N o v e m b e r 2 0 1 2 Policy on Employees & Human Rights POLICY STATEMENT Inalfa Roof Systems Group of companies ( Inalfa ) is the leading provider of sunroof systems to all major OEM s in the world. In all countries and societies in which we operate, we are determined to act according to our core values. Respect towards people, the environment and the society in which we live and work belong to these Core Values. We honor our values by recognizing the responsibility to respect employees human rights and demonstrating that we act accordingly. The Employees & Human Rights Policy of Inalfa is aimed at supporting and guiding our management and employees to achieve this goal. This Policy is published at our corporate website (www.inalfa-roofsystems.com).
2. INTRODUCTION In a globalizing world, the role in society of international companies like Inalfa is of increasing importance. To ensure that Inalfa meets its responsibilities in this role, it is amongst others necessary to create and protect a safe and responsible working environment for employees and their direct surroundings. To this end, Inalfa Roof Systems has developed a policy with regard to the basic employees & human rights that it respects and aims to safeguard. Our respect for individuals and for the well-being of employees is first of all reflected in our Core Values, Business Principles and Policies (www.inalfa-roofsystems.com). The Inalfa Employees & Human Rights Policy is a further elaboration and articulation of these commitments. Inalfa endorses the principles enshrined within the Universal Declaration of Human Rights 1) and the core conventions of the International Labor Organization (ILO) 2) based on respect for the dignity of the individual without distinction of any kind. Inalfa supports these human rights and employees rights in line with the legitimate role of business. Where an impact on employees rights falls outside the scope of Inalfa s responsibility, for instance in case of violations by third parties, Inalfa will provide assistance to its best abilities. This policy is applicable to all operating companies and subsidiaries where Inalfa Roof Systems Group holds a majority share or has otherwise management control. The provisions of this policy are further explained and accompanied by additional guidelines, designed to specify the details and consequences of the provisions. The further explanation and additional guidelines hence serve as a clarifying background for this policy. For any specific issues or questions concerning third party employees, agency personnel and contractors, we refer to the Inalfa Roof Systems Supplier Code (www.inalfa-roofsystems.com) and any other policy that may be applicable and that governs the relationship between Inalfa and its suppliers or contractor s in specific cases. In these General Business Principles the expressions Inalfa and Inalfa companies are used for convenience and mean the Inalfa group of companies and its subsidiary companies. Employees are all those employed by Inalfa, including management, regardless of the type of contract (temporary or fixed), including people who are employed through a third party or at will. These policies should be reviewed as a minimum standard; where local legislation goes beyond the content of these policies, our operating companies will adhere to the local legal obligations. Where compliance with local law can put the operating companies into the position of not being able to comply with the standards of these policies, the operating Inalfa company is expected to act as follows: 1. Seek ways to honor the principles laid down in these policies and try to act according to these principles as much as possible, without acting in direct contravention of local law. 2. If there is a risk that the operating company unwillingly contributes to violation of these policies, this risk should be treated as a legal compliance issue. In such cases, the operating company should contact the global HR Executive at corporate office in charge of Corporate Compliance Governance. These policies will be applicable as from 1 November 2012.
