Introduction

Responsible and ethical business conduct forms the foundation of all operations within the Bravedo Group. The trust of our stakeholders is essential to us, and we aim to be worthy of that trust—towards our employees, customers and partners.

The Bravedo Group Human Rights Policy guides our operations within the Group as well as in collaboration with partners and suppliers. The policy applies to all Group personnel, their employment relationships, and all individuals working directly under the Group’s management. It also covers the use of external labour, procurement, service delivery and customer collaboration.

In addition to this common policy, companies within the Group may have their own human rights–related guidelines, but these must align with the Group’s Human Rights Policy and meet at least the minimum requirements set out here.

Commitments

We respect the human rights of our employees, customers and all stakeholders in everything we do. This applies to everyone regardless of age, gender, sexual orientation, disability, ethnic or cultural background, or religious or political views.

We require employees, customers, partners and subcontractors to comply with all applicable laws and regulations. Respect for human rights and fundamental labour principles is a prerequisite for collaboration with us.

Our operations are guided by internationally recognised agreements and principles, including:

• The Universal Declaration of Human Rights

• The UN International Covenant on Civil and Political Rights

• The UN International Covenant on Economic, Social and Cultural Rights

• The ILO Declaration on Fundamental Principles and Rights at Work

• The OECD Guidelines for Multinational Enterprises

We also consider the results of Bravedo’s double materiality assessment, which highlight the central importance of human rights and social responsibility in our business.

Accessibility

The Bravedo Human Rights Policy is publicly available on the company’s website in Finnish and English. The policy is reviewed annually and updated when necessary to reflect best practices and evolving legal requirements.

Stakeholder Consultation and Involvement

The principles in this policy were developed in consultation with Bravedo’s Sustainability Committee, which includes representatives from different Group companies and personnel groups. In addition, Bravedo has conducted a double materiality assessment, during which key stakeholders—including employees, customers and suppliers—were consulted. The results of this assessment have been incorporated into the content of the policy.

Implementation and Oversight

The Bravedo Oy Steering Group has approved these principles and oversees their implementation at the Group level. Each subsidiary is responsible for appointing an accountable person to ensure implementation of the policy and to report to its board when necessary.

Roles and Responsibilities under the Policy

PRINCIPLES

Human Rights of Personnel

We commit to respecting the human rights of every employee and promoting equality, non-discrimination and diversity in all our operations.

The Group’s occupational safety and work ability management are guided by statutory obligations and internal operating models, such as company-specific equality and gender equality plans, occupational safety action plans and guidelines for preventing inappropriate behaviour. The goal is to ensure a healthy, safe and inclusive work environment where harassment, bullying or sexual harassment are not tolerated.

Acting in accordance with human rights principles, and advancing equality and non-discrimination, is the responsibility of every member of the work community. In certain roles—such as leadership and supervisory positions—there is an additional responsibility to uphold legal employer obligations.

Group companies collect annual data on employees’ experiences related to equality and non-discrimination to support operational development. This information is used, for example, to address potential discrimination or harassment, prevent and eliminate them, and identify ways to strengthen diversity and inclusion.

The Bravedo Group pays particular attention to respecting and promoting the rights of vulnerable groups, such as minorities.

Human Rights and Equality in Customer Work

It is important to us that customer work is conducted ethically and with full respect for human rights at all times. We do not tolerate unethical conduct by anyone within our network. We require external stakeholders to adhere to Bravedo’s Ethical Business Principles. In addition, suppliers are subject to their own Supplier Code of Conduct, which must be accepted in all procurement processes managed by the Group’s procurement team.

Subsidiary-specific policies further specify human rights and equality objectives and actions in customer work to ensure alignment with each business’s operating environment.

Human Rights in the Supply Chain

Bravedo incorporates human rights considerations into its procurement and business relationships primarily by setting clear expectations for its suppliers. In procurement managed by the Group procurement team, suppliers are required to comply with national laws, contracts and working conditions, and to commit to Bravedo’s Supplier Code of Conduct. Acceptance of the Code is a prerequisite for cooperation in these cases and communicates our commitment to human rights throughout the value chain. Our goal is to gradually expand this practice across the Group’s other procurement activities.

Suppliers are responsible for the actions of their subcontractors as if they were their own. The requirements applicable to the supply chain are further defined in the Group’s procurement policy.

Human Rights Due Diligence

The purpose of the Human Rights Policy is to ensure that human rights are respected and promoted across all operations within the Bravedo Group. We are committed to identifying, preventing, mitigating and remedying adverse human rights impacts that arise from or are linked to our business activities.

Bravedo is committed to developing and strengthening its human rights due diligence processes in line with international recommendations. Our primary tools currently include the Group’s double materiality assessment and risk management processes, through which human rights risks are identified and prioritised. Based on these assessments, we will deepen our risk management practices and actions over time.

Bravedo commits to respecting human rights in all our activities. This means that we:

• identify and assess human rights risks within our business and value chain,

• prevent and mitigate possible harm in cooperation with stakeholders,

• establish reliable reporting and remediation channels for concerns,

• assess the effectiveness of our actions annually and report on progress transparently.

Reporting Concerns and Contact Information

Internal reporting:
All employees are required to report potential misconduct either to their manager, another appropriate internal party or through Bravedo’s Whistleblowing Channel. The channel enables independent and confidential handling of reports in accordance with Directive (EU) 2019/1937.

External reporting:
External stakeholders may submit a report via the electronic reporting channel of the Office of the Chancellor of Justice.

Further details on report handling can be found in Bravedo’s Whistleblowing Privacy Notice.

For questions or development suggestions regarding this policy, please contact:

Marita Paajaste
HR Director, Barona
marita.paajaste@barona.fi


Bravedo Oy’s Steering Group approved this policy in October 2025.