HUMAN RIGHTS

Respect for human rights in all areas that it operates in is a founding principle for Comer Industries that goes beyond mere compliance with the law and permeates its ethics and business practices. This is why the issue is given a high priority among the values expressed in the Code of Ethics, echoing the principles of the international standards of reference applied by the Company, such as the Universal Declaration of Human Rights and the Ten Principles of the Global Compact.

The Company guarantees the physical and moral integrity of its collaborators, working conditions that respect individual dignity and safe and healthy working environments. Therefore, requests or threats aimed at inciting people to act against the law and the Code of Ethics or to conduct themselves in a manner detrimental to the moral and personal convictions and preferences of others shall not be tolerated. Furthermore, no form of forced, compulsory or child labor is allowed, acknowledging the primary importance of the protection of minors and the repression of any form of labor exploitation. A commitment that is also required from the organizations having a supply relationship with the Company, by signing the Code of Ethics together with the contractual agreements.

In 2022 the risk assessment 17 of sensitive processes within the Group was consolidated based on the Global Compact guidelines, spotlighting the main risk areas to focus preventive measures and training on. In this regard, internal processes at the production sites located in Italy and abroad, with particular attention on the areas of India and China, were analyzed through interviews and document and field audits. Moreover, human rights due diligence involving the entire supply chain was conducted.

Human Rights Due Diligence

The process implements the requirements contained in one of the most advanced pieces of legislation on the subject, the Supply Chain Act issued by the German legislature and in force since 2023. Extended to nearly 400 suppliers in various geographic areas, due diligence was then used to conduct a risk assessment of potential human rights violations.

The assessment explored various areas of the human rights sphere, with particular regard to the fight against forced and child labor and freedom of association and collective bargaining, weighting the risk based on criteria related to the type of process, commodity class, and the country 18 the activity takes place in.

No operations or suppliers with significant risks of incidents of forced labor, child labor or violation of freedom of association have been identified to date.

The extension of due diligence to a broader swath of suppliers is currently underway, and in parallel the development of a plan to mitigate the identified – albeit insignificant – risks that will be implemented during 2023.

The results of this activity and the Company's commitment to implement a concrete human rights program are expressed in the Integrated Human Rights Policy (see section Governance | Responsible business management), defined and published in 2022.

17 - With regard to the scope of the Company Comer Industries S.p.A., in 2023 it will be extended to the other Companies.

18 - For the country risk assessment, account was taken of the indices contained in the report https://www.theglobaleconomy.com/rankings/human_ rights_rule_law_index