Policy

Responsible Procurement

Version:
Effective date:
Approved by:
Issued by:Distribution:

1.0
July 1, 2022
Executive Committee
Group Sustainability
DKSH Group

Supersedes and replaces all prior versions as from the effective date.

Corporate Center
Group Sustainability

DKSH Holding Ltd.
Wiesenstrasse 8, P.O.Box, CH-8034 Zurichwww.dksh.com

Policy

Table of contents

1 Introduction ............................................................................................................................................. 3
2 Definitions ............................................................................................................................................... 3
3 Scope...................................................................................................................................................... 44 Responsible Procurement ...................................................................................................................... 4
4.1 Clients .......................................................................................................................................... 4
4.2 Suppliers ...................................................................................................................................... 4
4.2.1 Supplier qualification ...................................................................................................... 5
4.2.2 Supplier commitment ...................................................................................................... 5
5 Specific procurement risks ..................................................................................................................... 55.1 Minerals and Metals from Conflict Areas (“Conflict Minerals”) .................................................... 55.2 Child Labor ................................................................................................................................... 66 Raising concerns or grievances ............................................................................................................. 6Appendix 1 – Minerals and metals subjected to review and approval ...................................................... 7Appendix 2 – Risk of countries using Child Labor1 ................................................................................... 8Page 2Policy

1 Introduction
This Responsible Procurement Policy (“RPP”) enhances our Sustainability Policy and underpins DKSH’s
commitment to conducting its business in a responsible and sustainable manner. It communicatesassociated principles, standards, and practices to be applied throughout the DKSH Group, in alignment
with our corporate values and beliefs, reflecting by reference the following:• Regulatory requirements, including Swiss Regulations on transparency in non-financial matters andassociated due diligence requirements, and any other applicable laws and regulations in our markets;
as well as• Universal and multilateral standards or rulesets, specifically the‒ United Nations Global Compact (UNGC), the‒ OECD Guidelines for Multinational Enterprises and associated Due Diligence Guidelines forResponsible Business Conduct and Responsible Supply Chains for Conflict Minerals, and the‒ International Labor Organization’s Declaration on Fundamental Principles and Rights at Work

2 Definitions
For the interpretation of this RPP, the following definitions shall apply (in alphabetical order; plural
includes the singular form and vice versa):
Child Labor

Refers to child labor pursuant to Swiss Regulations and international standards

ClientIs a company for whom DKSH provides marketing and/or distribution services
under contractually agreed terms and conditions

Conflict Areas

Refers to areas in a state of armed conflict or fragile post-conflict as well as
areas witnessing weak or non-existent governance and security, such as failed
states, and in which there are widespread and systematic violations ofinternational law, including human rights abuses.

Conflict Minerals

Refers to a list of minerals and metals (including by-products) and their origins
pursuant to Swiss Regulations (see Appendix 1)

Procurement

Refers to the totality of DKSH’s purchasing activities for goods and/or services
from non-DKSH parties

Supplier

Refers to any external party who is not a Client and who provides goods orservices to DKSH

Supplier Category

Refers to a grouping of Suppliers in relation to the similarity of the type of goods
or services they provide

Supply Chain

Refers to a range of activities carried out by entities upstream from anorganization, which provide products or services that are used in thedevelopment of an organization’s own products or services

Swiss Regulations

Refers to applicable laws and regulations in Switzerland on transparency in nonfinancial matters and associated due diligence requirements including the Swiss
Code of Obligations and the Ordinance on Due Diligence Obligations andTransparency relating to Minerals and Metals from Conflict Areas and ChildLaborPage 3

