Sustainability
Policies

Information about this document
Identification of the Policy
Category of the Policy
Implementing Section of the Code of
EthicsRelationship with other Policy

ESG Policies (COPP_SUS_PL_01_ESG Policies)
Organic policy
N/A

15_COMA_ACP_PL_00_EN_ Anti-Corruption Policy
11_COMA_ADP_PL_01_EN
PolicyAnti-Discrimination

06_COMA_ERD_pl_00_Employees
Duties Policy

Rights07_COMA_ICT_PL_00_EN_Use
and Communication Technology

Information

of

and

08_COMA_SRP_PL_00_PT_Selection and Recruitment Policy.
COPP_PRIP_PR_00_Privacy Policy
COPP_ITC_PL_00_Information Security Policy
COPP_ITC_PR_01_User_Info_Sec_Pro

Other related business Policy
Werfen technology centers and affiliates
at which it is targetedBusiness unit affectedSustainability Principles
All
All those making up Werfen

Recipient personnel

All members of Werfen

Person in charge of implementation

VP of Sustainability

Party in charge of oversightEnvironmental, Compliance, Human Resources of each technology center or affiliate.

Main person in charge of supervision
Compliance Delegate
Approval date
Date of entry into force

Internal Audit department
N/A
27th December 2023
27th December 2023

2

Approval signatures

In SAP GRC (Chairman, CEO and CFO)

Version Control and Document Classification
Versions
VersionValid from001

27th December
2023

Document classification

AuthorModifications

VP Sustainability

CreationInternal and external use

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Contents
1. Purpose ................................................................................................................................... 5
2. Scope ...................................................................................................................................... 5
3. Definitions ................................................................................................................................ 5
4. Specific policy content ............................................................................................................... 6
4.1 Human Rights ..................................................................................................................... 6
4.2 Labour Rights / Decent Work ................................................................................................ 7
4.3 Environment ....................................................................................................................... 8
4.4 Anti-Corruption ................................................................................................................. 10
5. Communication mechanism for this policy .................................................................................. 10
6. Policy review and modifications mechanism ................................................................................ 10
7. Breaches of this policy ............................................................................................................. 114

1. Purpose
The purpose of this Policy is to establish a common, uniform and global framework containing the basicorganizational principles and guidelines that Werfen has in place concerning the following areas (some of them
being further developed in specific implemented policies, as explained below):
A)
B)
C)
D)

Human Rights
Labour Rights / Decent work
Environment
Anti-Corruption

This policy and the related procedures have been developed to:••

Be aligned with the United Nations Global Compact (UNGC) principles and ESG ratings requirements.
Be aligned with the Sustainability Principles of Werfen.

2. Scope
This policy is applicable to all Werfen companies, including all employees, as well as contractors, vendors, andvisitors within our premises, online platforms, or events. This policy is effective from the original date of issue
onwards until further notice and is not retroactive.
To the extent permitted or expressly recognized by local laws, compliance with this policy is obligatory. However,should any technology center or affiliate find that they cannot fully comply, they must communicate this
immediately to Werfen headquarters (Sustainability Department) in order to develop and approve an action plan
to ensure future compliance and prevent or mitigate damages, if any.

3. Definitions
The terminology used in this policy needs to be understood in the most common sense of the words used. For
concepts that need extra clarification, see the established Werfen definition below:
•
•
•
•
•
•
•

ESG: Environmental, Social and Governance.
ESG Policies: Sustainability policies
UNGC: United Nations Global Compact.
Sustainability Principles: Those set forth in Werfen’s Sustainability Policy as published from time to timeon Werfen’s website.
GRC: Governance, Risk and Compliance.
CEO: Werfen Chief executive officer.
CFO: Werfen Chief financial officer.

54. Specific policy content
4.1 Human Rights

1.

Freedom of expression

We value freedom of expression as a fundamental right that enables individuals to share diverse perspectives,
ideas, and opinions. We recognize that open and respectful communication promotes learning, innovation, andinclusion. Therefore, we commit to upholding the following principles:• We do not censor or punish individuals for expressing their opinions, beliefs, or ideas, except when such
expression violates applicable laws or ethical standards.