3. STANDARDS RELATED TO EMPLOYEES & HUMAN RIGHTS NON-DISCRIMINATION, EQUAL & FAIR TREATMENT Inalfa respects the right to non-discrimination and equal opportunity for employment. People are employed and are provided opportunity based on the principle of equal opportunity, without distinction to race, color, gender, religion, pregnancy, sexual preference, nationality, social origin and status, political or other opinion, personal background, descent or origin. In relation to the appointment or career prospects of employees, Inalfa will pay attention only to the suitability of the candidate on the basis of education, personality, skills, working experience and other relevant attributes as allowed under local law and his or her legitimate demands. Inalfa will take its decisions regarding present and future employees on the basis of objective criteria. Inalfa respects cultural and individual diversity and promotes inclusiveness. It respects personal beliefs / persuasions of present and future employees. No form of discrimination will be tolerated. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING Inalfa recognizes and respects the freedom of employees to choose whether or not to establish or to associate with any organization of their own choosing (including labor unions) without Inalfa s prior authorization. Inalfa will not make the employment of a worker subject to the condition that he/she shall not join a union or shall relinquish trade union membership. Furthermore, Inalfa will not cause the dismissal of - or otherwise prejudice - a worker by reason of union membership. Inalfa will not interfere with or finance labor organizations or take other actions with the object of placing such organization under the control of Inalfa. Inalfa respects - within the framework of (local) law, regulations and prevailing labor relations and employment practices - the right of its employees to be represented by labor unions and other employee organizations. Inalfa will engage in negotiations, either on its own behalf or through employers' associations, with a view to reaching agreement on fair employment conditions. FORCED LABOR Employment should be chosen freely. Inalfa will not engage in or support the use of forced or compulsory labor such as prison labor, debt bondage, trafficking, serfdom or any type of employment enforced by means of coercion. Inalfa will avoid working with suppliers or employment agencies that are known to be making use of forced or compulsory labor in their operation. CHILD LABOR Inalfa respects the rights of the child, including the right to education, the right to rest and play and the right to have the child s basic needs met. Inalfa will therefore not engage in or support the use of child labor, which means that Inalfa will not allow children to work within its facilities. Furthermore, Inalfa is committed to and maintains programs aimed at the elimination of child labor in its supply chain (please also refer to Inalfa Roof Systems Suppliers code at www.inalfaroofsystems.com).
4. Inalfa follows the ILO definition (3 of the minimum age for admission to employment or work. This age shall not be less than the age of completion of compulsory schooling and in any case not be less than 15 years of age (art. 2 paragraph 3 ILO minimum age convention, 1973 nr. 138), except in some developing countries, where it is 14 years of age (art. 2 paragraph 4 ILO minimum age convention, 1973 nr 138). In case local laws set a higher age to define what is considered a child, Inalfa will abide to the local law. WORKING HOURS Inalfa recognizes the right to rest and leisure and will therefore always comply with local laws, regulations and/or local customs with regard to working hours and overtime. Moreover, in line with the ILO-report of the committee of experts on the application of conventions and recommendations concerning working hours (Geneva, 2005), Inalfa will generally not require its staff to work in excess of a maximum of 48 hours per week (less in some cases, depending on local laws) and will provide at least one day off for every seven-day period*. In this way Inalfa aims to ensure safety in the workplace and to promote a healthy balance between working and home life of its employees. * In certain exceptional circumstances, there may be specific reasons to deviate from this standard. Prior approval by INALFA ROOF SYSTEMS s Group VP Human Resources is required in those cases. REMUNERATION Inalfa observes the statutory minimum wage set by the government of the country in which it has a local operation. Where this is not sufficient to meet basic needs, Inalfa strives to compensate employees with remuneration that ensures an adequate standard of living. Inalfa maintains a remuneration policy that emphasizes the internal equity and external comparability within a defined job market. Inalfa strives to offer equal pay for equal work performed at equal levels at similar locations. The key elements within Inalfa s pay and reward policy are: pay for responsibility pay for performance HEALTH, SAFETY & ENVIRONMENT Inalfa provides its employees with a safe and hygienic working environment and working conditions. Inalfa will take appropriate measures to continuously improve safety and health aspects within its facilities, including the provision of personal protective equipment (PPE) when and where necessary. Working conditions should allow for safe working practices and support the occupational health and well-being of employees. We maintain a policy aimed at continuous improvement of our health and safety performance. In those countries particularly developing countries where basic health care is not sufficiently provided by the government and/or if there is no possibility for employees to arrange for basic health care from local service providers themselves, Inalfa provides or ensures (access to) basic health care itself. Inalfa has a medical strategy aimed at providing or ensuring (access to) basic health care for its employees and their immediate families. Consistent with Inalfa s commitment to sustainable development, it will do all that is reasonable and practicable to minimize any adverse effects of its activities on the environment.
