Human Rights Framework Principles

ADR Group Human Rights Framework

Overview and Objective

The ADR Group aims to develop and strengthen its relationship with stakeholders who share the principles of the Ethical Code and promote its adoption throughout their value chain.

Regarding Human Rights, ADR considers it essential to ensure respect and protection in all aspects of its activities, both direct and indirect, to maintain an ethical, safe, and just working environment. This aligns with the commitments made through the "Business for People and Society" Manifesto. Infact, ADR was among the first Italian companies to sign the statement drafted by the UN Global Compact Network Italy in June 2023, aiming to encourage increased private sector engagement in the social dimension of sustainability, going beyond legal obligations for a fair and sustainable future for generations to come.
In this context, selecting partners who share the same priorities is essential to ensure the respect of human rights within the company's sphere of influence and create value for stakeholders.
To raise awareness of human rights, the ADR Group has adopted a Human Rights Framework, based on the United Nations Guiding Principles on Business and Human Rights and the Human Rights Framework Guidelines of the parent company, Mundys. The framework is briefly described below to share principles and communicate expectations to all stakeholders, including suppliers and business partners, for the continuous improvement of their activities and performance.

Scope of Application

The described framework is applicable to the ADR Group and all internal and external stakeholders (such as employees, suppliers, and business partners).
The Policy Commitment, the first element of the framework, represents the company's commitment to respecting human rights and adopting processes that translate this commitment into the culture and operational practices. The commitment to respect human rights is stated in the Group's Code Of Ethics, defining expectations for employees, business partners, and other parties directly connected to its activities, products, or services concerning human rights.
The Group Code Of Ethics, in particular, remarks the commitment to respect human rights included in the Universal Declaration of Human Rights and in the UN Guiding Principles on Business and Human Rights, as well as in the Declaration on Fundamental Principles and Rights at Work. This commitment pertains to areas that arise from the joint consideration of human rights and the Group's activities, as well as international principles and conventions, such as Social Security, Fair Remuneration, Working Hours, Skills Development and Training, Freedom of Association, Health and Safety, Forced Labor, Child Labor, Diversity and Inclusion, Harassment, Respect for Local Communities, and Privacy (detailed in the "DETAILS OF HUMAN RIGHTS AREAS" section).
The framework also includes Due Diligence activities as an integral part of measures to implement ADR Group's commitment to respecting human rights. Human rights Due Diligence is the process of identifying, preventing, mitigating, and addressing negative impacts. This process involves assessing actual and potential impacts on human rights, identifying measures to be taken in response, and monitoring and communicating how these impacts are managed.
Finally, the framework includes a system of rules and mechanisms to provide remedies for individuals affected by a violation of human rights and to rectify any damage caused by such violation.

Detailed Human Rights Areas

In the perspective of protecting human rights throughout the value chain, stakeholders are required to:

Ensure compliance with social security principles for workers, in accordance with national regulations - ILO Convention No. 118 / International Covenant on Economic, Social and Cultural Rights.
Ensure fair and equitable remuneration, in accordance with national regulations on wages and additional benefits, ensuring that employee remuneration is at least equal to that established by national collective agreements and committing to meet higher standards, ensuring fair income and a decent wage (living wage) - ILO Conventions No. 1, 100, and 131
Provide working hours, rest periods, and holidays in line with collective bargaining (where applicable) and industry standards - ILO Conventions No. 1 and 122

Provide to all workers process of teaching/learning useful knowledge for their work, promoting access to training and professional development opportunities to enhance workers' skills so that each can express their potential to the fullest

Ensure the right of workers to participate in collective bargaining in accordance with national laws to define contractual working conditions and regulate the implementation of collective agreements - ILO Conventions No. 87, 98, and 154

Promote an inclusive work environment that protects the health and safety of individuals by identifying and reducing workplace risks, ensuring access to medical care, and providing information on workplace health risks - ILO Conventions No. 148 and 155

Forbid any form of forced, compulsory, or forced labor under threat, including modern slavery - ILO Conventions No. 29 and 105 / Ratification of 18 International HR Treaties: Convention on the Protection of the Rights of All Migrant Workers and Members of their Families

Prohibit the employment of workers below the legal minimum admission age (according to the relevant country's legislation) and/or below 18 years in hazardous work, defined as any work activity that could have a negative impact on the minor's physical, mental, and moral health, as well as their safety and moral principles - ILO Conventions No. 138 and 182 / Ratification of 18 International HR Treaties: Convention on the Rights of the Child

Foster and promote a culture of diversity, inclusion, and equal opportunities at all levels to ensure a concept of equality and inclusion, without distinctions of race, nationality, language, age, sex/gender, gender identity, sexual orientation, ethnicity/culture, religion, physical condition and disability, economic status, political-union opinion, and others - ILO Convention No. 111 / Ratification of 18 International HR Treaties: Convention on the Elimination of All Forms of Racial Discrimination, Convention on the Elimination of All Forms of Discrimination against Women, Convention on the Rights of Persons with Disabilities.

Prevent and contrast any form of abuse in terms of harassment or discrimination or inappropriate behavior in the workplace, ensuring a safe and respectful working environment for everyone - ILO Convention No. 190 / Ratification of 18 International HR Treaties: Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment

Respect and consider the needs, cultures, and rights of local communities and contribute to the socio-economic development of the community in which the company operates - ILO Conventions No. 107 and 169

Ensure adequate safeguards for individuals affected by personal data processing operations and respect the right to privacy - Data Protection and Privacy Legislation; International Committee of the Red Cross (2016) on Personal Data Protection; GDPR Regulation EU 2016/679

Non-observance of the Human Rights Framework Principles

In line with international best practices and applicable regulations, a reporting and management process (whistleblowing) is provided as outlined in specific regulatory instruments, as indicated in the "Reporting Management" procedure of ADR.
Stakeholders who identify presumed violations of principles related to the Human Rights Framework are encouraged to promptly activate the channels outlined in the aforementioned procedure. Any identified violations of human rights in due diligence activities or reported through dedicated mechanisms will be assessed by the ADR Group. In case of confirmation of non-compliance, the company will take prompt and direct action to remedy the negative impacts resulting from the violation.