• We respect the dignity and rights of all individuals, regardless of their race, ethnicity, gender, gender identity,
religion, sexual orientation, or other personal characteristics.

• We provide opportunities for individuals to express themselves freely, including through forums, surveys,
feedback mechanisms, or other means.

The content of this section is aligned with the core organizational values of Werfen as defined in section 2 ofWerfen’s Code of Ethics, and is further developed and regulated in Werfen’s Anti-Discrimination Policy.

2.

Access to water and sanitation

We value access to water and sanitation to all Werfen companies, including all employees, as well as contractors,
vendors, and visitors within our premises or events, as a basic human right that enables individuals to live indignity and health. We recognize that lack of access to safe water and sanitation can lead to illness, poverty,
and social exclusion. Therefore, we commit to upholding the following principles:• We ensure that all individuals within our organization have access to safe, clean, and sufficient water for
drinking, cooking, cleaning, and personal hygiene.

• We ensure that all individuals within our organization have access to adequate sanitation facilities that
protect their privacy, dignity, and health.

• We ensure that all individuals within our organization are aware of the importance of water and sanitation
for their health and well-being, and are encouraged to adopt good hygiene practices.

3.

Digital security/privacy

We value digital security and privacy as essential components of our information management practices thatsafeguard our data, systems, and reputation. We recognize that digital security and privacy risks can lead tofinancial loss, legal liability, and harm to individuals and society. Therefore, all Werfen employees must comply
and must ensure that any third parties doing business with Werfen comply at all times with our Privacy Policy
and applicable procedures, as well as with all applicable laws and regulations on Privacy and Data Protection.
For more information, please refer to Werfen’s Privacy Policy as published from time to time on Werfen’s website.
In line with the above, all employees and directors across the organization are strictly bound by rules concerning
the use of IT resources, as covered by our Compliance Manual and further developed in Werfen’s IT Policies.

4.

Gender identity equality

We value gender identity equality as fundamental human rights that promote social justice, economic prosperity,and sustainable development. We recognize that gender identity-based discrimination, harassment, and violence can undermine individuals' dignity, well-being, potential, and create systemic barriers to inclusive andequitable societies. Therefore, we commit to upholding the following principles:6• We promote gender identity equality in all aspects of our organizational culture, policies, programs, andcompany activities.

• We respect human rights, including right to live free from violence, exploitation, and discrimination, and theright to participate fully and equally in all company activities.

• We address gender identity-based discrimination, harassment, and violence in the workplace, through prevention, response, and accountability measures.

• We ensure that employee's voices and perspectives are heard, valued, and represented in our decisionmaking processes.

The content of this section is aligned with the core organizational values of Werfen as defined in section 2 ofWerfen’s Code of Ethics, and is further developed and regulated in Werfen’s Anti-Discrimination Policy.
4.2 Labour Rights / Decent Work

5. Forced labor
We recognize that forced labor is a serious human rights violation and a form of modern slavery. Therefore, we
commit to upholding the following principles to all Werfen companies, including all employees, as well as contractors, vendors, and visitors within our premises or events:• We do not use or tolerate any form of forced labor, including bonded labor, debt bondage, human trafficking,or other forms of coercion or exploitation.

• We comply with all applicable laws and regulations related to child labor, including minimum age requirements for employment.

• We ensure that all workers are free to resign voluntarily their employment at any time they choose, without
fear of punishment or retaliation.

• We engage in responsible recruitment practices, ensuring that all workers are recruited ethically and are
not subject to any form of coercion or deception.

• We aim to refrain from establishing business relations with people or entities (either governmental or private)that do not comply with national and international regulations on the prevention of all forms of modern
slavery.

Werfen’s Compliance Manual and, in particular, our Selection and Recruitment of Personnel Policy are alignedwith the aforementioned ethical standards.

6. Illegal child labor

Our organization is committed to preventing and eliminating all forms of illegal child labor to all Werfen companies, including all employees, as well as contractors, vendors, and visitors within our premises or events.
We recognize that illegal child labor is a serious violation of human rights and a form of exploitation that canharm the health, education, and well-being of children. Therefore, we commit to upholding the following principles:• We do not use or tolerate any form of illegal child labor in our operations and supply chains, including forced
or compulsory labor, trafficking, or other forms of exploitation.

