Quality, trust and social commitment. CaixaBank's Human Rights Policy. May 2017

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1 CaixaBank's Human Rights Policy May 2017 Caixabank, SA, Barcelona,

2 Contents 1 Introduction 2 Scope and field of application 3 Commitments and principles of conduct in 31 Our responsibility to our employees 32 Our responsibility as providers of financial services 33 Our responsibility to providers 34 Our responsibility as part of the community 4 Implementation of the Policy Caixabank, SA, Barcelona,

3 1 Introduction The Board of Directors of CaixaBank, SA (hereinafter CaixaBank) has approved this policy in order to highlight the entity's commitment to human rights, in accordance with the highest international standards CaixaBank considers respect for human rights to be an integral part of its values and the minimum standard for legitimately carrying out its business activity It also considers that the protection of human rights rests mainly with governments and that companies have a responsibility to promote and respect them in the course of their operations Under this premise, in accordance with its Code of Business Conduct and Ethics, CaixaBank operates within a culture of respect towards human rights, and expects its employees as well as collaborators, partners and other parties directly related with its operations, products and services to do the same 2 Scope and field of application The principles of conduct of this policy shall be used as a guide in relation to human rights in the relationships that CaixaBank establishes with its employees, customers, shareholders, suppliers, trading partners and the communities in which it carries out its business and activities This Policy will be applicable to employees, directors and members of the governing bodies of CaixaBank This Policy affects the whole Group, and therefore the Governing and Management Bodies of the CaixaBank Group must take the pertinent decisions in order to integrate the stipulations of this policy at such companies, either by approving its own Policy in accordance with the principles established in this document or by adhering to those of CaixaBank, duly adapted where applicable CaixaBank shall promote and inform its Stakeholders regarding this Policy 3 Commitments and principles of conduct CaixaBank undertakes to respect all human rights recognised internationally and contained in: The United Nations International Charter of Human Rights o The Universal Declaration of Human Rights o The International Covenant on Civil and Political Rights o The International Covenant on Economic, Social and Cultural Rights The ILO Declaration on Fundamental Principles and Rights at Work and the eight covenants that this has identified as fundamental Caixabank, SA, Barcelona,

4 It also undertakes to carry out its activity in strict compliance with the applicable regulations and in accordance with the highest standards of ethical and professional conduct These include: The United Nations Guiding Principles on Business and Human Rights OECD Guidelines for multinational enterprises The United Nations Global Compact The United Nations Women's Empowerment Principles The Equator Principles The United Nations Principles for Responsible Investment to which VidaCaixa and CaixaBank Asset Management are adhered CaixaBank is working in order to understand the impact on human rights deriving from its activity and undertakes to prevent and avoid contributing to the adverse negative impacts and, where applicable, mitigate them as much as possible The Human Rights Policy is in line with other specific rules and policies, such as the Code of Business Conduct and Ethics, the Anti-corruption Policy and the Criminal Compliance Policy, as well as the adhesion to international initiatives in relation to corporate responsibility 31 Our responsibility to our employees CaixaBank considers its relationship with its employees to be one of its main responsibilities in relation to human rights The policy for recruiting and managing personnel is founded on a respect for diversity, equal opportunities and non-discrimination on any grounds, including gender, age or disability Within this framework, CaixaBank has internal policies and rules relating to: The promotion of diversity, inclusion and equal opportunities Protection against sexual harassment, discriminatory attitudes and abuse of authority The freedom of expression and opinion Freedom of association and collective bargaining Occupational Health & Safety The prevention of corruption Minimum pay that guarantees human dignity, respecting that established in the national minimum salary A working day in accordance with that legally established Career development and training The rejection of forced and child labour The implementation of these policies and rules is supported by training and sensitisation programmes and in the establishment of monitoring indicators In order to facilitate compliance with the CaixaBank codes of conduct there is a confidential internal channel through which employees may communicate any possible doubts regarding their interpretation or practical application, as well as report possible breaches Caixabank, SA, Barcelona,

