, accepts, and guarantees that it has read and understood the Sustainability Policy and the Human Rights Policy of THE COMPANY, which are an integral part of the Contract and may be consulted at the website:www.tgi.com.co at the link https://www.tgi.com.co/tgi/nosotros/gobierno-corporativo/politicas. Consequently, THE CONTRACTOR adheres to and agrees to comply with the aforementioned policies. 
• THE CONTRACTOR undertakes to conduct itself and ensure that its employees, representatives, and agents conduct themselves, during and in connection with the performance of the Contract under the provisions of the Sustainability Policy and the Human Rights Policy of THE COMPANY".
• The CONTRACTOR guarantees that, in the development of all activities carried out within the framework of the business relationship with the company, it designs and implements actions aimed at preventing and mitigating the risks and impacts (actual and potential) on human rights associated with its operation and thus comply with its duty to respect them.​​​​​​
• Human Rights Risk Criteria in the Contracting Risk Matrix

Risk management must be carried out throughout the entire contracting process, i.e., from the planning or preliminary stages, during its execution, and until the expiration of the contractual guarantees, as appropriate. Always taking into account the inherent risks of the organization, especially those that could arise in terms of sustainability and/or Human Rights. For this reason, our contractual risk matrix covers the following type of risk:

Risks Inherent to Human Rights Violations

It refers to the risks identified and evaluated by the organization in Human Rights and the establishment of due diligence to mitigate them.  These risks may be associated with other risks described below. Therefore, they should be complemented or may be associated with the supply chain processes and should also be reviewed when evaluating contracting risks. Some of them may be related to labor practices for hiring personnel in the territories, compliance with the legal minimums in hiring, generation of an open and transparent dialogue with the community, local government, and other stakeholders in the territory, adequate use of natural resources and the environment, as well as attention to impacts and measures to mitigate them, acting within organizational policies of sustainability, human rights, codes of good governance, or corporate principles.

Annexe 7.Claim Mechanisms (Attention PQRS) + SCV.pdf

Training in Human Rights.pdf

TGI - DUE DILIGENCE HUMAN RIGHTS MODEL.pdf