Policy Statement

RBC policy

1. Mission Statement

Van Peperzeel recognises that business activities have an impact on social and environmental issues. Wherever we operate, we seek to avoid causing or contributing to impacts related to workers, human rights, the environment, bribery, consumers and corporate governance, and to facilitate access to remedy.

As a responsible corporate citizen we strive to conduct social and environmental due diligence as established in the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. We have joined the IRBC Metals Agreement, a multi-stakeholder mechanism for implementing individual and collective due diligence; and for jointly developing long-term solutions towards tackling social and environmental risks in global metals supply chains.

2. Our principles

Van Peperzeel respect and uphold at all times the internationally recognised human rights as described in the Universal Declaration of Human Rights, codified in the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights, and articulated in specialised human rights treaties such as the Convention on the Rights of the Child (CRC) and the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), treaties that focus on the needs of particularly disadvantaged, marginalised, and vulnerable groups of people all over the world.

In addition, with regard to labour standards, we specifically commit to uphold the principles concerning fundamental rights contained in the core conventions of the International Labour Organization (ILO) as set forth in its Declaration on Fundamental Principles and Rights at Work.

With regard to environmental standards, we are committed to bring our policies and operations in line with the principles and decisions of international environmental agreements, notably the Convention on Biological Diversity (CBD), the United Nations Framework Convention on Climate Change (UNFCCC) – in particular the 2015 Paris Agreement – and the United Nations Convention to Combat Desertification (UNCCD). We will at all times comply with international and national environmental regulations, standards and best practices.

3. Approach: due diligence, stakeholder engagement, remediation

Van Peperzeel has embraced the six step approach of the OECD Due Diligence Guidance for Responsible Business Conduct. The core features of this due diligence process are as follows:

 the process is aimed at ‘demonstrating’ that our principles are not infringed upon in the course of doing business;

 it consists of:

o Embedding responsible business conduct into policies and management systems;

o Identifying and assessing actual and potential adverse impacts;

o Integrating and acting upon the findings (cease, prevent or mitigate adverse impacts);

o Tracking the effectiveness of the response;

o Communicating how adverse impacts are addressed;

o Providing for or cooperating in remediation when appropriate;

 it applies to Van Peperzeel’s own activities and to its relationships with suppliers and other business relationships.

 it is different from other due diligence activities in that it focuses on adverse impacts on individuals, communities, their environment and on their rights, and not on the risks to the company;

 the process will be reviewed regularly and updated if needed, because of the fact that risks may change over time, which means that due diligence is an ongoing process;

We will collaborate with suppliers and other organisations to increase our leverage to address and mitigate possible adverse impacts. As a last resort, disengagement is an option if a supplier or business partner refuses to prevent impacts after a notice and warning process.

With regard to stakeholder engagement, Van Peperzeel recognises that risks relating to people and the environment require meaningful engagement with internal and external stakeholders. To that end, we engage with both internal and external stakeholders, including our most vulnerable groups, on our responsible business conduct related policies and strategies, and to help us define and understand our (potential) social and environmental impacts.

Stakeholder engagement is particularly important in relation to identifying, assessing and remedying adverse impacts among our stakeholders. In case we cause or contribute to an adverse impact we will endeavour to remedy or co-operate in the remediation of the situation through legitimate processes. Van Peperzeel therefore seeks to have grievance mechanisms in place, both for employees and for other relevant stakeholders. We will report publicly on how complaints have been managed. In situations where we are directly linked to negative human and environmental rights impacts because of activities in our supply chain, we will seek to use our leverage to prevent or mitigate those impacts.

4. Scope

This policy applies to (1) all employees and employees of Van Peperzeel, subsidiaries, entities it owns, business units where company has a controlling interest]. It also applies, as far as is reasonably achievable, to (2) our upstream and downstream supply chain through partners, suppliers and third party contractors.

Ad 1. Employees

Van Peperzeel treats all of our employees with respect and dignity and promote diversity and inclusion in the workplace. Our company policies and procedures adhere to all applicable domestic laws and are consistent with ILO core labour principles, including freedom of association and collective bargaining, non-discrimination, equal remuneration and the elimination of forced labour and child labour.

This is also included in our employee handbook/code of conduct.

Ad 2. Suppliers, contractors and other business partners

Van Peperzeel expects its customers, suppliers and their respective supply chains, and other business partners to uphold the commitments set out in this policy. Our principles, including compliance with this policy, are included in contracts.

We are committed to work with our business partners to implement the OECD Guidelines for Multinational Enterprises to promote supply chain transparency and establish long-term sustainable relationships.

5. Salient risks

Once the risk identification / heat map is finished, Van Peperzeel will include a summary of those human and environmental right that we recognises as likely to be the most salient for our operations and information on how we will account for its actions to meet our

responsibility to respect human and environmental rights. Our intention in the coming year is to gain insight into our chains and to analyse them for (potential) risks. When we have a better view on these (potential) risks, we will update this policy.

Salient environmental and human rights risks and violations are the most severe impacts that a company (or its business relationships) can have on people or the environment. We intend to further validate our areas of severe impact, assess their likelihood and severity in order to prioritise our impacts for risk management and to enable us to address them proactively. Therefore, our areas of severe impact are continuously evolving and are part of our due diligence commitment.

6. Rule of law & conflicting requirements

In all situations and contexts, and in all jurisdictions, Van Peperzeel will comply with applicable laws and international standards, respect the rule of law or this policy, and strive to respect internationally recognised human rights and environmental standards. We will seek ways to honour the principles of internationally recognised human rights and environmental standards when facing conflicting or unclear requirements.

7. Approval and oversight

This policy statement has been endorsed by the board of Van Peperzeel and shall be overseen at board level by Johan van Peperzeel.

Van Peperzeel will report, in our annual management review report, on the progress of the implementation of this policy. The policy will be reviewed periodically to ensure that it continues to meet our targets.