LEM GROUP Labour & Human Rights Policy
TABLE OF CONTENTS
1. PURPOSE .............................................................................................................................. 2
2. SCOPE AND EXPECTATIONS .............................................................................................. 2
3. VERSION LOG ....................................................................................................................... 3
4. REFERENCE DOCUMENTS .................................................................................................. 3
5. OUR COMMITMENT .............................................................................................................. 3
5.1 Child/ forced labour.......................................................................................................... 3
5.2 Social dialogue ................................................................................................................ 4
5.3 Equal opportunities and non-discrimination ..................................................................... 4
5.4 Fair wages/ compensation ............................................................................................... 4
5.5 Working conditions incl. hours ......................................................................................... 45.6 Health & Safety................................................................................................................ 46. HUMAN RIGHTS DUE DILIGENCE ....................................................................................... 5
6.1 Internal Audits.................................................................................................................. 56.2 Transparency and Reporting ........................................................................................... 5
7. MEETING OUR HUMAN RIGHTS COMMITMENTS .............................................................. 5
7.1 Responsibility and Oversight ........................................................................................... 57.2 Risk Management ............................................................................................................ 57.3 Supplier Engagement ...................................................................................................... 57.4 Continuous Improvement ................................................................................................. 5

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LEM GROUP Labour & Human Rights policy N° CO.11.10.604.0/ version 0

LEM GROUP Labour & Human Rights Policy

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William Teulery

Natasha Bastien

CO.11.10.604.0

0Throughout this document, the following verbal forms are used:- “shall” or “must” indicate a requirement.
- “should” indicates a recommendation.
- “may” indicates permission.
- “can” indicates a possibility or a capability.
Information marked as “NOTE” is for guidance in understanding or clarifying the associated topic.
1. PURPOSE
At LEM, we are led by a strong purpose: to help customers and society accelerate the transition to asustainable future. Sustainability, at LEM, encompasses Environmental, Social and Governancetopics. We strongly believe that the respect of labour and human rights contributes to reinforce oursocial posture as we care about the impact of our decisions on human rights and preventing harm toany person.
LEM is committed to supporting the principles contained within the Universal Declaration of HumanRights, the OECD Guidelines for Multinational Enterprises, and the ILO (International LabourOrganization) Core Conventions on Labour Standards.
2. SCOPE AND EXPECTATIONSThis Labour & Human Rights Policy (“Policy”) applies to all LEM Group incl. its different subsidiaries,affiliates, establishments worldwide and should be implemented in daily work. In addition, we expect
and support our upstream and downstream supply chain partners, suppliers, and third-party
contractors (consultants, temporary workers, volunteers working on any LEM sites) to comply with theprinciples set forth in this Policy.
LEM expects that any employee, business partners and other parties whose impacts may be directly
linked to LEM’s operations to report any violation to this Policy, to their manager, Human Resources,
Legal Counsel or Speakup line. Whistle-blower process and protection of the whistleblowers aredetailed in the LEM Group Whistleblowing and Investigation Policy.
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LEM GROUP Labour & Human Rights Policy
3. VERSION LOG
Version0Date(yyyy-mm-dd)
2023.11.30

Description of changes
First release

4. REFERENCE DOCUMENTS
Internal
orUCLEM
external
Internal CO.01.00.181.0
Internal CO.01.00.182.0
Internal CO.11.10.101.0
Internal

Document title
LEM Group Environmental Policy
LEM Group Safety Policy
LEM Group Code of Conduct
LEM Group Whistleblowing & Investigation Policy

5. OUR COMMITMENT
LEM adheres to Universal Declaration of Human Rights, the OECD Guidelines for Multinational
Enterprises, and the ILO (International Labour Organization) Core Conventions on Labour Standards.
We also comply with the national laws and regulations in each market we operate in as stated in ourCode of Conduct.
We have identified the following areas of focus related to human rights:
5.1 Child/ forced labour

We commit to respect human being and subsequently children’s rights. We do not tolerate child labour
and work actively against all forms of exploitation of children in any areas of our global operations,facilities, and supply chain. We do not provide employment to children before they have reached thelegal age, as defined by the relevant authorities, and do not compromise on the basic requirements
defined in the UN Convention of the Rights of the Child.
All forms of forced and compulsory labour are against our principles. We do not practice or tolerate
any form of exploitation or forced or compulsory labour, indentured labour, bonded labour, slave
labour or any form of human trafficking, and we expect our suppliers to follow the same principles.

