Human Rights Policy - Laminazione Sottile Group

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GROUP HUMAN RIGHTS POLICY

1 INTRODUCTION

Respect for People is one of the inspiring principles of the Laminazione Sottile Group (hereinafter also “LS Group”), also made official within the Company Values. People are at the heart of our growth process and contribute to the development of our company through passion, creativity and their specific talents, working in teams based on mutual respect. A diversity of personalities and ways of being that, within a framework of shared values, represents a source of constant enrichment, comparison and innovation.

1.1 Purpose of the document and summary of contents

Our Human Rights Policy outlines the expectations that the Group places on its Employees and its commitment to supporting a peaceful, participatory and professional work environment. It is inspired by the Universal Declaration of Human Rights, the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, the LS Group Code of Ethics.

We believe in an effective collaboration with our suppliers and with external companies operating in the plants, to whom we ask to share our values and principles and to adhere to this Policy.

1.2 Regulatory context and scope

The Group respects - and all Employees must comply with - applicable international and national laws and regulations. In some specific cases, it is possible that the Group’s standards and requirements are more restrictive than what is required by the legislation of some countries; it is also possible that in some countries, conduct that the Group expressly prohibits is permitted. In this sense, the Laminazione Sottile Group demands compliance with the standards of this Policy, regardless of whether or not they are prohibited by national law.

This Policy applies to Laminazione Sottile S.p.A. and all its subsidiaries (part of the LS Group).

Subsidiaries are responsible for adopting this document and ensuring compliance with it.

The Policy includes all behaviours committed both inside and outside the Group Companies by Employees or staff in administration, regardless of their classification or level of seniority. Therefore, the Human Rights Policy applies in the Group’s offices as well as off-site: for example, at customers’ plants and offices, during events and in places of travel, and is valid in all work contexts, including business trips, meetings, events and all social situations related to the Group and its business.

The Group will take all appropriate measures to prevent inappropriate behaviour and to ensure that the person reporting it does not have negative repercussions.

Although it cannot directly control the behaviour of Third Parties (suppliers, external companies), the Group does not tolerate any acts committed by them in breach of this Policy and will implement the consequent measures with repercussions on the continuation of the business relationship.

1.3 Issuance, review and terms of validity

This Policy is valid from the date of its issue (indicated on the document).

Any subsequent update repeals and supersedes, from the date of its issue, all previously issued versions.

The Group HR Function is responsible for updating this Policy and disseminating it.

The Policy is subject to periodic review (at least every five years) and re-issued by the Issuing Entity where necessary (in particular in the event of organizational changes, any gaps/critical issues found or when the applicable national and international standards and regulations, referred to as best practices, are subject to changes).

1.4 Responsibility and disclosure

The governance bodies of the LS Group, supported by the Steering Committee and the Group Sustainability Committee, and with the engagement of the Functions involved in various capacities (including, but not limited to, the Human Resources, Legal & Compliance Functions) play a strategic role in the full implementation of this Policy, ensuring the involvement of all workers and collaborators so that they express behaviours consistent with the values contained therein.

In order to ensure the continuous improvement of its performance, in relation to the processes covered by this Policy, the LS Group undertakes to identify the most significant performance indicators (KPIs), to set achievable improvement objectives and to periodically monitor and report the achieved results in the annual Sustainability Report.

2 DIVERSITY, EQUITY & INCLUSION

Diversity is richness. Wealth for the company that benefits from different points of view that help to improve the way it does business; wealth for the staff themselves who compare themselves with colleagues from different national, ethnic and cultural backgrounds; wealth for the territory that innovates through change.

For this reason, the Laminazione Sottile Group embraces the concept of diversity: we welcome and value all the differences of our employees, regardless of their ethnicity, nationality, citizenship, skin colour, gender, sexual orientation, cultural background, religion or belief, age, disability, marital status or other physical or cultural characteristics that make our employees unique.

Our long history bears witness to the value of inclusion, understood as the development of a working environment in which employees perceive a sense of belonging, feeling recognised in their value, respected and appreciated.

Our commitment to ensuring the principles of Diversity, Equity and Inclusion aims to safeguard the well-being of our employees and all those who work with the Group through:

• a workforce that reflects the diversity of the places and communities in which we operate around the world;

• a work environment in which individual differences are valued and the work contribution of all is recognised;

• a context of inclusion and belonging that provides employees with physical and psychological security, transparency, in which each person is encouraged to make their own contribution;

• recruitment methods that exclude discriminatory criteria in the selection of candidates, both during the initial screening phase and during the advanced stages of on-site interviews;

• a process of periodic review of recruitment procedures to always ensure fair treatment;

• equal training, development and career progression opportunities for all employees;

• possibility of taking maternity/paternity leave without slowing down the professional growth and career development of the person;

• the development of employee talent, to develop opportunities for improvement and innovations and provide the best solutions to our customers;

• the promotion of dignity and respect, not tolerating any form of intimidation, bullying, discrimination or harassment.

