Human Rights Policy_EN

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HUMAN RIGHTS POLICY

As approved by the Board of Directors at 8 July 2021

ABOUT THE WDP HUMAN RIGHTS POLICY

The purpose of this policy is to formally document and outline WDP’s commitments regarding human rights and provides a framework for how WDP will uphold human rights within its operations and throughout its value chain.

HUMAN RIGHTS

Human rights refer to the basic rights and freedom to which all people are entitled, as expressed in the United Nations Universal Declaration of Human Rights. The concept is broad ranging and encompasses civil, political, economic, social and cultural elements. The UN Guiding Principles on Business and Human Rights set out the responsibility of business to respect human rights.

At WDP, we recognise that every person has the right to live a life that is free from fear, harassment and discrimination, and that everyone is entitled to a universal set of human rights such as:

Human rights embedded in WDP’s corporate culture WDP’s value pillars

Right to work

Right to establishing and caring for a family

Right to fair remuneration and equal pay for equal work

Equal opportunity in career advancement

Right to social security

Right to appropriate education

Right to collective bargaining

Right to enjoyment of physical and mental health

Right to rest and leisure from work

Right to safe and healthy working conditions

Right to privacy

Freedom from discrimination

Freedom of thougth, conscience and religion

Vitally Engaged

Additional relevant materialities in WDP’s materiality matrix

Talent Attraction, Retention & Development

Vitally Engaged

Impact by repsonsibility

Sustainable growth

Impact by repsonsibility

Vitally Engaged

Occupational Health, Safety & WellBeing

Corporate Governance & Business Ethics

Employee Diversity & Inclusion

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This policy applies to all WDP group entities, WDP group’s operations, the operations of our suppliers, and other entities with whom we have a business relationship (i.e. business partners, entities in our value chain, clients, any other entity directly linked to our business operations, products or services).

We focus on proactively upholding human rights by:

Fostering healthy and safe work environments #HealthyandSafe Health & Safety

Ensuring fair working conditions for our employees, and fostering fair working conditions for our suppliers’ employees: no forced labour or human trafficking, no child labour, freedom of association, right to collective bargaining #FairWorkingConditions

Contributing to a good worklife balance for our employees through flexible or part-time work and a focus on systematically improving health, physical, and mental well-being

Providing a fair and balanced remuneration and creating the most optimal and favourable conditions of work with a focus on a continuous development of our employees #EqualPayForEqualWork | #WarehouseOfTalent

Promote human dignity, diversity, gender equity and refuse to tolerate any form of discrimination (and certainly not based on personal characteristics such as gender, gender identity, gender expression, sexual orientation, origin, nationality, ethnicity, religion, political, or philosophical opinions, disabilities or physical appearance), bullying, sexual intimidation or other forms of harassment or violence (sexual and non-sexual) #TeamRespect

Procuring services and goods in a responsible and sustainable way, taking into consideration human rights. #RespectOurPartners

Engaging broadly with potentially impacted stakeholders through effective feedback and grievance mechanisms. #SpeakUp

Adopting an efficient risk-based approach to upholding human rights that is appropriately implemented incorporating independent control.

Transparently disclosing our approach to upholding human rights, including risk management actions, breaches, and corrective action.

Employees Code of Conduct

Supplier Code of Conduct

Health & Safety

Talent Attraction & Retention of talent

Job website

Code of Ethics ESG

Supplier Code of Conduct

Grievance Management Procedure

Corporate Governance Charter

Annual Report

We will take the appropriate steps to prevent and mitigate adverse human right impacts and will cooperate to remediate adverse human rights impacts

In all contexts, WDP commits to comply with all applicable laws and respect internationally recognized human rights wherever we operate. We will seek ways to live up with the principles of internationally

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SCOPE COMMITMENT

recognized human rights when faced with conflicting requirements and we will treat the risk of causing or contributing to gross human rights abuses as a legal compliance issue wherever we operate.

DUE DILIGENCE

We strive for zero human rights risk exposure within WDP’s operations and supply chain. We will identify those risks through a proper human rights due diligence embedded within our broader risk management system, while at the same time adopting a risk-based approach that focuses on areas with identified potential for elevated risk of human rights impacts

WDP'S OWN OPERATIONS

WDP ensures that employees are legally entitled to work at WDP and that our employees are aware of their legal rights and obligations at work. We actively engage with our employees to understand their perceptions of our workplace regarding discrimination, harassment and well-being. We are committed to fair and balanced remuneration, including equal pay for men and women in like-for-like roles and to a continues development of our employees. We do not infringe on any employee’s right to collective bargaining.

WDP'S SUPPLY CHAIN

WDP expects its suppliers to comply with all applicable laws and to respect and promote internationally recognized human rights wherever they operate. Our critical suppliers will be asked to formally approve and comply with the Supplier Code of Conduct, while to others these principles are highly recommended. We will assess compliance with the Supplier Code of Conduct by our suppliers throughout all phases of our engagement with them in order to address human rights risk exposure and any potential breaches. We understand that our supply chain extends beyond the suppliers with whom we have a direct contractual relationship and we are willing to work with our suppliers to assess and address human rights risks in their supply chains

WDP'S PROPERTY PORTFOLIO MONITORING AND COMPLIANCE

Across our property portfolio, we strive to collaborate with our customers to identify and address potential human rights risks in their operations.

We will use best endeavors to engage our own employees, our suppliers, and other workers in our supply chain to better understand potential human rights impacts and increase awareness of human rights obligations.

We are committed to maintain a grievance mechanism for stakeholders to raise concerns about potential human rights impacts in our operations and supply chain.

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Our Grievance Management Procedure sets out the different available grievance procedures within WDP #SpeakUp and #ShareYourThoughts.

We will monitor supplier performance in identifying and addressing human rights concerns, with the view to tracking the effectiveness of our own approach to managing human rights risks over time.

Our performance in identifying and managing human rights risks in our value chain will be reported to the Audit Committee and the Board of Directors.

We will take appropriate action to cease or prevent adverse human rights impacts that have been identified or that have been brought to our attention. The appropriate action will depend on whether we have caused the impact ourselves, contributed to the impact, or are linked to the impact through our business relationships. In all cases, our focus will be on mitigating the risk to the individual(s), experiencing the impact and using our leverage to foster continuous improvement.

WDP points out the importance of all individuals to be able to raise issues or concerns without fear of retaliation. Have you noticed a (possible) violation of the Human Rights Policy? Please let us know. We value honesty and concern. Not only will you be protecting yourself, but you will also be putting the safety and integrity of your colleagues, your workplace, your company and all stakeholders involved first.

WDP provides a specific grievance mechanism in order to guarantee that a proper review will be conducted and actions can be taken without any concern about reprisals against the reporting person, always guaranteeing the necessary discretion and confidentiality.

This Human Rights Policy may not cover every situation you face. When in doubt, or when there are questions about a violation, you should seek guidance through WDP’s compliance officer.

We report to the public on our human rights-related commitments, efforts and statements, consistent with this Human Rights Policy, as part of our Annual Report (Corporate Governance Declaration and ESGreporting).

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#NODOUBT
#SpeakUp
GRIEVANCE MECHANISM
PUBLIC REPORTING

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