5 32 Our responsibility as providers of financial services CaixaBank requires of its employees a respect for people, their dignity and their fundamental values, as indicated in its Code of Business Conduct and Ethics It also aims to work with customers which share its values in respecting human rights, recognising that its level of influence on such customers will depend on the nature and circumstances of the relationship In this regard, CaixaBank undertakes to use any means within its reach to: Guarantee access to its services without discrimination based on gender, race, age or disability To provide a series of policies and procedures that guarantee the organisation has adequate knowledge of its customers, in accordance with the enforceable legal requirements In each case Respect the confidentiality and privacy of customers Develop new products and financial services in a manner consistent with their aspirations in relation to human rights Offer customers products or services that are suitable for their circumstances and needs Attempt to anticipate and inform customers with special financial difficulties Possess programmes, products and services aimed at the most vulnerable groups and promote financial inclusion Integrate social and environmental risks into decision-making processes and avoid financing or investing in those companies related to human rights controversies Specifically: o The financing of significant investment projects shall be performed following the commitments acquired as signatories of the Equator Principles and in accordance with the internal regulations on the management of social and environmental risks o VidaCaixa and CaixaBank Asset Management, have adhered to the United Nations Principles for Responsible Investment as a demonstration of its will to integrate these principles into the management of mutual funds and pension plans o The criteria set forth in the policies of the sector established by the entity shall be followed It is with this in mind that CaixaBank has the policies, committees, due diligence processes and other internal systems to assist it in establishing whether it is appropriate or permissible to enter into customer relationships or participate in certain operations The controls are included within the general processes of the entity and these vary according to the size, sector and profile of the customer as well as its location, context and potential risk of any adverse impact Where considered appropriate, there will also be external support CaixaBank has a complaints and claims management policy The aim of this policy is to ensure the application of the financial services customer protection and transparency standards in the resolution of disputes and the continual improvement of the commercialisation processes of its services Similarly, the company has a variety of channels for communication, consultation, and claims, which complements the official channels Caixabank, SA, Barcelona,

6 33 Our responsibility to providers CaixaBank insists on the utmost respect for human and labour rights from its suppliers and encourages them to include in their practices behaviour that is in line with its values and transmit these through their own value chain In this regard, CaixaBank promotes and includes among its practices: Knowledge of and respect for shown by its suppliers regarding the Ethical, social and environmental standards for suppliers of the group Knowledge of and respect for the United Nations Global Compact Principles The performance of additional controls of those suppliers internally considered to be a potential medium-high risk The adoption of the necessary corrective actions to reduce the effect of the non-fulfilment of its standards 34 Our responsibility as part of the community The sustainability of the CaixaBank business model is directly linked to the prosperity of the territories in which it carries out its activity CaixaBank undertakes to comply with all applicable laws, collaborate with the public and legal institutions and respect the internationally recognised human rights, wherever it operates CaixaBank also undertakes to make a positive contribution to human rights in the communities in which it operates In accordance with its mission, vision and values, the commitments established in its Corporate Responsibility Policy and Environmental Policy: Promote the dissemination of international principles in relation to human rights within its area of influence and, thus collaborate, in so as far as is possible, with other International institutions, organisations and government bodies Promote and disseminate the initiatives and programmes which would result in a positive contribution to human rights and the United Nations Sustainable Development Goals (affordable housing, child vaccination, education, labour market integration for groups at risk of social exclusion, combating climate change, eradication of poverty, etc) CaixaBank has a variety of communication channels through which its stakeholders may present their queries, suggestions and claims Caixabank, SA, Barcelona,

7 4 Implementation and communication of the Policy The Code of Business Conduct and Ethics adopted by the Board of Directors shall be respected by employees, senior management and members of the governance bodies in the implementation of this Human Rights policy CaixaBank considers the action in terms of human rights when initiating, renewing, expanding or terminating business relationships with third parties In this regard, it undertakes to dedicate the necessary resources to ensure an effective implementation of this Policy The culture of human rights is ingrained into the company through periodic communications and training actions All efforts will be made so that employees with duties that have a greater potential impact on human rights (such as the areas that manage project finance, labour relations or security, etc) shall receive specialised training The company periodically analysed the human rights issues relating to its activity and implement due diligence processes to assess the risk of non-compliance, which it shall use to propose preventive measures or solutions to the negative impacts and measures to maximise the positive impacts It also undertakes to maintain and disseminate the communications or claims mechanisms so that those directly affected by its operations may inform of any possible impact concerning human rights Specialised external advice has been sought in the preparation of this Policy This Policy will be made public and actively communicated to the whole workforce, trading partners and other relevant parties Policy approved by the Board of Directors on May 25, 2017 Caixabank, SA, Barcelona,

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