2.1 Non-discrimination

In general, the Laminazione Sottile Group promotes, with transparent processes, equal opportunities for all employees at every stage of the employment relationship (selection and hiring, training, professional development and remuneration) and is committed to ensuring that personnel do not suffer unfair and discriminatory treatment based on:

• Ethnicity, skin colour, national or family origin

• Sex, gender identity or sexual orientation

• Age

• Citizenship, marital status, maternity

• Religion or religious belief

• Mental or physical disability or health status

• Other categories protected by law

3 HARASSMENT AND INAPPROPRIATE BEHAVIOUR

The Laminazione Sottile Group does not tolerate any behaviour similar to harassment, bullying and other forms of abuse or intimidation: these, even when they do not represent a crime in themselves, damage both the dignity of the person who suffers them (compromising their health, confidence, morale, motivation at work, work performance) and the organisational spirit and reputation of the Group.

All Employees must be aware that behaviours and words can be perceived and interpreted by each person differently: helping to create and maintain a respectful and harmonious work environment means paying attention to verbal and body language, as well as to one’s own behaviour, eliminating intimidating, hostile, degrading, humiliating or offensive words and attitudes.

Inappropriate conduct may include, but is not limited to, offensive or sexually explicit jokes, unwelcome sexual advances, unwelcome physical contact or requests for sexual favours, racial slurs and insults, threats, intimidation, physical or verbal abuse and coercion, defamation, misuse of personal information, dissemination of offensive or sexually explicit written or graphic material, sabotage or damage to a person’s work performance.

Consistent with the principle of non-discrimination, this Policy prohibits attitudes and behaviours aimed at denigrating, displaying hostility or aversion to ethnic or national affiliation, age, gender or gender identity, religion, marital status and all other protected characteristics of an individual or group.

Inappropriate conduct is prohibited regardless of sex, gender, or whether it is engaged in by a line manager, employee, customer, salesperson, or Third Party with whom the Employee interacts on a job basis.

The Group also explicitly prohibits any behaviour that relates employment, remuneration or career opportunities to any form of sexual or sentimental activity.

4 MODERN SLAVERY

We are committed to preventing all forms of slavery, forced or bonded labour, child labour and human trafficking (hereinafter collectively referred to as “modern slavery”), both in our business and in our supply chain.

Modern slavery is a serious crime and a violation of fundamental human rights. This “modern slavery” shows itself in different forms involving the exploitation of an individual by others, for personal or commercial gain. This includes a range of activities ranging from recruitment, to hosting, to transporting, to providing labour through threat or coercion.

4.1 Prevention of modern slavery in the company

Each employee enters into an agreement (in compliance with the specific National Collective Labour Agreement or national regulations in force) with the specific Group company in which the terms and conditions of their employment are outlined. Work details, including pay, holidays, working hours and breaks, are in compliance with the National Collective Labour Agreement and applicable national laws, to ensure respect for human and workers’ rights, the health and safety of all our employees and contractors.

In addition, the LS Group ensures that appropriate checks are carried out on all employees during the recruitment process, to confirm that they meet all the requirements required by law.

The recruitment agencies and partners with whom the Group collaborates share our commitment to combating modern slavery.

4.2 Prevention of modern slavery in the supply chain

We are committed to implementing and enforcing systems and controls to prevent modern slavery in our supply chain. We expect all of our contractors, suppliers, and other business partners to meet the same rigorous standards, and we require our contractors and suppliers to abide by our policies and codes to combat the use of forced, compulsory, or trafficked labour, and not to employ in any way enslaved or bonded personnel, both adults and minors.

We have defined a series of policies and standards to strengthen our commitment to safeguard and protect human rights, including the Group’s Code of Ethics. These policies and codes specifically prohibit forced or child labour, slavery in all its forms, and human trafficking.

We require all our suppliers to adhere to our Supplier Code of Conduct, which provides for the prevention of modern slavery in all its forms.

5 LOCAL COMMUNITIES AND INDIGENOUS PEOPLE

We are committed to respecting the rights of local communities and contributing to their economic and social growth.

