1. Purpose
The purpose of this Human Rights Policy and supporting processes is to outline Camira’s commitment to human rights in accordance with the UN Universal Declaration of Human Rights, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and other applicable international human rights standards.
2. Strategy
Camira recognise our responsibility to avoid complicity in human rights abuses and we aim to advance the human rights of our employees, customers, supply chain partners by making a positive contribution to economic, environmental and social progress in the communities where we operate.
Our commitment includes:
• Non-Discrimination: Ensuring equal opportunities and treatment for all employees, regardless of race, gender, age, religion, disability, or any other characteristic.
• Fair Labour Practices: Adhering to fair labour practices, including the prohibition of child labour, forced labour, and ensuring fair wages and safe working conditions.
• Freedom of Association: Respecting the right of employees to freely associate and bargain collectively.
• Community Engagement: Engaging with communities in domestic and foreign locations to understand local human rights concerns and ensure our operations do not negatively impact their rights.
• Supply Chain Responsibility: Expecting our suppliers and partners to uphold similar human rights standards and verify compliance with these standards on request.
• Corporate Governance: Developing and applying effective self-regulatory practices and systems which nurture a relationship of mutual trust between Camira and our partners.
3. Process
Camira’s approach to identifying and assessing human rights risks is embedded within our Group Risk Management Process. Businesses and functions governed by this statement are contractually required to conform to Camira’s control requirements including active diligence in the identification and notification of human rights abuses. Our supply chain partners are contractually obligated to mitigate human rights risks within their own supply chains and possibility of responsible disengagement has been communicated if expectations around responsible business conduct are not respected.
Camira is focused on providing a working environment in which our people can thrive. Our suite of people-related strategies and policies ensure that integrity is ingrained as a core value, and annual delivery of Modern Slavery, Equality, Diversity & Inclusion, Sexual Harassment and Whistleblowing training validates our shared understanding of our compliance culture. It is the responsibility of all our people to adhere to the strategies, policies and training provided, in addition to any specific local requirements.
Internal policies and controls relevant to Human Rights include:
• Group Compliance Policy
• Corporate Social Responsibility Policy
• Risk Management Policy
• Group Health & Safety Policy
• Supplier Code of Conduct
• Whistleblowing Policy & Procedures
Camira takes practical steps to guard against exploitation, discrimination or the limiting of personal freedoms, by integrating human rights considerations into our business decision-making processes and sharing our strategies, policies and controls with our supply chain partners through our Supplier Assessment Framework and corporate website and intranet. By conducting regular due diligence visits and engaging in ongoing dialogue with stakeholders, we aim to identify, prevent, mitigate, and remediate any adverse human rights impacts to which we may be inadvertently involved.
4. Roles and Responsibilities
Camira’s Board of Directors accepts full accountability for Camira’s Human Rights strategy and risk management processes.
Designated risk managers are appointed based on their appropriate level of seniority, skills and experience, and are provided with adequate authority, time, training, resources and skills to assume responsibility for monitoring human rights impacts and improving controls. Risk managers responsibilities are recorded in job descriptions and all Camira employees are required to report potential human rights violations and non-compliances if encountered.
5. Communication and Reporting
Camira aim to promote an environment in which individuals and groups feel safe to raise concerns regarding actual or potential adverse human rights impacts and will never take disciplinary action against workers or other representatives who make bona fide reports. We are committed to investigating any reported issues promptly and transparently and addressing potential impacts through prevention or mitigation, and actual impacts through remediation.
Camira will prepare and disclose transparent information including actions taken, estimated timelines and benchmarks for improvement, in accordance with internationally recognised standards, and will refrain from publication of insufficient or unclear information.
6. Review of Policy
As we develop our approach to Human Rights, this policy shall be periodically reviewed and updated. It applies to all subsidiaries of Camira Group Holdings Limited and is approved by the Board. This statement has been signed by the Commercial Director, on behalf of the Board of Directors.
ANTHONY CROALL
Commercial Director
Dated: January 2025