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3 ScopeThis RPP outlines the principles and practices how DKSH addresses business risks in its Supply Chain
in a sustainability context. It encompasses all Procurement activities of DKSH in relation to its productand service offerings and applies to the DKSH Group of companies (“DKSH”), its personnel, its joint
ventures (unless specifically excluded by agreement) as well as any other company or personnel
managed or controlled by DKSH.
4 Responsible ProcurementDKSH’s business is guided by the following principles and standards pertaining to ethics, human rights,
working conditions and environmental stewardship:• We conduct our business in a lawful and ethical manner, compete fairly in the marketplace and do nottolerate any form of bribery and corruption• We treat all our people equally and with fairness, dignity, and respect, and seek to offer safe
workplaces free of discrimination or harassment• All work is conducted on voluntary basis and on freely agreed, and documented terms of employment,
based on fair pay and reasonable working hours• We do not tolerate Child Labor in any form and fully embrace ILO Conventions No. 138 and 182• We take appropriate measures to protect the health and safety of our people at work and anyone else
working on or visiting our premises• We expect our people to speak up and voice concerns or grievances and ensure access to fair
procedures and remedies• All workers are free to exercise their right to form and/or join trade unions or to refrain from doing soand to bargain collectively• We do not procure minerals or metals from Conflict Areas, and support industry standards or otherinitiatives on responsible business practices, specifically in certain product categories we operate indeemed to be at higher environmental and/or social risks, such as for example textiles or palm oil• We operate an environmental management system geared towards preventing or mitigating adverse
impacts caused or contributed by us, including our CO2 footprint and its effect on climate change
We are committed to supporting our business relationships in the Supply Chain to meet these standards
and to conduct their business in a responsible manner, as further specified herein below.
4.1 Clients
DKSH seeks to enter and maintain relationships with Clients who share similar values and beliefs, striving
to operate their business responsibly, and will seek corresponding assurance in commercial agreements
governing the relationship. DKSH reserves its rights to turn down business opportunities with prospective
Clients on concerns over conflicts with the principles and standards as outlined under 4. above.
Whenever appropriate and relevant, we shall engage with existing Clients upon concerns that responsible
business conduct may be compromised, to establish whether such concerns are unfounded, remedialactions by Clients will be undertaken, or whether a disengagement shall be considered.
4.2 Suppliers
DKSH assesses new Suppliers and monitors active Suppliers for risks or concerns pertaining to ethicalbusiness conduct, environmental practices, labor conditions as well as human rights. The assessment

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encompasses adequate screening and due diligence procedures and enhances processes andprocedures applicable pursuant to DKSH’s Non-Trade Procurement (NTP) and Third-Party (Sales)Intermediaries (TPI) policies.
DKSH reserves its rights to turn down business opportunities with prospective Suppliers on concerns ofconflicts with the principles and standards as outlined above.
DKSH will follow up on concerns arising with active Suppliers and in justified cases will seek anunderstanding with Suppliers on corrective action plans. In severe cases or where remediation is not
likely to be resulting in satisfactory outcomes, DKSH will seek disengagement on the principle that we do
not do business with Suppliers that do not meet DKSH’s expectations on responsible business practices.
4.2.1 Supplier qualification
DKSH assesses Suppliers in terms of their conformity with DKSH’s standards of doing business, via anassessment and qualification procedure.
Suppliers are categorized based on the nature of business they do with DKSH, and the respective
categories are assessed and rated on likely impacts in relation to environmental, social, or governancethemes material to DKSH, including considerations for industry-specific as well as market-based factors(for example Child Labor, modern slavery, or anti-corruption indices), applying recognized standards andcertification systems.
Supplier Categories and Suppliers assessed at a higher risk profile are prioritized for further screening
and verification. Any concerns arising from such verification shall be directly taken up with Suppliers andbrought to satisfactory resolution or, alternatively, to a Supplier disqualification.
For lasting Supplier relationships, DKSH maintains a process of monitoring Supplier business conduct
on an ongoing basis.
4.2.2 Supplier commitment
Where reasonable and proportionate, given the nature and frequency of business transactions, DKSH
will seek corresponding commitments by Suppliers to responsible business conduct, as outlined above.
Such commitment shall provide DKSH with the right to conduct audits and to terminate Suppliers if
DKSH’s expectations are not met and Suppliers are unwilling or unable to present a satisfactory remedialaction plan.
5 Specific procurement risks
5.1 Minerals and Metals from Conflict Areas (“Conflict Minerals”)
DKSH generally does not procure for processing or otherwise trade in minerals or metals as identified byAppendix 1. Any exceptions require notification to Group Compliance (GRC) and will set in motion areview and approval procedure. If such review raises concerns on minerals or metals potentiallyoriginating from Conflict Areas, due diligence in accordance with requirements pursuant to applicable
Swiss Regulations shall be performed, including but not limited to information gathering from publicauthorities, international organizations and civil society, consultation of experts or commissioning audits.
GRC in collaboration with Group Supply Chain (SCM) orchestrates at least annual conformity checks(tariff code checks as per Appendix 1 on all procurement activities by DKSH), to verify internal compliancewith notification and review requirements pursuant to applicable Swiss Regulations. Any imports noted
but not notified to GRC shall be investigated, to establish that the minerals and metals do not originate