In developing our projects, we are committed to involving all relevant stakeholders and respecting the rights of the most vulnerable populations, such as indigenous and tribal people (where they are present in the Group’s sphere of influence), in accordance with applicable international standards (with particular reference to ILO Convention 169 and the United Nations Declaration on the Rights of Indigenous Peoples).

6 DUE DILIGENCE ON RESPECT FOR HUMAN RIGHTS

The due diligence process is the implementation tool of the commitments expressed in this Policy to make respect for human rights effective in the sphere of influence of the LS Group.

To this end, this Policy provides guidance on how to:

• identify areas of activity potentially exposed to the risk of human rights violations;

• take a census on the existing measures in these areas to mitigate the risk;

• assess whether these measures are adequate to give effect to commitments to respect human rights;

• identify, on the basis of adequacy assessments, the areas of activity in which it is appropriate to reduce the risk of human rights violations;

• provide input for the definition of improvement plans in areas actually at risk;

• ensure a follow-up of improvement actions and the periodic repetition of due diligence.

6.1 Due diligence process

The list of human rights to be considered in the due diligence is as follows:

• forced labour and child labour

• discrimination

• freedom of association and collective bargaining

• health and safety

• working conditions and pay

• vocational training

• privacy

• environment

• prevention of corruption

• civil and political rights (freedom of thought and expression, political and religious freedom, equality before the law).

The cyclical due diligence process consists of three main phases:

1. identification of areas of activity that present potential risks of human rights violations;

2. census of measures to mitigate the risk of human rights violations in the areas identified in the previous phase;

3. assessment of the adequacy of mitigation measures to identify areas of activity where these may not be sufficient to contain the risk to an acceptable extent.

Following the results of the previous three phases, if particular risks of human rights violations have been found for which an improvement plan has to be adopted, a followup verification on the implementation of the plan must be provided. Finally, the results of the due diligence process should be adequately communicated to the outside world by including the same results in the Sustainability Report.

Phase 1 - Identification of areas of activity potentially exposed to the risk of human rights violations

Human rights holders and stakeholders of the LS Group are natural persons. In order to identify the areas of activity of the LS Group potentially at risk of human rights violations, it is therefore necessary, first of all, to identify the categories of persons whose rights may be violated. The main reference in this regard is the stakeholder map.

Taking into account that many of the human rights in question are related to work, it will also be useful to consider - within the different categories of stakeholders, where applicable - the respective employees (e.g. employees of suppliers) and it will be necessary to pay particular attention to the following categories to be considered most “vulnerable”:

- women, children, the disabled, foreign workers and migrants;

- employees of suppliers who carry out their activities in the offices of the LS Group; - local communities/ indigenous peoples.

All the categories of persons referred to in the previous point must be “crossed” with the list of human rights identified in order to hypothesise the situations in which it is possible – in theory – that, in the relationship with the LS Group or its suppliers, a human right held by persons belonging to the aforementioned categories is infringed. This exercise does not take into account the mitigation measures in place, as it aims to configure a set of areas potentially exposed to the risk of human rights violations.

Once the situations in which it is possible – in theory – for a human rights violation to occur have been identified, these situations must be explained by linking them to specific processes or activities of the LS Group.

Phase 2 – Census of the mitigation measures present

Only areas of activity classified as potentially at risk of human rights violation, as a result of phase 1, are subject to this phase 2. The purpose is to verify the presence of elements to monitor respect for human rights, that is, measures to mitigate the risk of their violation.

The main risk mitigation measures to be sought are:

• existence of legal or contractual rules (e.g. deriving from the National Labour Agreement), aimed at protecting human rights and demanding their respect, applicable in the case in question and severity of the related sanctions;

• existence of certified (ISO) or structured management systems with their own monitoring systems (e.g. Model 231 for companies based in Italy);

• existence of Guidelines and Operating Instructions that prescribe behaviours in line with respect for the specific human rights at risk;

• existence of company structures responsible for preparing, applying and controlling compliance measures and any further voluntary mitigation measures;

• presence of specific monitoring systems on compliance with company rules on human rights (e.g. checks at construction sites);

• presence of systems for reporting behaviour contrary to respect for human rights;

• carrying out employee training and/or awareness-raising activities;

• provision of sanctions (for example disciplinary) in case of non-compliance with human rights;

• as regards in particular the subjects operating in the supply chain and the business partners, the systematic presence of qualification criteria, of contractual clauses that address the respect of the specific human rights of relevance.

The presence of mitigation measures may be recorded on the basis of the information present in the company’s document system, supplemented by interviews with the managers of the various activities and other in-depth information deemed necessary.