• We comply with all applicable laws and regulations related to child labor, including minimum age requirements for employment.

Werfen’s Compliance Manual and, in particular, our Selection and Recruitment of Personnel Policy are alignedwith the aforementioned ethical standards.

77. Non-discrimination in respect of employment and occupation
Our organization seeks to foster a positive non-discriminatory environment in which equal opportunities anddiversity and inclusion are protected and promoted for all employees, while also complying with current applicable legislation and international best practices.

• We aim to establish equal treatment and opportunities for all employees and to ban any discrimination on
the grounds of race, gender identity, gender, religion, age, sexual orientation, marital status, ideology,
political opinion or any other ground prohibited by applicable law.
The content of this section is further developed and regulated in Werfen’s Anti-discrimination Policy.

8. Safe and healthy working environment
Our organization is committed to providing a safe and healthy working environment for all employees, contractors, and visitors. This policy outlines our commitment to preventing workplace injuries and illnesses and promoting the well-being of our workforce.
We recognize that a safe and healthy working environment is essential for the well-being of our employees andthe success of our business. Therefore, we commit to upholding the following principles:• We comply with all applicable laws and regulations related to occupational health and safety.
• We assess and manage workplace hazards to prevent workplace injuries and illnesses, including physical,
chemical, biological, and psychosocial hazards.

• We provide employees with the necessary resources and training to enable them to work safely and toprevent accidents and injuries.

• We encourage employees to report any safety or health concerns and we investigate all incidents and nearmisses to identify and address root causes.

• We maintain a workplace culture that prioritized ergonomic safety and health and promotes open communication and collaboration on safety issues.

• We regularly monitor and review our occupational health and safety performance and strive for continuous
improvement.

9. Working conditions (wages, working hours)
Our organization is committed to providing fair and equitable working conditions for all employees. This policy
outlines our commitment to ensuring that employees are compensated for work in accordance with applicablelaws and regulations.
We recognize that fair and equitable working conditions are essential for the well-being of our employees andthe success of our business. Therefore, we commit to upholding the following principles:• We comply with all applicable laws and regulations related to wages and working hours.
• We provide fair wages and benefits that are commensurate with employees' skills and experience.
• We provide employees with rest breaks, time off, and overtime pay in accordance with applicable laws andregulations.

• We regularly review and adjust our wage and hourly policies to ensure that they are fair, equitable, andcomply with applicable laws and regulations.

4.3 Environment

As further explained in Werfen’s Sustainability Policy, we believe in the importance of sustainability for people(socially), our planet (environmentally) and our prosperity (economically). Therefore, we firmly believe in theimportance of operating our business without compromising the needs of our planet and our future generations.

8For this reason we follow certain guidelines and principles aimed at ensuring respect for the environment, asdetailed below.

10.

Climate change

Our company recognizes the urgent need to take action to address climate change. This policy outlines ourcommitment to reducing our greenhouse gas emissions, promoting sustainable practices, and contributing to a
low-carbon economy.
We recognize that addressing climate change requires a collective effort from governments, businesses, andindividuals. Therefore, we commit to upholding the following principles:• We measure the estimation of our greenhouse gas emissions and set reduction targets.
• We adopt sustainable practices in our operations, such as reducing energy consumption, minimizing waste,
and promoting sustainable transportation where applicable.

• We prioritize the use of renewable energy sources and energy-efficient technologies in our operations.
• We support policies and initiatives that promote a low-carbon economy and a sustainable future for all.
11.

Water

This policy outlines our commitment to responsible water management, reducing our impact on the environment,
and ensuring the sustainability of our water resources.
We recognize that responsible water management requires a collective effort from governments, businesses,
and individuals. Therefore, we commit to upholding the following principles:• We promote sustainable water management practices, such as water conservation, water reuse, and watershed protection.

• We support policies and initiatives that promote responsible water management and conservation.

12.

Air quality

Our company recognizes the importance of maintaining clean air for the health and well-being of our employees,
customers, and the broader community. This policy outlines our commitment to reducing our impact on air
quality and promoting sustainable practices.
We recognize that responsible air quality control requires a collective effort from governments, businesses, andindividuals. Therefore, we commit to upholding the following principles:

•
•
•

13.

