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Human Rights Policy

Commitment
Enerveo respects recognised international human and labour rights, and conducts all its operations with honesty,
integrity, respect and openness. We are committed to upholding the human rights of those working for and on be-
half of Enerveo, and to addressing any adverse human rights impacts with which it may be involved.

Enerveo has zero tolerance of Modern Slavery in all its forms such as human trafficking, forced labour, and child
labour in both its business and interested parties.

Objectives
• To provide a safe, secure, inclusive and respectful workplace for all employees and our Interested Parties;
• To support and be fully committed to upholding Human Rights International Standards and Legislation
including Modern Slavery;
• To treat our employees and interested parties fairly and equally, actively avoiding any potential
infringements on the human rights of others, addressing any adverse human rights impacts it might be
involved in immediately and working in partnership with our Interested Parties such as Trade Unions; and
• To ensure strategic and operational risk assessments include the Human Rights of our employees and
Interested Parties so that we continue to maintain an inclusive, respectful and positive working culture.

This will be achieved by:


• Remaining compliant with UN Guiding Principles on Business and Human Rights, the principles
underpinning the UN Global Compact, the International Bill of Human Rights and the fundamental rights set
out by the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work;
• The inclusion of a Modern Slavery Clause in all new contracts requiring suppliers to address the risk of
human rights abuse in relation to Enerveo's activities. We comply with the Modern Slavery Act 2015 and
publish an annual Modern Slavery Statement outlining the actions it has taken to address modern slavery,
available on our company website;
• Assessing our direct and supply chain operations for the risk of modern slavery and human rights abuses
and works to mitigate any risks that may emerge. This includes working with strategic suppliers to ensure
this risk is considered and appropriate action is being taken;
• Promoting personal development, dignity and respect for all our employees and those with whom we have
business relationships, and actively encouraging inclusion and diversity in our business and across our
supply chain;
• Respecting the right of our employees to have their private lives and always seeking to achieve a fair
balance between that right and our legitimate business interests;
• Recognising that all employees have the right to fair remuneration. Enerveo pays employees the real Living
Wage, calculated based on the cost of living, in both the UK and Ireland, and includes a Living Wage Clause
in all new relevant service and works contracts in the UK; and
• Raising Human Rights awareness to our Employees and ensuring understanding of modern slavery and the
potential risks in our direct operations and supply chain.

Responsibilities
• The Executive Board are responsible for the oversight for this policy including the approval of any changes
to the policy. They support the Policy Owner to make sure that the policy is adhered to through awareness
and monitoring of policy implementation.
• This policy applies to all Enerveo employees, contingent workers and people contracted to provide services
to the Company through third parties. All employees must comply with the policy and supporting procedures
and to respect human rights and conduct their business relationships with honesty, integrity and respect.

PO-COR-0009 October 2021


Rev: 1.00
Human Rights Policy
• The Human Resources Director has responsibility for overseeing the application of this policy to those who
work for Enerveo and through management of appropriate Company Consultative Processes. Managers are
responsible for making sure that their teams and colleagues understand and comply with the policy and
supporting procedures as well as complete any relevant training.
• The Executive Committee is responsible for providing an update on activities relating to modern slavery risk
mitigation to the Board.

Luca Warnke Carolyn Reed


Chief Executive Officer Human Resources Director

PO-COR-0009 October 2021


Rev: 1.00

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