Human Rights

MYTILINEOS operates on the basis of its firm commitment to zero tolerance of human rights violations, which is implemented both by not participating (directly, passively, or implicitly) in such violations, and by avoiding all transactions and contacts with third parties, in the countries where it operates, that may have caused or are reasonably suspected to be involved in the creation of conditions that may cause human rights violations. This commitment is in accordance with the main pillars of MYTILINEOS’ Human Rights Policy, its “Code of Business Conduct” and its “Suppliers / Business Partners Code of Conduct”.

MYTILINEOS is committed to the first 6 Principles of the United Nations Global Compact, which are based, inter alia, on the internationally recognised principles of human rights protection as set out in the International Declaration of Human Rights (UDHR). The specific commitment of MYTILINEOS to monitor and publish its impact in this area, as well as its Code of Business Conduct and Suppliers / Business Partners Code of Conduct addressed to all hierarchical levels of the Company and to its suppliers/collaborators, promote the respect and protection of Human Rights by reducing the likelihood of incidents in the Company’s work environment.

Impacts

Actual positive impacts

Based on its control mechanisms, the Company has not recorded any cases of violation of the rights of its employees, nor of the rights of its local communities, while at the same time it does not participate in any form of child or forced labour (modern slavery). The Company's policy in this regard reinforces the promotion of respect and protection of Human Rights, both within its internal environment and in its sphere of influence.

Potential negative impacts

Due to the size of MYTILINEOS, its diverse business activities and its international presence in countries with developing economies, negative impacts on human rights are recognised as a possibility, which may arise under certain circumstances, within the large number of its business partners and suppliers due to potentially incomplete, imperfect or ongoing processes, policies, codes of conduct or as a result of different cultures, as well as other parameters such as (culture, mindset, beliefs, customs, morals, depending on the country of operation, etc.). Therefore, exercising control over the precise application of the Company's protective and preventive framework against such phenomena becomes of primary importance and an ongoing objective to be achieved by MYTILINEOS.

Major risks

Due to its activities in developing countries abroad, primarily through its Sustainable Engineering Solutions (SES) and Renewables & Storage Development (RSD) Business Units, MYTILINEOS identifies risks related to human rights, both within its working environment and in the operating environment of its key suppliers and partners. Potential risks include activities related to child labour, a culture of corruption, inequalities in the workplace, restriction of human rights at the level of local communities, etc. These risks may affect the Company's financial, human, and social capital, through possible impacts on its reputation and social licence to operate, while it may also lead to legal sanctions and the undertaking of emergency measures beyond those required by normal business conditions.

• MYTILINEOS monitors relevant labour legislation (national, European, ILO), including reports on respect for human rights, working conditions and child labour, and is in full compliance with collective and relevant international conventions.
• The Company's direct employees are covered by company or collective labour agreements where applicable and participate through their representatives in health and safety committees.
• The Company, through its basic mechanism for reporting violations of the Code of Business Conduct and the Suppliers / Business Partners Code of Conduct provides the opportunity for its employees and suppliers/business partners to raise any concerns and incidents of Human Rights violations.
• With regard to its activities in developing countries, MYTILINEOS takes all necessary measures to ensure compliance with the law.
• The first formal assessment of MYTILINEOS' key suppliers on sustainability issues, including the protection of Human Rights, took place.

• The Company implemented a special training for its executives, through the e-learning process, about Human Rights, during which 211 employees, following 730 in 2021, were informed about respect for freedom of association, the elimination of all forms of forced or compulsory labour, the recognition and elimination of child labour and the elimination of any discrimination related to the workplace and employment.
• No incidents of human rights violations were reported achieving the Company's long-standing goal of zero tolerance for human rights violations.
• No areas were identified where the deficiencies recorded could jeopardise the protection of Human Rights in the Company's activities.