HUMAN RIGHTS POLICY

    Effective Date: June 2025

    1. Introduction

    This policy outlines Rovensa’s commitment to respecting human rights throughout our operations, supply chain, and business relationships. It provides guidance to employees, suppliers, customers and other stakeholders on respecting human rights and maintaining appropriate conduct. This policy is in alignment with our existing Code of Conduct and Supplier Code of Conduct for both our own workforce and value chain, respectively.

    This policy highlights our dedication to upholding human rights standards, both internally and externally, emphasizing their importance in our business operations. We recognize that respecting and promoting human rights at every level—within our workforce, supply chain, and broader communities—is crucial to our business. We aim to protect and promote fundamental human rights, prevent or mitigate any adverse impacts, and strive to avoid complicity in human rights abuses.

    We adhere to international human rights standards and are committed to complying with all relevant laws and regulations wherever we operate. In instances where national law conflicts with international standards, we will adhere to the higher standard.

    We acknowledge that achieving these standards poses unique challenges in different regions. However, our main goal is to embed them in our direct operations and, moving forward together with our suppliers and business partners, to encourage the adoption of these standards, driving a positive impact on human rights across the world.

    Scope

    The Human Rights Policy applies to the whole Rovensa Group, including its employees, suppliers, customers, local community and also other stakeholders directly or indirectly affected by our business operations.

    Roles & Responsibilities

    All stakeholders mentioned in the scope are responsible for adhering to this policy and demonstrating integrity in complying with its requirements. Employees should take an active role in ensuring concerns about potential infringement of this policy are reported through formal grievance mechanisms.

    A shared responsibility to respect human rights must be assumed by suppliers and other business partners, through collaboration on risk analysis and diligence reviews.

    Significant developments in Rovensa’s human rights initiatives, along with notable impacts and key performance indicators, will be comprehensively reported in the Group’s annual sustainability report.

    Policy Review and Update

    This policy should be reviewed whenever necessary to ensure that it remains current and appropriate for fulfilling its purpose. Any change to the policy must be made by the Sustainability Team with the approval of the Executive Management Team (EMT). The Group reserves the right to change the present policy at any time.

    Policy Disclosure

    The policy should be communicated and made available to the organizational structure of Rovensa Group, being permanently accessible to all employees on our intranet, and also to other relevant stakeholders whenever necessary.

    Effective Date

    The policy will come into effect in June 2025.

    2. Our Commitment

    Rovensa is committed to upholding the principles of dignity and respect for all individuals and is dedicated to promoting and protecting fundamental human rights. As a global company, we foster an environment that honours our values. We ensure respectful working conditions for our own employees and expect the same from our business relationships.

    Through our SEEDS values – Safety, Empowerment, Ethic, Dedication, and Striving – we ensure that all individuals directly or indirectly connected to our business, from our own employees to our business partners, are treated with respect, dignity, and fairness, in line with the internationally recognized human rights standards.

    We are signatory members of United Nations Global Compact, and committed to upholding and supporting internationally recognized human rights standards, such as:

    • The Universal Declaration of Human Rights;
    • The International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work;
    • 10 Principles of United Nations Global Compact, namely the two principles that explicitly refer to the respect for human rights (Principle 1 and Principle 2);
    • OECD Guidelines for Multinational Enterprises.

    By embracing the principles of these standards, we aim to respect, protect, prevent, and mitigate any potential adverse impacts resulting from our business operations. Additionally, we strive to promote positive human rights practices wherever we operate and across our value chain.

    3. Our Focus Areas on Human Rights

    Our commitment to protecting and promoting human rights is founded on core values and principles that guide our actions both internally and externally. These values are evident in our interactions with employees, suppliers, and throughout our entire business chain.

    We expect all employees, suppliers, and business partners, whether directly or indirectly associated with Rovensa, to fully embrace these values, as the defense and promotion of human rights is a shared responsibility.

    Child Labour, Forced Labor and Human Trafficking

    Child Labour is an infringement of fundamental human rights. We oppose all forms of modern slavery, including child labor, forced labor, human trafficking, the deprivation of personal freedom by employers, and the facilitation of human trafficking for exploitation across all workplaces, operations, and the supply chain.

    We prohibit the use of child labour in our direct and indirect operations.

    Social Dialogue and Freedom of Association

    We recognize the importance of employees’ rights to freely associate, organize, and engage in collective bargaining in accordance with applicable legal regulations.

    Employees have the right to elect their own representatives, and we are committed to maintaining constructive and open dialogue to achieve mutually beneficial agreements.

    Employee Health and Safety

    Implementing and maintaining high health and safety standards is essential for protecting employees from workplace, transportation and commuting hazards.

    This includes identifying, assessing, and addressing potential risks, as well as providing regular training.

    Working Conditions

    We ensure a safe, fair, supportive, and growth-oriented working environment by maintaining an adequate standard of living for our employees and their families through fair remuneration and compensation.

    We provide compensation that exceeds the legal minimum wage in each country.

    We also offer continuous training and development opportunities and ensure reasonable working hours that comply with legal standards.

    Discrimination, Violence and Harassment

    We strive to uphold a workplace free from discrimination, harassment, and violence.

    Practices that discriminate based on race, sexual orientation, political affiliation, disability, religion, age or gender are not tolerated.

    Diversity, Equity and Inclusion

    We value diversity and cultivate a culture that enables every individual to contribute to their fullest potential.

    We promote equal treatment and opportunities for all.

    Privacy and Data Protection

    We respect employees’ privacy and protect personal data according to applicable EU and national regulations.

    Other Work-related Human Rights

    We acknowledge that our business activities may impact nearby communities, including water, sanitation, and land use.

    We are committed to minimizing environmental impact and safeguarding community wellbeing.

    4. Governance

    We view human rights management as an ongoing responsibility requiring a robust management structure.

    • Integration into business processes
    • Comprehensive risk analysis and due diligence
    • Preventive and remedial measures
    • Regular evaluations

    The Executive Management Team holds accountability for delivering human rights commitments.

    The Sustainability Department oversees implementation.

    An internal Human Rights Core Team supports implementation across departments.

    5. Grievance Mechanism

    We provide access to a global whistleblowing channel serving as a secure and confidential grievance mechanism.

    This channel enables reporting of unethical behavior, misconduct, or human rights violations.

    The mechanism is open to employees, suppliers, customers, and business partners.

    Appropriate measures will be taken if violations occur.