ERG – Human Rights Commitment

Respect for Human Rights has always represented an essential and important element of the way the ERG Group goes about its business.

This is because at ERG we firmly believe that human rights are the basis of all relationships within civil society as they are considered inalienable rights of all individuals, without distinction, given that they belong to the entire human race.

ERG has a publicly available Human Rights Policy aligned with internationally accepted standards, such as the International Charter of Human Rights, the UN Guiding Principles on Business and Human Rights, the UN Global Compact Principles, and the Women’s Empowerment Principles (WEPs).

The Policy also refers to the ILO Declaration on Fundamental Principles and Rights at Work and related Conventions, the OECD Guidelines for Multinational Enterprises, and the OECD Due Diligence Guidelines for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Internally, ERG’s Human Rights Policy is supported by a set of company-wide documents, including:

• Code of Ethics
• Sustainability Policy
• Human Rights Policy
• Diversity & Inclusion Policy
• Policy for Gender Equality
• Policy Prevention of Violence, Harassment and Bullying in the Workplace
• Whistleblowing Guidelines
• Health Safety and Environmental Policy
• Supplier Code of Conduct
• Anti-Corruption Policy
• Organisation and Management Models pursuant to Legislative Decree no. 231/01
• Privacy Organisation Model

Our Commitment in Preventing/Respecting Human Rights

The Human Rights Policy applies comprehensively across ERG’s sphere of influence. It establishes clear expectations and binding requirements for:

• ERG’s own operations, including all employees.
• Suppliers, expected to adhere to ERG’s ethical, social, and human rights standards.
• Business partners, aligning with ERG’s values in all collaborations.

Due Diligence Process

ERG has established control bodies such as:

• Oversight Body: in its role as the Ethical Committee, which oversees the proper application of the Ethical Code, with specific regard to human rights, equal opportunities, etc., and manages any reports through dedicated channels (dedicated email and regular mail) available to all employees and third parties.
• Human Capital Committee: which monitors the effective implementation of Human Rights, Diversity & Inclusion, Anti-Violence, Harassment, and Bullying Policies, Gender Equality, and manages reports regarding their non-compliance (through our whistleblowing system).

The Group carries out a due diligence process through a systematic and periodic review of the risk mapping of both potential and actual human rights issues across:

• Own operations
• Value chain and business relationships
• New business relations

The Human Rights Policy outlines the following stages:

Human Rights Risk Identification

Risks are mapped and reassessed periodically, in accordance with our risk management framework and double materiality analysis, as described in the 2024 Integrated Annual Report.

The company’s human rights risk assessment process includes:

• Identifying third parties at risk, such as suppliers, contractors, subcontractors, and business partners, by analyzing factors such as the geographical area of operations and the nature of activities performed; this helps prioritize areas where human rights violations are more likely to occur.
• Conducting audits, based on ERG’s internal procedures, in areas identified as being at higher risk; these can be carried out remotely or on site and are designed to verify actual practices against stated commitments.

As part of its risk identification and due diligence efforts, ERG monitors and addresses a range of human rights issues that may be actual or potential concerns across its operations and value chain. These include:

• Forced labor and Human Trafficking: Risk to make sure that no violations occurred.
• Child labor: Risk to ensure that no minors are employed in hazardous or inappropriate roles.
• Freedom of association: ERG ensures workers are free to organize and participate in unions or similar bodies without interference.
• Right to collective bargaining: The company supports dialogue and negotiation between employees and employers and verifies the presence of collective agreements where applicable.
• Discrimination: ERG evaluates whether fair treatment is guaranteed regardless of personal characteristics such as gender, origin, religion, or disability, and verifies inclusion measures in place.

Covering the following groups: Own employees, Women, Children, Indigenous people, Migrant workers, Third-party employees and local communities.

Human Rights Assessment

Over the past three years, we have conducted a full assessment covering 100% of our own operations. No specific human rights risks were identified during this process, and therefore, no mitigation actions have been implemented. However, we recognize that the absence of identified risks does not eliminate the need for ongoing monitoring and the continuous improvement of our assessment tools.

Regarding our supply chain (Tier 1 suppliers and contractors), the assessment currently covers 9.4% of the total. Although no risks have been detected to date, we are aware of the importance of gradually expanding the scope of this analysis—particularly in geographic or sectoral contexts where risks may be more prevalent.

This assessment marks an initial step in our commitment to responsible human rights management. We remain focused on strengthening our due diligence practices with the goal of building a more robust and transparent system for identifying and managing human rights risks.

Human Rights Mitigation and Remediation

While no high-risk cases have emerged to date, ERG has procedures in place for remediation and mitigation, including action plans, supplier engagement, and review of contract terms. In case of violations, corrective measures are promptly applied, respecting stakeholder rights and maintaining full transparency.

While no mitigation plans are in place due to low-risk exposure, however a Group-wide efforts have been made to strengthen existing risk mitigation and management processes:

• Recruitment system hiring adults older than 18 years old.
• Implementation of policies guided by Code of Ethics that is regularly revised and updated, with a focus on human rights protection. All employees receive training on its core values. The most recent update was in 2023.
• Sustainability incentives: MBO/LTI remuneration system which include Human Rights objectives (HSE objectives, Women in workforce, Sustainable procurement).
• Adoption and maintenance of an integrated management system compliant with international standards (ISO 14001, ISO 45001, UNI PDR 125:2022), supported by regular HSEQ and compliance audits.
• Defining HSE Contractual Terms that govern the obligations of both ERG and its contractors with respect to health, safety, and environmental protection.
• ICT applications to respect national legislation on disabilities (e.g. impaired sight).
• Constant update and monitoring of the Data Protection Organisational Model and of related company’s policies and protocols, including audits, to ensure the adequacy also in terms of compliance with the applicable regulations.
• Requiring all suppliers, contractors, and partners to comply with company’s Code of Ethics and Supplier Code of Conduct, which uphold international standards on workers’ rights and explicitly prohibit human rights violations such as human trafficking, child labor, forced or compulsory labor, and indentured or prison labor.
• Enforcing compliance through continuous monitoring, corrective measures, and strict subcontractor controls. Serious breaches lead to contract termination, blacklisting, and exclusion from future tenders, supporting ERG’s sustainability and human rights commitments.
• Dedicating a portal to track counterparties for sanctions, legal proceedings (including under Italian Legislative Decree no. 231/01), human rights violations, crimes, and negative media coverage.
• Assessing suppliers through a sustainability questionnaire regarding ESG topics such as diversity, inclusion, and human rights which results, inform tender evaluations, helping identify risks and reward best practice and helping suppliers to define action plans.
• Enabling whistleblowing channels (web platform and voicemail), accessible to all Group companies and counterparties, allowing the reporting of crimes, misconduct, or violations—including human rights breaches. The system ensures confidentiality and protects whistleblowers from retaliation through measures such as data encryption