Respecting human rights

Governance and our human rights policy

Oversight of our human rights approach sits with our Board Sustainability Committee. Our Human Rights Policy and accompanying explanatory note outline the principles that guide our decision-making, actions and behaviours. Expectations relating to human rights are also included in our Code of Business Conduct. and our Code for Responsible Sourcing, which defines our expectations for suppliers.

We aim to respect and uphold human rights throughout our operations and supply chains, and we work to avoid activities that could directly or indirectly negatively impact the rights of employees, contractors, supply chain workers, Indigenous Peoples, or members of the communities where we operate. Our expectation is that all individuals connected to our operations are treated safely, respectfully and with dignity.

Committed to international standards

We seek to align our approach with internationally recognised human rights standards, including the Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, the International Labour Organization’s Declaration (ILO) on Fundamental rights at work and other relevant conventions. Where applicable, we also reference the Voluntary Principles on Security and Human Rights (VPSHR) and international humanitarian law.

We aim to prevent, mitigate and address potential or actual adverse human rights impacts through ongoing due diligence processes. This includes impacts that may affect employees, contractors, workers within our value chain, communities, and others whose rights may be adversely impacted by our activities.

We work to apply good practice approaches informed by the UN Guiding Principles on Business and Human Rights (UNGP’s), the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the International Financial Corporation (IFC) Performance Standards, and other applicable voluntary standards. We are a member of ResponsibleSteel^TM and align with its principles and certification processes.

We recognise the rights of Indigenous Peoples’, including their cultural heritage and connection to land, water and resources. We are committed to consulting and cooperating in good faith with Indigenous Peoples with the objective of obtaining free, prior and informed consent (FPIC) for new projects and significant changes to existing projects where significant adverse impacts may arise. We do not tolerate threats, intimidation, violence, surveillance or attacks-whether physical or legal-against human rights defenders related to our operations.

Modern slavery

We take steps designed to prevent modern slavery in all its forms. We do not tolerate child labour, forced, compulsory, or bonded labour, human trafficking, or any other form of modern slavery within our own operations, value chain or investments.

We comply with the UK Modern Slavery Act 2015, and our Modern Slavery Statement describes the measures we take to identify, prevent, and address modern slavery risks across our operations and supply chain.

Due diligence framework

We are committed to implementing ongoing human rights due diligence, tailored to our industry, operating context and organisational structure. This includes identifying actual and potential human rights impacts-supported by human rights saliency assessments, aligned with recognised good practice. Impacts are assessed and prioritised using he UNGP’s criteria of severity.

In 2023, alongside updating our Human Rights Policy, we completed a corporate-level saliency assessment. Priority areas were identified and integrated into core business processes, including human resources, social performance and supply chain management. This integration is supported by continuous improvement. Examples include the 2025 update to our External Stakeholder Engagement Procedure, publication of our Grievance Procedure, updated human rights training for employees and new training for suppliers and security personnel.

Responsible sourcing

We are strengthening our Responsible Sourcing Policy and Responsible Sourcing Code to clarify expectations for suppliers and align with applicable regulations and good-practice standards. We assess human rights considerations within our business relationships using risk assessment tools, KYC procedures, audits, monitoring plans, certification schemes such as ResponsibleSteel^TM, and contractual provisions.

Implementation and monitoring

We monitor adherence to our human rights and environmental standards using a structured, risk-prioritised framework that combines internal oversight with independent external assessments. The Group level Saliency Assessment identifies and prioritises our most significant human rights risks, guiding targeted mitigation actions and management efforts. Human rights risks and controls are also incorporated into Compliance processes and reviewed regularly.

Mandatory training, compliance certificates and a bi-annual Compliance Certification process reinforce implementation, Relevant findings are reported to the Group Audit and Risk Committee.

We conduct ESG due diligence on suppliers and maintain a grievance mechanism with human rights as a standalone category, enabling the identification and investigation of potential breaches. Under this mechanism, concerns are assessed by local grievance committees, and based on their materiality and criticality, high-risk concerns are promptly escalated to corporate oversight functions, while lower-risk concerns are assigned to local investigators.

Grievance and remedy

Where human rights concerns arise, we are committed to supporting appropriate remedy. We may engage individually or in cooperation with business partners, and we work with legitimate judicial or non judicial processes where needed.

Our Grievance Procedure guides the receipt, assessment, investigation and resolution of grievances. A global reporting mechanism–via email, post and telephone hotlines available in the official languages of our operating countries–provides channels through which individuals or stakeholders may raise concerns related to human rights or environmental impacts.

Reports are handled confidentially in accordance with data protection requirements and recognised grievance handling practices. Reports may be submitted anonymously, and retaliation against those raising concerns is not tolerated.