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Policyfrom a Conflict Area, including a documentation of this finding. Where investigations return a positive
result, adequate corrective action shall be taken.
DKSH procures and resells a vast array of trading goods and cannot control or rule out that such goods
unknowingly contain Conflict Minerals. To mitigate the potential occurrence of Conflict Minerals in trading
goods, DKSH applies contractual safeguards and assurances as reasonably applicable and enforceable
in its Supply Chain, apart from subjecting the respective Supplier categories to risk screening.
Reasonable suspicion of Conflict Minerals to be contained in trading goods procured by DKSH shall beinvestigated and appropriate action shall be taken, up to and including a discontinuation of business
relationships.
5.2 Child LaborDKSH does not tolerate any form of Child Labor and aims not to source or offer products or services thatare produced or provided using Child Labor. Any suspicion of the use of Child Labor requires notification
to Group Compliance (GRC) and will set in motion a review procedure. If based on such review, there
are no reasonable grounds to suspect Child Labor, this finding shall be documented. If such review raises
reasonable grounds to suspect the use of Child Labor, due diligence and reporting obligations inaccordance with requirements pursuant to applicable Swiss Regulations shall be performed, andappropriate action shall be taken, up to and including a discontinuation of business relationships.
Reasonable grounds for suspicion are deemed to exist if the suspicion results from findings based on
specific evidence or multiple indications, and this suspicion cannot be dispelled despite furtherclarifications.
Particular attention shall be paid to products or services that are produced or provided in countries withan enhanced or heightened risk of using Child Labor as defined in Appendix 2.
6 Raising concerns or grievances
DKSH expects Suppliers to timely self-disclose to DKSH adverse events that may or will affect DKSH’s
business and/or reputation. Suppliers may also raise concerns they have over DKSH’s business conduct,and specifically over incorrect or unethical treatment by DKSH personnel.
Moreover, DKSH encourages reporting by any concerned party over Supplier business conduct.
DKSH favors reporting via its IntegrityLine reporting system (https://dksh.integrityline.org).

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Appendix 1 – Minerals and metals subjected to review and approval

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Appendix 2 – Risk of countries using Child Labor1
Country
Afghanistan
Albania
Algeria
AndorraAngolaAntigua and Barbuda
Argentina
Armenia
Australia
Austria
Azerbaijan
BahamasBahrain
Bangladesh
Barbados
BelarusBelgium
BelizeBenin
BhutanBolivia
Bosnia and Herzegovina
Botswana
BrazilBrunei
Bulgaria
Burkina Faso
BurundiCabo VerdeCambodia
Cameroon
CanadaCentral African Republic
ChadChile
China
Colombia
Comoros
Congo
Costa Rica
Côte d'Ivoire
Croatia
Cuba
CyprusCzech Republic
DenmarkDjibouti
Dominica
Dominican Republic
DR Congo
EcuadorEgypt
El Salvador
Equatorial Guinea
Eritrea
Estonia
Ethiopia
Fiji
FinlandFranceGabon
GambiaGeorgia
Germany
Ghana

12

Index
score 2
6.20
3.60
3.90
1.90
6.60
4.10
4.10
3.90
2.30
2.30
3.60
3.30
5.10
5.90
3.50
3.10
2.30
3.80
5.70
4.40
5.00
3.50
4.20
3.70
4.20
3.40
5.70
6.30
4.30
6.40
6.20
3.30
7.30
6.90
2.50
5.60
4.00
5.70
6.40
3.30
6.10
2.20
3.20
3.20
3.00
1.50
5.30
2.80
4.50
6.30
3.50
4.50
4.00
7.30
7.20
2.00
5.50
4.80
1.90
1.10
4.50
6.30
3.50
2.30
4.50

Risk
Enhanced
Enhanced
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Basic
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Basic
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Heightened
Heightened
BasicEnhanced
Enhanced
Enhanced
Enhanced
Basic
Enhanced
Basic
Basic
Basic
Basic
Basic
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Heightened
Heightened
BasicEnhanced
Enhanced
Basic
Basic
Enhanced
Enhanced
Enhanced
Basic
Enhanced

