ERM GLOBAL POLICY

Human Rights, Modern Slavery and Child Labor1.

PURPOSEThe purpose of this policy is to outline ERM’s commitment and actions in support ofinternational efforts to uphold human rights and against modern slavery and child labor. The
policy is in alignment with the ERM Code of Business Conduct and Ethics, ERM’s AnnualStatements on Modern Slavery, and applicable international and national laws.

2.

SCOPE

This Policy applies worldwide to all ERM entities, all Employees and all ERM Agents.

3.

DEFINITIONSTERMAgent(s)DEFINITION

Any officer of any ERM entity, hired personnel, consultants, intermediaries,lobbyists, agents, representatives, independent contractors,subcontractors, and any others who act on ERM’s behalf.

Basic Minimum

ERM defines “basic minimum age” and “age for hazardous work” as 15

Age or Age foryears and 18 years respectively, or the minimum age set by national law,

Hazardous Work

with any conflict in application by ERM to be resolved by the higher age.
Certain exceptions may exist and be permitted by ERM for supporting thegoal of promoting education and work experience as part of a bona fideeducation program, but only in conformance with local law. The above
definitions are in line with the ILO Conventions 138 and 182.

Child Labor

The term child labor means hazardous labor or labor provided by a childbelow a basic minimum age.

Employee(s)Any personnel hired directly by ERM (regardless of status classification of
full-time, part-time, temporary, contract, etc.); interns (even if an intern
does not receive payment by ERM); employees of other companies
seconded into ERM, and any ERM employee seconded to a non-ERMcompany.

ServitudeServitude is the obligation to provide services imposed by the use ofcoercion, while “forced or compulsory labor” refers to any work or service
that is performed involuntarily and under the menace of penalty.

HumanThe recruitment, transportation, transfer, harboring or receipt of a person

Trafficking

by improper means (including but not limited to force, abduction, fraud orcoercion) for an illegal or improper purpose, including forced labor.

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CLASSIFICATION: INTERNAL OR EXTERNALTERMModern Slavery

DEFINITION

A broad phrase used to encompass slavery, servitude, forced orcompulsory labor and human trafficking.

SlaverySlavery occurs when ownership is exercised over a person which deprives
the person of his or her freedom.

The above definitions are in line with the UK Modern Slavery Act 2015, International Labour
Organisation (ILO)’s Forced Labour Convention 29 and the 1926 Slavery Convention.
Example types of modern slavery:

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4.

COMMITMENTERM endorses the United Nations Guiding Principles on Business and Human Rights andsupports the principles contained within the UN Declaration of Human Rights, the International
Bill of Human Rights and the International Labour Organisation’s Declaration on Fundamental
Principles and Rights at Work.
ERM are signatories to the UN Global Compact and thereby commit to uphold it’s 10 principles,two of which focus on human rights. We report our performance annually via theCommunication on Progress which is published on the UN Global Compact website.
We conduct human rights due diligence as part of our project selection and review process.
This includes triggers within our Project Liability Analysis (PLAN) tool and our automatedsanctions checks.
Modern slavery is both a crime and a violation of fundamental human rights. ERM is committed
to the elimination of all forms of modern slavery and to the international effort to abolish childlabor. ERM takes a zero-tolerance approach to such activities and seeks to identify and address
such risks in our offices, operations and wider supply chains. ERM publishes an AnnualStatement on Modern Slavery Statement that outlines our activities and performance during
the year.
ERM will routinely fund, develop and require training on modern slavery as determined by
ERM’s ExCom Sustainability Working Group.
ERM is committed to supporting its clients in their efforts to address modern slavery and childlabor in their operations and supply chains. ERM delivers a range of services to its clients
including the development of modern slavery and child labour policies, risk assessments,mitigation strategies and remediation. Examples of ERM client work in this area may bereported in the Sustainability Report or our corporate communication channels, subject to3HUMAN RIGHTS, MODERN SLAVERY AND CHILD LABORVERSION: 6
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confidentiality and other considerations, as determined by ERM’s ExCom Sustainability Working
Group.

5.

EMPLOYEE RESPONSIBILITIES
1. All Employees are expected to be aware of human, rights, modern slavery and childlabor risks and to remain vigilant in spotting the signs when conducting business,particularly when involving third-party business partners.
Some examples include:•Hiring a sub-contractor to support a site assessment;•Contracting transport or logistical services for a remote project;•Using a recruitment agency to hire new employees; and•Contracting cleaning services for ERM’s offices.

2. Employees should familiarize themselves with the ERM Business Code of Conduct andEthics and ERM Statement on Modern Slavery, which include provisions related tomodern slavery and child labor.
3. If an Employee suspects a breach of this Policy they should report their concerns
immediately to their line manager and Chief Compliance Officer or via thebusiness.conduct@erm.com email notification system. Additionally, ERM has a 24/7
online or call-in option for any employee who wishes to report concerns anonymously.
The anonymous reporting option is the ERM Helpline. The Helpline is a third party
independently administered system that is a multilingual reporting system accessible
to all employees.
4. Any Employee who breaches this Policy or fails to report any breach they becomeaware of will be subject to appropriate disciplinary action up to and including dismissal.
5. Student educational work experience that has been approved by ERM in accordancewith international standards and local applicable law is not considered child or forcedlabor.

6.

BUSINESS PARTNER RESPONSIBILITIES
1. Business partners including sub-contractors, suppliers and recruitment agencies are
required to comply with ERM’s Supplier Code of Business Conduct and Ethics andSustainable Procurement Policy, which include provisions related to human rights,
modern slavery and child labor.
2. Business partners should also endeavor to cascade the provisions of the Supplier Codedown their own supply chains.
3. If a business partner suspects a breach of this Policy they should report their concerns
immediately to the Chief Compliance Officer.

7.

PROCEDURE

All Employees will be registered in ERM’s Human Resources Information System (HRIS) andcontractors providing labor or services to ERM will be registered in ERM’s Global Contractor
Management System as that system is progressively rolled out globally. ERM’s hiring andcontractor selection protocols must be adhered to but may vary to meet local applicable law

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and applicable ERM global, regional, and local policies. All approval for student educational
work experience must be obtained in writing from the applicable Regional Human Resources
Director.

8.

IMPLEMENTATIONThis policy will be reviewed at least every three years. On at least a yearly basis, the ERM
Global Sustainability Director will report progress under this policy to ERM’s Global CEO.

ERM GLOBAL POLICY MANUAL ADMINISTRATION
Policy Title: Human Rights, Modern Slavery and Child Labor
Version Number: 6 (Note: originally titled Child and Forced Labor in 2010, then revised toSlavery, Child Labor and Human Trafficking in 2016 and 2019 revisions prior to current title)
Policy Number: 13Effective Date of this Version: 14 Mar 2024
Original Approver and Original Effective Date: Group CEO/20 Aug 2021. Approval andversion history maintained by ERM Legal Department.
Policy Description: Policy to support human rights and prohibit modern slavery and childlabor use or involvement by ERM, updated for the UK Modern Slavery Act 2015.
Authority to Amend this Policy: Chief Compliance Officer
Authority to Waive this Policy: None
Policy Review Cycle: 3 years from Effective Date of this version
Docket Responsibility for Review Cycle: ERM Global Sustainability Director5