Human Rights Policy

 

Introduction

Responsible and ethical business practices form the foundation of all Bravedo Group operations. The trust of our stakeholders is essential, and we strive to earn and maintain that trust among our employees, customers and partners.

The Bravedo Group’s Human Rights Policy guides our operations both within the Group and 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 control. It also covers the use of external workforce, procurement, service delivery and customer collaboration.

Subsidiaries may have their own complementary human rights–related policies, but these must be aligned with the Group Human Rights Policy and meet at least the minimum requirements defined in this policy.

Commitments

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

We require employees, customers, partners and subcontractors to comply with applicable laws and regulations. Respect for human rights and fundamental principles of working life is a prerequisite for cooperation with us.

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

• The UN Universal Declaration of Human Rights
• The International Covenant on Civil and Political Rights
• The International Covenant on Economic, Social and Cultural Rights
• The ILO Declaration on Fundamental Principles and Rights at Work
• The OECD Guidelines for Multinational Enterprises

In addition, we take into account the results of Bravedo’s double materiality assessment, which highlights the importance of human rights and social responsibility in our business.

Accessibility

Bravedo’s 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 policy has been prepared in consultation with Bravedo’s Sustainability Committee, which includes representatives from different companies and personnel groups. In addition, Bravedo has conducted a double materiality assessment involving key stakeholders — employees, customers and suppliers. The results of the assessment have been taken into account in the policy content.

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 a person accountable for ensuring implementation and reporting to its board when necessary.

Roles and Responsibilities under the Policy

Human Rights Principles

Human Rights of Employees

We are committed to respecting the human rights of all employees and to promoting equality, non-discrimination and diversity in all our operations.

Occupational health and safety management within the Group is guided by legal requirements and internal practices, such as company-specific equality and non-discrimination plans, occupational safety programmes and procedures for preventing inappropriate behaviour. The objective is to ensure a healthy, safe and inclusive working environment where harassment, bullying or sexual harassment is not tolerated.

Respect for human rights principles and the promotion of equality and non-discrimination are the responsibility of every member of the work community. In certain roles, such as management and supervisory positions, there is an additional employer responsibility to ensure compliance with legal obligations.

Group companies collect annual data on employees’ experiences related to equality and non-discrimination to support continuous improvement. This data is used, among other things, to address potential discrimination and harassment, prevent and eliminate such issues, and identify ways to promote 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

We are committed to ensuring that all customer work is conducted ethically and with full respect for human rights. We do not accept unethical practices within our own operations or within our network.

We require external stakeholders to commit to Bravedo’s Code of Conduct. In addition, suppliers are required to comply with Bravedo’s Supplier Code of Conduct, the acceptance of which is required in procurements managed by Group Procurement.

Subsidiary-level policies further specify human rights and equality objectives and measures in customer work, taking into account the specific characteristics of each business.

Human Rights in the Supply Chain

Bravedo takes human rights into account in its procurement and business relationships primarily by setting clear expectations for suppliers.

In procurements managed by Group Procurement, we require suppliers to comply with national laws, agreements 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. Through this, we communicate our commitment to respecting human rights throughout the value chain. Our aim is to gradually extend this requirement to cover all Group procurement.

Suppliers are responsible for their subcontractors as for their own operations. Requirements for supply chain actors are also defined in the Group’s Procurement Policy.

Human Rights Due Diligence

The Human Rights Policy aims to ensure that human rights are respected and promoted in all Bravedo Group operations.

We are committed to identifying, preventing, mitigating and remedying adverse human rights impacts that are caused by our operations or to which we are linked.

Bravedo is committed to developing and strengthening its human rights due diligence processes in line with international recommendations. Currently, the most important tools are the Group’s double materiality assessment and risk management processes, through which human rights risks are identified and prioritised. Based on these, we will further develop our risk management and actions step by step.

Bravedo is committed to respecting human rights in all its operations. This means that we:

• identify and assess human rights risks as part of our business and value chain
• prevent and mitigate potential adverse impacts in cooperation with stakeholders
• establish reliable reporting and remediation mechanisms
• monitor 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 reports via the electronic reporting channel of the Office of the Chancellor of Justice.

Further information on the handling of reports can be found in Bravedo’s Whistleblowing Privacy Notice.

Contact

For questions or development suggestions related to this policy, please contact:

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