Responsible Sourcing Policy

1. Introduction

At ACCUMIN, we are committed to operating in accordance with internationally recognized principles in the areas of human rights, environmental management, business integrity and anti-corruption. These values unite and guide us. They also reflect our commitment to the Ten Principles of the United Nations Global Compact.

These values include the way we work with our suppliers throughout our supply chain. This document sets out our Responsible Sourcing Code, which provides process and performance requirements applicable to all suppliers working with ACCUMIN. Through its implementation, we aim to achieve measurable and tangible improvements in our supply chain. We count on the commitment and support of our suppliers for continuous improvement, which will help us achieve this goal.

We appreciate all of our suppliers' efforts to help us achieve our goal of sourcing our products and services responsibly and creating sustainable value throughout our supply chain.

ACCUMIN believes that our joint efforts to establish a more sustainable supply chain will provide ample opportunities to strengthen our business relationships and create value for our respective companies.

We expect all our suppliers to implement the Responsible Sourcing Code diligently and transparently. In particular, we urge them to:

• Implement processes or leverage existing systems that enable suppliers to identify, avoid or mitigate risks and impacts, both in their own operations and in their business relationships.
• Evaluate its operations and supply chain against the Responsible Sourcing Code or any similar standard based on the United Nations Global Compact.
• Communicate and interact actively with employees, suppliers and key stakeholders so that they can identify potential concerns.

Scope of application

This policy applies to all suppliers or temporary employment agencies contracted by an ACCUMIN Group company in all countries where it operates.

Likewise, the Responsible Sourcing Code applies to companies or professionals (subcontractors) who are also contracted by a supplier to provide services or supplies to the ACCUMIN Group.

3. Compliance with this Responsible Sourcing Policy

By doing business with ACCUMIN, Suppliers acknowledge that they have reviewed, understand and agree to comply with this Responsible Sourcing Policy. Suppliers further agree to apply, where applicable, the terms and guidelines set forth in this policy in the provision of their services and delivery of goods, ensuring that their operations comply with ACCUMIN's purchasing standards and ethical requirements.

ACCUMIN's Finance Directors are responsible for ensuring a thorough understanding of ACCUMIN's Responsible Sourcing Policy and its principles.

They shall actively monitor compliance with the policy and take the necessary measures to monitor and ensure compliance, ensuring that all suppliers comply with its requirements.

4. Human Rights

The scrupulous respect for Human Rights and Public Freedoms as set forth in the national and international legislation in force and always in accordance with the Universal Declaration of Human Rights of the United Nations is connatural to the actions of Accumin and the people who form part of it.

Treating all people with respect and dignity is a fundamental pillar of our activities at ACCUMIN. To ensure this, our suppliers must have policies and processes appropriate to their size and circumstances, including:

• A clear commitment to respect human rights, translated into guidelines and directives accessible to all personnel.
• A human rights due diligence process focused on identifying, preventing, mitigating and accounting for potential negative impacts.
• Procedures to facilitate remediation of any adverse human rights impacts, including the establishment of grievance mechanisms where possible.

ACCUMIN providers are expected to recognize, avoid and address negative consequences that violate any internationally recognized human rights, such as, but not limited to, the following:

4.1 Forced labor and human trafficking

Do not participate in or condone the use of forced labor or human trafficking.

Be diligent in identifying and addressing any form of modern slavery in operations and the supply chain, including prison labor, indentured labor, debt bondage, slavery or any other form of forced labor.

Loans or wage advances should be based on fair terms, be clearly explained to the worker, be mutually agreed upon, and not obligate the worker to remain with the employer until payment is completed.

Do not withhold or confiscate any worker's personal documentation, including passports.

Do not allow workers to pay recruitment, processing or placement fees, and agree with all workers on the terms of their employment in writing at the time of recruitment.

4.2 Child labor

Do not use child labor. Minors may be employed in limited circumstances, provided they are at least 15 years of age, the legal minimum age for employment or the age for completing compulsory education, whichever is higher.

4.3 Working time

Allowing workers time off. Regular working hours comply with the country's legislation and do not exceed 48 hours per week on a regular basis.

Give workers a day off of at least 24 consecutive hours every seven days.

Provide workers with holidays and leaves of absence. Ensure that the workweek, including overtime, does not exceed the limits established by applicable legislation and obtain workers' voluntary consent to overtime.

4.4 Salaries and benefits

Adequately compensate workers. Compensation should be sufficient to cover the basic needs of workers and their families, as well as to generate discretionary income.

Pay wages regularly and in full, and allow workers the benefits and leave to which they are entitled by law.

Do not use salary deductions as a disciplinary measure.

4.5 Fair and equal treatment

Maintain an inclusive and professional work environment and practices.

Do not tolerate offensive, degrading or abusive behavior or discrimination of any kind.

Provide equal hiring and employment opportunities, and do not discriminate on the basis of personal characteristics.

Make employment decisions objectively and based on merit.

4.6 Workplace safety

Provide a safe and healthy work environment to prevent accidents and injuries.

Identify, evaluate and control occupational health and safety risks.

Where hazards cannot be effectively controlled at source, ensure that workers have and use appropriate personal protective equipment.

Periodically train workers in health and safety and maintain records. Accommodation, whether provided directly or through a third party, must be clean, safe and meet workers' basic needs.

4.7 Freedom of association

Adopt an open attitude towards the activities of trade unions and other workers' organizations.

Respect and not interfere with the right of workers to form or join a union or representative organization of their choice.

Recognize the right of workers to collective bargaining. Recognize the access of workers' representatives to exercise their representative functions in the workplace and to communicate openly about working conditions without fear of discrimination, retaliation, intimidation or harassment.