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LEM GROUP Labour & Human Rights Policy
5.2 Social dialogue

We recognize and respect the right of our employees to freedom of association and their rights tocollective bargaining (incl. labour unions). The employment of a worker is not contingent upon thecondition that such worker joins or not an union or be forced to relinquish trade union membership.
Furthermore, union membership shall not be the cause for the dismissal of, or otherwise prejudiceagainst, a worker.
5.3 Equal opportunities and non-discrimination

We are committed to an inclusive work culture. We appreciate and recognize that all people are
unique and valuable and should be respected for their individual abilities. We do not tolerate any formof harassment or discrimination based on gender, religion, race, national or ethnic origin, culturalbackground, social group, disability, sexual orientation, marital status, age, or political opinion.
We provide equal employment opportunity and treat all employees fairly. LEM people leaders shall
only use merit, qualifications, and other professional criteria as the basis for employee-related
decisions regarding, for instance recruitment, training, compensation, and promotion.
5.4 Fair wages/ compensation

We pay every worker an adequate compensation for the work he/she performed. It is sufficient tomeet the worker’s basic needs and their families within the working hours set by national law. We
provide equal pay for equal work and do not tolerate any discrimination related to origin, nationality,religion, race, gender, disability, or age. We comply with the individual national legal standards andthe standards of the national branches or company collective labour agreements.
5.5 Working conditions incl. hours

We treat all employees fairly and honestly regardless of where they work. We recognize the right torest and leisure and therefore comply with local laws, regulations and/or local customs regarding
working hours and overtime.
All employees are entitled to good working conditions, rest breaks, rest facilities, privacy and drinking
water at their place of work. Moreover, they also receive paid holiday leave in accordance with thelegislation of the country where they work in.
5.6 Health & Safety

We do not compromise on a safe and healthy working environment for all employees, and we commit
to offering safe and healthy workplaces in accordance with national legislation. We have H&S
prevention programs and aim at clear objective of zero accidents across all our sites. We seek
continuous improvement of occupational health and safety performance for all our employees. Our
involvement is described in the LEM Group Health and Safety Policy.

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6. HUMAN RIGHTS DUE DILIGENCE
At LEM Group, we are committed to upholding the highest standards of human rights across ouroperations and value chains. The Executive Committee of LEM is responsible for ensuring adherence
to these commitments and our management has responsibility for communicating this Policy,
overseeing their implementation, and holding all employees accountable for compliance. Considering
the impacts human rights violation can cause, LEM, throughout its different experts (and potential
external parties) is engaged in appropriate actions to identify, prevent, or mitigate those impacts in its
value chains.
6.1 Internal Audits

We conduct onsite internal audits looking at human rights/ working conditions and compliance withlocal labour laws to identify, prevent, and mitigate adverse human rights impacts. We might request
the support of external expertise and stakeholder consultations in line with the UN Guiding Principles
on Business and Human Rights.
6.2 Transparency and Reporting

We maintain a transparent approach by regularly tracking and reporting on our human rights efforts,
and ensuring our stakeholders are informed of our progress.
7. MEETING OUR HUMAN RIGHTS COMMITMENTS
To meet our human rights commitments, LEM Group takes the following actions:
7.1 Responsibility and Oversight

Designated roles within our management for ensuring continuous oversight and adherence to thisPolicy.
7.2 Risk Management

We prioritize the most salient risks, continuously improving our due diligence practices throughassessments and remediation strategies.
7.3 Supplier Engagement

Collaborating with suppliers, we work to instill respect for human rights in every aspect of the supplychain.
7.4 Continuous Improvement

Aligned with our values of innovation and integrity, we are dedicated to constant enhancement of ourhuman rights approach, seeking new ways to protect and promote human rights globally.

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