6.3. Human rights

GRI 414-1

The Elia group acknowledges its responsibility with respect to human rights and respects the rights of its employees, customers and consumers with regard to privacy, personal safety, freedom of expression and property rights. The Elia group also assumes responsibility for ensuring that social standards are complied with along the supply chain. For this reason, Elia Transmission Belgium SA/NV and 50Hertz Transmission GmbH are not only members of the United Nations Global Compact, but are also committed to the core labour standards of the International Labour Organization (ILO).

In order to ensure that our business partners also comply with internationally binding rules on human rights - such as the prohibition of forced and child labour - sustainability and ethics are essential components of our evaluation of suppliers and service providers evaluation. Elia Group suppliers commit to a common and binding Supplier Code of Conduct (SCOC), which is a key part of all Elia Group supplier contracts. Suppliers must accept the SCOC when submitting a bid and are obliged to comply with it. Human rights are also included in the clauses of the General Purchasing Conditions.

Further developments in this area are currently being discussed at Group level. For example, in the future, suppliers will be asked about their approach to sustainability, including human rights due diligence, via an external service provider; their responses will be recorded in a balanced score card. Initial proposals for this are expected during the course of 2022. In addition, Elia Group raises awareness of sustainable actions to take in regular discussions with stakeholders across the supply chain, furthering their understanding of compliance with ethical principles and guidelines related to sustainable development.

All procurement at Elia Group is undertaken in accordance with procurement guidelines. These state that procurement (> €100.000) is carried out via the Purchasing Department. A multi-level strategy prevents any misuse and increases control over all procurement-related activities. The ‘ four eyes principle’ is guaranteed at all times. The procurement guidelines, purchasing manual and the General Purchasing Conditions form a framework which aims to prevent corruption across all of our locations.

50HERTZ IN GERMANY

Based on the human rights due diligence requirements anchored in the German National Action Plan (NAP), 50Hertz Transmission GmbH conducted an analysis of its direct and indirect supply chains. As a result, four human rights risks were identified as a priority:

• Occupational health and safety; • Environmental protection and health; • Employment and working conditions; • Freedom of association and expression.

50Hertz Transmission GmbH is examining these as part of an in-depth analysis of the submarine cable value chain, which is complex. Additionally, their construction requires high levels of investment. This analysis includes interviews with 50Hertz Transmission GmbH ‘s direct suppliers in order to determine and track the risk potential of steps along the value chain and to develop suitable measures to address any issues along the latter.

In the spring of 2021, an intensive stakeholder discussion about human rights in the submarine cable supply chain was held with key production and construction suppliers. Suppliers adopt a risk-based approach to mitigate the risk of human rights violations across their supply chains (these include adhering to a mandatory Code of Conduct, undertaking supplier assessments and audits, and the use of a whistleblower system). 50Hertz Transmission GmbH ‘s approach for determining risks in the supply chain was shared during this discussion.

Sustainability-related changes will continue to be embedded into the supply chain management process over the coming years.

SEA CABLE SUPPLY CHAIN

Risk level

Metal Mining (Aluminum/ Lead/ Copper) Metal Smelting Metal Fabrication Metal Manufacturing (Wires/ Rods)

Logistics

Engineering

Raw materials for synthetic material Refined plastics/ chemicals Sea cable production (incl. insulation) Cable Installation Cable Operation Recycling and Disposal*

50Hertz

Direct supplier (contract partner)

Indirect supplier

Increased risk level

Completion level

* Currently deprioritised due to non applicability (end of product life cycle still unknown)