Human Rights Policy Statement

Purpose and scope
The purpose of this policy is to describe the commitments and responsibilities of Ombrascents and Ombrascents’ expectations towards its business partners with regards to embedding respect for human rights across Ombrascents’ activities and value chain. We are committed to making a positive difference by upholding the highest standards of human rights in everything we do.

The policy outlines Ombrascents’ commitment to respecting human rights and implementing ongoinghuman rights due diligence. This process is designed to identify, prevent, mitigate, and account for the company's impacts on human rights, including mechanisms for remedying any adverse human rights impacts that Ombrascent has caused or contributed to. This policy applies to all Ombrascent entities and its employees. The minimum human rights requirements for Ombrascents’ business partners are detailed in the Ombrascent Supplier Code of Conduct. Ombrascent encourages and supports its business partners to continually improve and develop their practices beyond these minimum requirements to meet the human rights standards and expectations set out in this document.

Ombrascents Human Rights Commitment:
This Human Rights policy is developed to express our commitment in respect to internationally recognized human rights standards:
- The universal declaration of Human Rights (adopted by the UN)
- The conventions of the International Labour Organisation (ILO)
- OECD guidelines for Multinational Enterprises
- The UN Guiding Principles on Business and Human Rights
Ombrascents strives to respect these standards. This policy describes our values and it clearly outlines and
defines our policies, and processes in place to identify, prevent, mitigate and account for how we address human rights impact.

Risk management
At Ombrascents, we are dedicated to proactively managing human rights risks within our value chain. To ensure we identify and address potential human rights risks effectively, we conduct risk analyses on an ongoing basis, with a detailed review performed annually. This process allows us to implement appropriate measures to mitigate any identified risks.

In addition to our annual assessments, we also carry out ad hoc reviews whenever significant changes occur within our business. Examples of such significant changes include expansion into new markets, the introduction of new products, or modifications in business operations.

Salient issues
In our latest comprehensive risk analysis, we have identified our salient issues. Salient issues are the areas we have identified as those human rights at risk of the most severe negative impact on people through our activities or business relationships. The list of salient issues is informed by the human rights risk analysis conducted. Our salient 9 issues are:
- Equality and non-discrimination
- Clean and healthy environment
- Occupational health and safety
- Right to an adequate standard of living
- Livelihood and access to resources
- Freedom of association and collective bargaining
- Fair and just working conditions
- Child labor
- Forced labor, modern slavery and human trafficking

Equality and non-discrimination
We are dedicated to treating all employees and value chain workers equally and fairly. We strictly prohibit any form of discrimination based on gender, race, color, religion, age, disability, sexual orientation, gender identity or expression, national or ethnic origin, political opinions, social or marital status, family medical history, or any other status protected by applicable laws. Our commitment ensures that all aspects of employment, including hiring, training, promotion, and dismissal, are conducted without bias, fostering an inclusive and respectful workplace for everyone.

Clean and healthy environment
We are committed to carrying out our own activities and those within our value chain without negatively impacting the health and well-being of communities.
Occupational health and safety We are committed to providing a safe and healthy workplace for our own employees and value chain workers and comply with applicable health and safety laws and regulations.

Right to an adequate standard of living
We recognize and respect the economic, social, and cultural rights of all people. This includes, but is not limited to, the rights to adequate food, housing, education, health, social security and social protection, participation in cultural life, water and sanitation, and work.

Livelihood and access to resources
We are committed to ensuring that our own and value chain activities do not negatively impact people's livelihoods or access to essential resources like land and water. We strive to source materials sustainably and ethically, safeguarding both the environment and the well-being of local communities.

Freedom of association and collective bargaining
We respect and recognize the right of each employee and value chain workers to negotiate collectively, to create or join the union organization of their choice and without penalty, discrimination, or harassment.

Fair and just working conditions
We are committed to providing fair and just working conditions for all employees and workers throughout our value chain. We ensure that all individuals are treated with respect and dignity, offering fair wages, reasonable working hours, and access to necessary resources and support.

Child labor
We prohibit child labor in all aspects of our operations and value chain. For the purposes of employment, we define a “child” as anyone under the age of 15. However, if national or local law sets a higher mandatory school leaving age or minimum working age, the higher age will apply. We adhere to these legal requirements and do not hire individuals under the applicable mandatory minimum age.

Forced labor, modern slavery and human trafficking
Ombrascents will not engage in or support the use of any form of modern slavery, forced labor or human trafficking. This involves forced labor without proper compensation, working under threat or penalty, and being subjected to dehumanizing treatment.#

Risk management and preventive measures
We have a set of preventive measures concerning our own business area and our direct suppliers to safeguard and promote human rights along the value chain and minimize human rights risks. We continuously review and improve those preventive measures in light of our ongoing risk management process. Key preventive measures include:
- E-learnings for our employees educate them about Ombrascents’ commitment to human rights;
- Supplier Code of Conduct that outlines Human Rights standards expected from our suppliers.

We expect our suppliers to respect and adhere to the same philosophy in the management of the rest of the value chain.
- Responsible Sourcing Policy that integrates human rights and environmental considerations
into our procurement practices;
- Onboarding our suppliers on SedEx to monitor and assess our suppliers compliance with
Human Rights Standards and identify areas of improvement;
- Third-party auditors to conduct SMETA, compliance audits, or virtual assessments at highrisk suppliers;
- Supplier Business Reviews to discuss audit findings (SedEx) and Ecovadis results and support them with corrective actions to manage issues and improve performance Complaints procedure.

Complaints can be submitted through our whistleblower tool: http://whistleblower.ombrascents.com, which acts as the initial point of contact for all types of grievances. This notification mechanism and complaints procedure is designed to be user-friendly, ensuring that all stakeholders, including employees, suppliers, and customers, can easily report their concerns. Complaints are immediately escalated and directed to the Integrity Committee, who are responsible for investigating the reported issue and ensuring that appropriate remedial actions are taken. Findings from our complaints procedure and risk assessments are incorporated into our review process to ensure continuous improvement.

Ombrascents guarantees the confidentiality of all complaints and ensures that the identity of the complainant is protected. We are committed to safeguarding our stakeholders from any form of retaliation or disadvantage as a result of submitting a complaint.
Remedial action At Ombrascents, we are committed to addressing any human rights identified within our operations or value chain. The effectiveness of our remedial actions is reviewed annually and on an ad hoc basis if there is a changed risk situation, such as the introduction of new products. Remedial measures are
updated without undue delay as necessary.

Documentation and reporting
Ombrascents is committed to continuously improving our human rights strategy and practices. We regularly review and update our policy and procedures to ensure they remain effective and aligned with international human rights standards.

This policy statement is publicly available and communicated to all employees and suppliers. We welcome feedback and encourage open dialogue to enhance our human rights efforts.