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Introduction

Transition Industries (the “Company”), including its subsidiary Pacifico Mexinol (“Mexinol”), is committed to upholding and acting in accordance with the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, the Voluntary Principles on Security and Human Rights and the International Finance Corporation’s Performance Standards. 

Respect for Human Rights is embedded across Company policies, procedures, and practices. The Company Code of Conduct provides a framework to ensure we do the right thing which includes commitments to respecting human rights and requiring all of our employees, contractors and business partners to operate responsibly.

The Company is committed to the elimination of forced and compulsory labor and the abolition of child labor. Where applicable, we commit to respecting Indigenous Peoples’ rights in a way that respects their history, culture, and customs within legal and constitutional frameworks. We also do not tolerate any forms of discrimination and harassment, including gender-based, in our workplace.

Our policies and practices on Human Rights apply to labor and the workplace; suppliers and procurement; Indigenous Rights; local context; and land, environment and community rights.

Purpose

The purpose of this policy is to outline, inform and uphold our commitment to:

  • Conducting business responsibly and have zero tolerance for abuses of human rights in our workplace, in our communities, or across our supply chain
  • Rejecting all forms of modern slavery and not employing children under the age of 15, or children under the age of 18 for hazardous work.
  • Conducting business practices in accordance with the local laws and the Company Codes of Business and Ethical Conduct
  • Assessing annually operational impacts and potential human rights risks.
  • Developing and implementing action plans that mitigate risk, which are regularly reviewed and improved.
  • Ensuring that vulnerable individuals, including women and Indigenous People, are inclusively engaged, their needs identified and measures put in place to mitigate risks and enhance benefits.
  • Maintaining a program of engagement with both authorities and communities for the planning and development of all projects, focused on cooperation that is advantageous for all parties and ensuring the disclosure of our plans and activities.
  • Respecting the right of access to information in our engagement with stakeholders.
  • Engaging with local and Indigenous communities within a Projects’ general area of operations in a way that is culturally appropriate, timely, and respectful of all parties involved.
  • Incorporating stakeholder concerns and feedback on any perceived operational impacts to the environment and local communities as a result of project activities.
  • Providing a work environment free of harassment, discrimination, or bullying, as well as specific measures to prevent Gender Based Violence and Harassment.
  • Respecting the rights to freedom of speech, expression, association, and collective bargaining.

Legal Frameworks

The policy is aligned with the following legislature and frameworks:

  • The Universal Declaration of Human Rights
  • The United Nations Guiding Principles on Business and Human Rights
  • The International Labor Organization’s Declaration on Fundamental Principles and Rights at Work
  • The Voluntary Principles on Security and Human Rights and the International Finance Corporation’s Performance Standards.
  • Relevant legislation in the country of the Project

Scope

This policy applies to personnel, including employees as well as temporary or contingent workers. We expect our suppliers, contractors, and business partners to adhere to this policy. It shall be signed by managers, employees, contractors and subcontractors, reflecting acknowledgement and commitment with the implementation.

Your responsibility

Employees and contractors must follow all applicable provisions and the spirit and intent of this corporate governance document and support others in doing so. Employees and contractors must promptly report any suspected or actual violation of this corporate governance document through available channels so that the Company can investigate and address it appropriately. Employees and Contractors who violate this corporate governance document or knowingly permit others under their supervision to violate it, may be subject to appropriate corrective action, up to and including termination of employment or contract, as applicable, in accordance with the Company’s corporate governance documents, employment practices, contracts, collective bargaining agreements and processes.

Interpretation and administration

The Company has sole discretion to interpret, administer and apply this corporate governance document and to change it at any time to address new or changed legal requirements or business circumstances.

Non-retaliation

The Company supports and encourages employees and contractors to report suspected violations of corporate governance documents, applicable laws, regulations, and authorizations, as well as hazards, potential hazards, incidents involving health, safety, security or the environment. Such reports can be made through available channels. The Company takes every report seriously and investigates it to identify facts and, when warranted, makes improvements to our corporate governance documents and practices. All employees and contractors making reports in good faith will be protected from retaliation. Good Faith Reporting will not protect employees and contractors who make intentionally false or malicious reports, or who seek to exempt their own negligence or willful misconduct by the act of making a report.

Policy Guidelines and Responsibilities

This policy is the joint responsibility of the Head of Corporate Affairs and Head of ESG and implemented and overseen at the project-level under the direct supervision of the Mexinol Community Relations Manager.