Depending on the sector, location and context in which ACCUMIN's suppliers or third parties operate, suppliers may need to consider additional human rights, particularly those related to local communities and vulnerable groups that require special attention, and conduct due diligence to identify, prevent, mitigate and account for human rights impacts on these groups.

5. Environmental Responsibility

At Accumin, we are firmly committed to protecting and improving the environment. Our suppliers must also adhere to Accumin's environmental commitments, set out in the ESG Policy, as the integrating framework for our programs, actions and initiatives with our employees, customers, suppliers and other stakeholders.

In accordance with these commitments, we expect our suppliers:

5.1 Environmental compliance

Obtain all necessary environmental permits, licenses and registrations and document them properly for your operations.

Provide training to relevant personnel to ensure knowledge of and compliance with environmental permits and other legal requirements.

5.2 Environmental management

Implement an environmental management system adapted to the size, complexity and specific nature of its activities. This system shall allow the identification, evaluation, control and effective mitigation of the environmental impacts generated.

Implement appropriate policies to integrate environmental practices into your operations and activities, and assign designated roles within your organization to take responsibility for environmental issues.

Implement preventive measures aimed at avoiding environmental incidents and, should they occur, respond immediately with effective corrective actions, thus demonstrating a firm commitment to continuous improvement of environmental performance.

5.3 Resource consumption and waste minimization

Minimize the consumption of natural resources through sustainable practices, thus reducing the use of energy, water and other materials during the execution of its activities.

Apply specific practices to prevent environmental pollution, reducing emissions, polluting discharges and the generation of solid and liquid waste derived from its operations, always respecting the precautionary principle.

To adequately and effectively manage all waste generated by its operations, promoting reduction, reuse, recycling and final disposal in accordance with applicable environmental regulations.

6. Business integrity

We express our firm commitment to the values and principles set forth in our Code of Ethics and do not tolerate any practice that could be considered irregular in the development of our relationships with our employees, customers, suppliers, partners, competitors and other third parties or stakeholders.

In accordance with these commitments, we expect our suppliers:

6.1 Bribery and corruption

Do not bribe anyone, anywhere, for any reason, or allow anyone to bribe on your behalf. Offering or accepting anything of value, such as money, gifts, favors, entertainment or even employment for a family member of a public official, could be construed as an attempt to influence a person's professional actions or decisions and, therefore, as bribery.

Do not make facilitation payments (small payments, in cash or in kind, to expedite an action that a public official should normally perform).

6.2 Fair competition

Compete fairly on the basis of product or service quality, innovation, price, advertising and other legitimate means. Understand and comply with competition law requirements applicable to your business and do not engage in anti-competitive behavior.

6.3 Confidential information and intellectual property

Protect ACCUMIN's confidential information. Use this information only for the purposes authorized by the contractual agreement.

Do not share confidential information without ACCUMIN's consent.

Adequately protect the confidential and private information of your employees.

6.4 Conflicts of interest

Report to ACCUMIN any situation that may represent a conflict of interest in your relationship with ACCUMIN. Conflicts of interest often arise when objectivity in the performance of work is, or could be, affected by a personal interest. These situations may involve organizations, individuals, or both.

7. Implementation

To help ACCUMIN suppliers comply with our Responsible Sourcing Code, ACCUMIN can explain our expectations in more detail and identify how to support suppliers' efforts to implement these principles in their operations and business relationships.

Identifying risks and impacts and finding appropriate ways to respond to them can take time. However, we expect suppliers to commit in good faith to implementing the Responsible Sourcing Code, reporting measurable progress and continuous improvement initiatives.

If there is no clear commitment to prevent, mitigate and account for negative impacts, or if the lack of action and improvement persists, we may consider termination of the contract.

We reserve the right to terminate contracts immediately in the event of a serious breach of the Responsible Sourcing Code.

The Responsible Sourcing Code does not create any rights beyond those included in the contractual relationship between ACCUMIN and an ACCUMIN supplier or any other party; it does not constitute a promise or warranty.

Suppliers can demonstrate that they adhere to the Responsible Sourcing Code by aligning themselves with comparable standards or certification schemes based on the United Nations Global Compact.

8. Speaking out

We strongly support a culture of whistleblowing without fear of retaliation against those who report actual or suspected violations of the Responsible Sourcing Code. Therefore, we encourage our suppliers:

• Provide workers with easily accessible means to raise concerns anonymously and protect them from retaliation.
• Maintain systems and processes to investigate issues raised and take appropriate action, while protecting the confidentiality of all involved.
• Develop the means for individuals and stakeholders external to the organization to raise concerns and address them early.
• Report any concerns or suspected violations of the Responsible Sourcing Code to ACCUMIN through your key contact.
• For any communication related to the implementation of the Responsible Sourcing Code, please send us a message to the specific whistleblower channel we have set up on the corporate website: https://whistleblowersoftware.com/secure/canal_denuncias_accumin.

9. Data Privacy

Data privacy in supplier relationships is important to protect the privacy and rights of the individuals whose data is processed in the course of collaboration with them. The GDPR plays a key role in this regard, and we must ensure that our suppliers and service providers comply with appropriate data privacy measures. We therefore carefully evaluate our business partners in advance. When collaborating with them, we enter into contracts that comply with data privacy regulations and contain clear data privacy regulations, rights and obligations.

10. Dissemination and Communication

Communication and dissemination of this Policy for Responsible Use of Responsible Sourcing Policy is the responsibility of Accumin's ESG Committee, with the objective of ensuring that Accumin employees and other stakeholders are properly informed about this Policy.