We aim to reduce our emissions of air pollutants wherever possible, including particulate matter, nitrogenoxides, and volatile organic compounds through the implementation of responsible practices and technology.
We comply with all applicable laws, regulations, and industry standards related to air quality control.
We support policies and initiatives that promote responsible air quality control, including the developmentof clean energy sources and the adoption of clean technologies.

Waste

Our company recognizes the importance of managing waste responsibly to protect the environment and promotesustainable practices. This policy outlines our commitment to reducing waste generation, promoting recycling,
and disposing of waste in a safe and responsible manner.
We recognize that responsible waste management requires a collective effort from businesses, governments,
and individuals. Therefore, we commit to upholding the following principles:

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•
•
•
•

14.

We minimize the generation of waste wherever possible, through the adoption of sustainable practices
and the use of environmentally-friendly materials.
We promote recycling and the reuse of waste materials wherever possible, through the implementation of
responsible recycling programs.
We dispose of waste in a safe and responsible manner and in compliance with all applicable laws, regulations, and industry standards.
We support policies and initiatives that promote responsible waste management, including the development of new technologies and the adoption of sustainable practices.

Energy and resource use

Our company recognizes the importance of minimizing our energy and resource use to reduce our environmental
impact and promote sustainable practices. This policy outlines our commitment to gradually promoting energy
and resource efficiency throughout our facilities.
We recognize that responsible energy and resource management requires a collective effort from businesses,
governments, and individuals. Therefore, we commit to upholding the following principles:• We strive to minimize our energy and resource use through the adoption of sustainable practices and theuse of energy-efficient technologies wherever possible.

• We promote the use of renewable energy sources wherever possible to reduce our dependence on fossil
fuels.

• We support policies and initiatives that promote responsible energy and resource management, including
the development of new technologies and the adoption of sustainable practices wherever possible.

4.4

Anti-Corruption

15. Anti-Corruption
Werfen does not allow any of its directors, administrators, employees or collaborators to receive, request or
accept, whether directly or through an intermediary, any unjustified benefit or advantage as remuneration inorder to unduly favour the other party in the acquisition or sale of goods, in the contracting of services, or inany commercial relationship.
Furthermore, it is prohibited for any member of Werfen, whether directly or through an intermediary, to offer
or grant to directors, administrators, employees or collaborators of another company any unjustified benefit oradvantage as consideration to obtain, retain, or guarantee an unfair advantage within the framework of acquiring
or selling goods, contracting services, or in any commercial relationship.
For more information, please refer to Werfen’s Code of Ethics and Anti-Corruption Policy published on Werfen’s
website as updated from time to time.

5. Communication mechanism for this policy
In order to ensure that the content of this policy is known to, and applied by, Werfen employees, it will beavailable to all employees through the SAP tool GRC. The VP Sustainability is responsible for communicating
this policy.
Any queries that arise when reading or applying this policy can be directed to VP Sustainability by e-mail at:
sustainability@werfen.com

6. Policy review and modifications mechanism
This policy has been approved by the Chairman, CEO and CFO.

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No fixed term has been set for reviewing this policy. It will be reviewed whenever one of the following situations occurs:•

A change in the applicable national and/or international laws that make it advisable to adapt this policy.
This will be identified and communicated by Werfen headquarters (Corporate Legal Department)•

A change to the Code of Ethics, vision, or mission. This will be identified and communicated by Werfen
headquarters (Compliance Department).

•

A material incident is identified in Werfen’s internal control. This will be identified and communicated byeither the external auditors or Werfen headquarters (Internal Audit Department).

All reviews and any modifications will be documented in the version tracker on the first page of this policy.

7. Breaches of this policy
Compliance with the content of this policy is mandatory, as indicated in the Scope section, for all Werfen
companies, including all employees, contractors and vendors, as well as all visitors within our premises, online
platforms, or events. Compliance with this policy will be monitored by Werfen headquarters (Internal Audit
Department).
As a company, Werfen provides a variety of mechanisms and channels by which any concerns, issues orviolations of the ESG Policies can be brought to the attention of Werfen including but not limited to the VP of
Sustainability, our Ethics Channel, to our Legal Department, to our Werfen affiliates’ Human Resources
Departments, or any member of management.

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