Human Rights Policy

June 2023 Human Rights Policy

A. Policy Objective The Company, hereinafter referred to as the “Company,” is deeply committed to upholding and advancing human rights within the scope of its global business operations. This policy is designed to reinforce the obligation to respect human rights across all aspects of our operations, foster enhanced trust with external stakeholders, and exemplify internationally recognized sound business practices. We firmly uphold that safeguarding and promoting human rights represents not only a best practice in global business but also a fundamental tenet of business sustainability. This Human Rights Policy is rooted in the principles outlined in the Company’s Code of Ethics and Business Conduct, guided by universally accepted standards as outlined in Section G.

B. Applicability The directives within this Policy extend to the Company, its subsidiaries, affiliates, joint ventures, and any other entities, whether directly or indirectly controlled or managed by the Company. This includes employees and directors of these entities, as long as their activities relate to the Company’s operations. The Company expects suppliers and partners to adhere to business principles that align with our own.
C. Guiding Principles

• Non-Discrimination The Company is unwavering in its commitment to upholding human rights. Trust, respect, and ethical business practices constitute the bedrock of positive relationships among our employees. At the core of these relationships is the recognition of each employee’s individual worth and contribution. Diversity among our employees is a source of strength, and every employee is treated with the utmost respect and rights. Our commitment to equal opportunity is unwavering, and we categorically denounce any form of discrimination, harassment, unjust treatment, or reprisal.

In compliance with applicable laws, employees and job applicants shall be evaluated based on performance and qualifications without regard to factors such as race, creed, gender, religion, national origin, age, disability, veteran status, or sexual orientation. Equitable compensation shall be determined solely based on performance and qualifications, free from the influence of race, creed, gender, religion, national origin, age, disability, veteran status, or sexual orientation

Particular attention is given to individuals or groups at heightened risk of human rights violations due to vulnerability or marginalization, including but not limited to women, ethnic and religious minorities, children, LGBT+ individuals, persons with disabilities, and migrant workers and their families.

• Elimination of Forced Labor, Child Labor, and Human Trafficking The Company vehemently opposes all forms of harmful child labor, forced labor, or compulsory labor, including prison labor, indentured labor, bonded labor, military labor, and modern slavery. It is the Company’s unequivocal policy to prohibit harmful child labor and the use of forced or compulsory labor across all Company workplaces.
• Freedom of Association and Collective Bargaining The Company respects employees’ right to join, establish, or abstain from labor unions without the fear of retaliation, intimidation, or harassment. When employees are represented by a legally recognized union or works council, the Company is committed to fostering constructive dialogues with duly appointed representatives. Collaborative efforts with the workforce are pursued to reach mutually beneficial agreements, both in everyday interactions and during collective bargaining labor contract negotiations.
• Health and Safety Safeguarding a safe and healthy work environment is an integral component of the Company’s operational ethos. Accidents not only harm employees but also undermine operational efficiency and erode community trust. The Company assumes responsibility for accident prevention by promoting a proactive safety culture, adhering to safe procedures, and utilizing prescribed personal protective equipment.
• Working Conditions and Hours The Company upholds a commitment to equitable and honest treatment of all employees, irrespective of their work location. Adequate rest breaks, access to restrooms, appropriate rest and changing facilities, and potable water must be available at all workplaces. Furthermore, employees are entitled to personal and holiday leave in accordance with jurisdictional legislation.
• Fair Wages and Compensation The Company commits to providing wages that either meet or exceed legally required wage standards, or, in the absence of such laws, align with prevailing local industry norms. Compensation for work performed is a fundamental right of every worker.
• Migrant Workers The Company sets forth expectations that all workers, including migrant workers, receive just wages, benefits, and working conditions in compliance with local laws. The Company unequivocally opposes practices such as withholding passports, charging fees for employment, or any other unfair treatment.
• Prevention of Harsh or Inhuman Treatment and Harassment The Company guarantees employees’ rights to be treated with respect and dignity in line with a work environment devoid of harassment, be it sexual, physical, verbal, or psychological. The Company categorically rejects the use of indentured, slave, bonded, or any other form of involuntary labor. Corporal punishment is strictly prohibited. Harassment encompasses any offensive act, comment, or display that causes humiliation, insults, embarrassment, intimidation, or threat.

D. Training and Reporting

• Training and Communication The Company commits to regularly train its employees on human rights matters. New employees undergo training on the foundational principles outlined in the Code of Ethics, serving as the basis for this policy. Ongoing recertification is provided to all employees. The Company tailors human rights training content based on diverse roles, functions, and business partnerships. Aiming for comprehensive integration, the Company incorporates human rights management throughout its operations and business affiliations.

The Company reinforces human rights considerations within due diligence processes, policies, internal systems, and training. It is our resolve to mitigate human rights risks through these proactive measures.

Pursuant to the Global Reporting Initiative, significant developments related to human rights initiatives are reported in the Company’s annual Sustainability Report.

• Reporting This Human Rights Policy aligns with the Company’s Code of Ethics and Business Conduct, which includes provisions for employees to report potential internal violations. The Company maintains an Ethics Response Line, designated for reporting suspected breaches of the Code of Ethics and Business Conduct or any other Company policy. The Ethics Response Line and other reporting mechanisms detailed in Section 4 of the Code of Ethics and Business Conduct may be employed to express concerns.

Prompt and thorough investigations are undertaken for all allegations of misconduct, with employee cooperation being integral to such investigations. The Company upholds a zero-tolerance stance against retaliation resulting from good faith reporting, complaints, or cooperation with investigations. Appropriate remedial measures will be taken if misconduct is substantiated following an investigation. Violations of this policy may result in disciplinary actions, including termination.

E. Suppliers and Partners As outlined in our Sustainable Sourcing Statement and Supplier Code of Conduct, the Company anticipates our suppliers to conduct themselves with integrity, adhering to local laws and regulations, including those pertaining to human rights. The Company’s Supplier Selection and Approval Process entails due diligence, screenings, and third-party assessments of suppliers during the onboarding process. The Sustainable Sourcing Statement underscores compliance with modern slavery regulations, necessitating ESG and risk assessments where relevant. Adherence to screening criteria and corrective action plans is also emphasized.

The Company’s standard terms and conditions stipulate the possibility of terminating commercial relationships with suppliers, contractors, and other business partners contracting on these terms if they breach the Supplier Code of Conduct.

F. Responsibility and Oversight The Corporate Sustainability Office is entrusted with the administration and updates of this Policy. Oversight and guidance on the Company’s sustainability programs, including human rights-related issues, are provided by the Sustainability Committee of the Company’s Board of Directors.

G. Relevant Policies and Guiding Standards International Guiding Standards

• Universal Declaration on Human