5. HARASSMENT Inalfa considers protecting personal dignity, integrity and health at the workplace to be one of its core responsibilities as a good employer. One aspect of safeguarding the integrity of each employee is to ensure that harassment (4 in any form, of a sexual nature or other, does not occur and, if it does occur, to ensure that adequate procedures are readily available to deal with the problem and prevent recurrence. No form of harassment will be tolerated. TRAINING AND PERSONAL DEVELOPMENT Inalfa acknowledges the importance of training and personal development of its employees. Training: In general, Inalfa provides for and bears the costs of regular training on issues that it finds relevant to the business and/or to the function of the employee. Training and development opportunities for employees will be identified on a regular basis and when considered relevant, training is organized for the employee. Personal development: Personal development (employability) is regarded as a shared responsibility for Inalfa and its employees. This shared responsibility should be reflected in the contribution both parties are prepared to make in financial terms and/or in terms of time invested in additional education and training. Inalfa encourages its employees to undertake additional training courses and will support them when additional training is considered necessary. Inalfa will promote policies aimed at the development of skills relevant for its operation and in line with the talents of its employees. SECURITY In politically unstable or conflict affected regions, Inalfa may be confronted with potential security risks to its employees, their dependents and its facilities. When managing security in those situations Inalfa will respect the rule of law and will adhere to international human rights principles (5. Inalfa shall prevent its hired security guards from unlawfully infringing on the rights of its employees or of others affected by its operations. When necessary, security guards shall be trained how to behave in such difficult situations and when and how to intervene in security threatening situations. NON-COMPLICITY IN HUMAN RIGHTS VIOLATIONS Inalfa recognizes that in countries that are politically less stable or where human rights (6 are compromised, dilemmas may arise, including whether or how it can continue to operate in that country with integrity. Inalfa will act in such a way that none of its operations knowingly contribute to human rights violations by others.
6. MANAGEMENT OF THESE POLICIES IMPLEMENTATION Inalfa has formulated clear standards on Human Rights and expected Business Codes of Conduct. Next to the formulation of these standards it is important to integrate and implement our policies and strategy throughout all our operating companies in the world. To achieve this we will focus on: Education and training. The operating companies will be trained to raise their awareness of these policies, and they will be supported in their efforts to respect the rights of their employees. Monitoring performance against our own benchmarks. Use additional self-assessment tools and develop action plans. Facilitate dialogue with stakeholders (such as employees and trade unions) through clear reporting on the policy compliance performance of our company. GRIEVANCE PROCEDURES Inalfa provides grievance-procedures in all its operating companies, and will inform employees about the existence of such procedures and stimulate the proper use of these procedures, while discretion and protection will be guaranteed to those who make use of these procedures. In case of grievances employees are expected to always follow local procedures first, before making use of other channels (e.g. the Inalfa Roof Systems code on whistle blowing). Please also refer to and review the section of this document pertaining to the Review Committee General Business Principles for reporting compliance issues and proper escalation procedures. Venray, the Netherlands November 2012 Approved by the Board of Management NOTES REFERED TO IN THIS POLICY 1 The Universal Declaration of Human Rights, General Assembly of the United Nations, 10 December 1948. Together with the main instruments through which it has been codified, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights, it forms the International Bill of Human Rights. http://www.un.org/en/documents/udhr/ 2 The 8 Core or Fundamental Conventions identified by the Governing Body of the International Labour Organisation (ILO), http://www.ilo.org/global/what_we_do/internationallabourstandards/ Introduction/ConventionsandRecommendations/ 3 Source: ILO conventions on Child Labor (138,182); http://www.ilo.org/ipec/facts/iloconventionsonchildlabour/lang--en/index.htm 4 Harassment: a form of (suspected) serious wrongdoing as referred to in paragraph H of the INAL- FA ROOF SYSTEMS Code of Business Conduct and the INALFA ROOF SYSTEMS Code of Whistle blowing 5 Human Rights: as defined in the Introduction (page 3 of this Policy) 6 Human Rights: as defined in the Introduction (page 3 of this Policy