Country
GreeceGrenadaGuatemalaGuineaGuinea-Bissau
GuyanaHaiti
Honduras
Hungary
Iceland
India
Indonesia
Iran
Iraq
IrelandIsraelItaly
JamaicaJapan
JordanKazakhstan
Kenya
Kiribati
KosovoKuwaitKyrgyzstan
Laos
LatviaLebanonLesothoLiberia
Libya
Liechtenstein
Lithuania
Luxembourg
Macedonia
Madagascar
MalawiMalaysia
Maldives
Mali
Malta
Marshall Islands
Mauritania
Mauritius
MexicoMicronesia
Moldova
MonacoMongolia
Montenegro
MoroccoMozambique
MyanmarNamibia
Nauru
Nepal
Netherlands
New Zealand
Nicaragua
Niger
Nigeria
North Korea
NorwayOman

Index
score 2
3.50
2.00
4.90
6.50
7.60
4.20
5.80
5.30
2.40
1.70
4.90
4.90
5.00
5.30
2.50
2.50
2.40
4.40
2.50
3.60
3.60
5.60
4.00
4.50
4.20
4.10
5.30
2.50
3.70
4.90
5.50
8.20
2.70
2.00
2.00
2.70
5.90
5.30
4.60
6.00
6.20
2.70
4.90
5.10
2.90
4.60
5.50
3.50
2.20
3.40
3.20
3.60
5.10
6.40
5.40
5.30
5.50
2.40
2.50
5.10
7.20
6.00
6.50
2.20
5.30

Risk
Enhanced
Basic
Enhanced
Enhanced
Heightened
Enhanced
Enhanced
Enhanced
Basic
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Basic
Basic
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Heightened
Basic
Basic
Basic
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Enhanced
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Basic
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Basic
Enhanced
Heightened
Enhanced
Enhanced
Basic
Enhanced

Country
Pakistan
Palau
PanamaPapua New Guinea
Paraguay
Peru
Philippines
PolandPortugal
Qatar
Romania
RussiaRwandaSaint Kitts and Nevis
Saint Lucia
Saint Vincent and T. G.
Samoa
San Marino
Sao Tome and Principe
Saudi Arabia
SenegalSerbiaSeychelles
Sierra Leone
Singapore
Slovakia
Slovenia
Solomon Islands
SomaliaSouth Africa
South Korea
South Sudan
Spain
Sri Lanka
State of Palestine
Sudan
Suriname
Swaziland
SwedenSwitzerland
Syria
Tajikistan
Tanzania
Thailand
Timor-Leste
Togo
Tonga
Trinidad and Tobago
Tunisia
TurkeyTurkmenistan
TuvaluUgandaUkraineUnited Arab Emirates
United Kingdom
United States
Uruguay
Uzbekistan
Vanuatu
Venezuela
Vietnam
Yemen
ZambiaZimbabwe

Indexscore 2
6.40
6.60
3.10
7.30
4.90
4.20
4.50
2.40
2.60
4.00
3.00
3.10
4.70
4.30
4.00
2.80
4.40
3.60
4.10
4.40
5.20
3.40
3.40
6.30
3.80
2.20
2.00
5.90
9.10
3.60
2.90
7.10
2.30
3.60
4.50
6.20
5.80
5.70
1.70
2.70
5.20
3.80
5.70
3.80
5.50
5.10
5.70
4.00
3.70
3.70
4.10
5.60
5.20
3.40
5.70
2.20
4.40
3.50
4.60
5.60
4.30
5.60
7.10
6.60
5.90

Risk
Enhanced
Enhanced
Basic
Heightened
Enhanced
Enhanced
Enhanced
Basic
Basic
Enhanced
Basic
Basic
Enhanced
Enhanced
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Basic
Enhanced
Heightened
Enhanced
Basic
Heightened
BasicEnhanced
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Heightened
Enhanced
Enhanced

According to the UNICEF Children's Rights in the Workplace Index. (https://www.childrensrightsatlas.org/countrydata/workplace/) This index shall be updated yearlyIndex Scores are calculated by UNICEF on a 0 to 10 basis – lower scores reflect more fulfilment of child rights and morebasic level of due diligence, while higher scores reflect less fulfilment of child rights and more heightened levels of due
diligence

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