Phase 3 – Assessment of the adequacy of mitigation measures

The activity consists of assessing whether, in an area at risk, the mitigation measures recorded are suitable for preventing the situations of human rights injury hypothesised in the area in question.

At the end of this phase, two groups of activities will result: those adequately supervised, which will be subject to assessment again, and those that require the definition of an Improvement Plan.

7 DISSEMINATION AND TRAINING OF PERSONNEL

This Policy is communicated to the staff of all Group companies and is made available to Third Parties on the company websites.

Training is a further essential element for the widespread dissemination of the Policy, to increase employees’ awareness of the issues covered and to promote its prevention. In this regard, the Group undertakes to provide all Employees (directly and through administration) with mandatory and up-to-date training on the Group Code of Ethics, the contents of this Policy as well as on how to report concerns, suspected violations of ethical aspects and/or illegal or inappropriate behaviour.

These training courses are guaranteed both for all new incoming resources and periodically for staff already in force.

8 REPORTING PROCESS

It is essential for the protection of people, the work environment and the reputation of the Group that all Employees report any acts and behaviours contrary to this Policy, such as discriminatory acts, harassment, bullying or sexually inappropriate behaviour.

The Employee - without prejudice to the possibility of recourse to the competent authorities - is required to report violations of the policy, alternatively:

• through the channels provided for by the Whistleblowing Policy;

• the Human Resources structure of its Group Company;

• to their direct Manager or, where this is involved, to the hierarchical superior, on the basis of their reporting lines, who in turn will involve the Human Resources structure of their Group Company;

• through any other channel available in force at the specific Group Company.

The Laminazione Sottile Group expects this circumstance to be reported by the Employee even if there are situations in which another person is the victim of conduct prohibited under this Policy.

The Group undertakes to verify the report, treating it with respect, investigating and promptly and impartially managing the related report. The Group will take all necessary measures to ensure confidentiality and discretion to reports (in accordance with applicable legal regulations and to the extent permitted by any investigation to be carried out). Under this Policy, Employees are required to cooperate in investigations.

9 PROHIBITION OF RETALIATION

The Group is firmly committed to protecting the Employee who reports any conduct prohibited by this Policy, or who raises doubts, from any retaliation against them. Such Employee will be protected for as long as necessary, not only by the alleged perpetrator, but by anyone who may exert undue pressure.

A retaliation is an adverse conduct towards a person due to the fact that he/she:

• reported an actual or perceived violation of a Group regulation or law, or reported prohibited or inappropriate conduct in the workplace;

• was opposed to conduct that could violate Group or legal regulations or other prohibited or inappropriate conduct in the workplace;

• has participated in the reporting and investigation process referred to in Group legislation;

• provided support to an investigation or proceeding that concerns an actual or perceived violation of a Group regulation.

Retaliation is strictly prohibited and is in itself a violation of this Policy. Anyone who engages in a retaliation against the Reporting Employee or Reporting Third Party, including acts aimed at silencing the Employee through economic incentives or other benefits, will be subject to action according to the envisaged disciplinary sanctioning system. For more details, please refer to the Group Code of Ethics.

10 DISCIPLINARY ACTIONS

Violation of the provisions contained in this Policy or of the principles, values, fundamental obligations and rules of any kind specific to the matter, may result in the responsible Employee being subject to a proportionate disciplinary measure, including dismissal, in accordance with the provisions of the Disciplinary Code in force.

The Group undertakes to implement and constantly update the highest organisational and management standards to prevent similar situations from recurring.

ANNEX 1 – REFERENCES

• Universal Declaration of Human Rights

• UN Guiding Principles on Business and Human Rights

• ILO fundamental conventions and ILO Declaration on Fundamental Principles and Rights at Work

• Modern Slavery Act 2015 - Section 54 – UK

• California Transparency in Supply Chains Act of 2010 (SB 657)

• Modern Slavery Act 2018 (No. 153-2018) - Australia

• Laminazione Sottile Group Code of Ethics

GLOSSARY

Keywords Definitions

Employees All persons linked to the Laminazione Sottile Group or Group Companies by an employment agreement (including consultants and seconded employees), as well as all members of the executive, strategic and control bodies

Group companies These are Group companies controlled directly or indirectly by Laminazione Sottile S.p.A.

Group The Laminazione Sottile Group, consisting of Laminazione Sottile S.p.A. and its subsidiaries

Third Parties

Natural or legal persons linked to the Group by a contract such as, for example, customers, suppliers, agents, etc.

Latest revision: April 04, 2025

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