Human and Labor Rights Policy
A - Purpose and scope
1.SUBSTANTIATION
In 2003 the EDP Group subscribed to the United Nations Global Compact, the following year approved its Sustainable Development Principles and, in 2005, published the first edition of the Code of Ethics. No longer than 2006, the EDP Group established a new business strategy setting the priority to renewable energy investment. In 2021, the EDP Group reinforced its growth and internationalization strategy, assuming the “All Green by 2030” ambition and enlarged international recognition, for its ethical excellence and deep respecting of human and labor rights in all dimensions of its activity.
Since the founding years of the internationalization and decarbonization strategy, the Code of Ethics has been updated and revised enabling the organization to face new challenges and risks, tackling the contemporary social transformation, and, in the same way, several policies were published, orienting specific themes, developing the principles established in the Code of Ethics. In this sense, in 2017, the Declaration of Respect for Human and Labor Rights was approved, committing to the United Nations Guiding Principles on Business and Human Rights, including the development of risk maps, deeper reporting on human and labor rights management, enhanced internal procedures, particularly in supply chain management.
Now, taking the strengthening of the internationalization strategy through investment in renewable energy and the revision of the EDP Group’s Code of Ethics, carried out in September 2020, it became necessary to update related policies and procedures, namely the specific policy of respect for Human and Labor Rights.
Accordingly, and informed by international references, listening to stakeholders, the complaints system and the media, the Executive Board of Directors (EBD) decided to update the EDP Group’s Declaration of Respect for Human and Labor Rights Policy (article 14-a), transforming it into the Human and Labor Rights Policy, on July 2021, as follows.
2. OBJECTIVE
The Human and Labor Rights Policy aims to ensure respect for Human and Labor Rights in the EDP Group’s sphere of activity, implementing the commitments defined in its policies, specifying the international reference treaties and standards and establishing the procedures that ensure compliance with them.
3. SCOPE
The Policy applies to all EDP Group companies and employees, business relationship and activities, in all its geographic locations, regardless of the local practices or level of social and economic development.
In implementing the Policy, the EDP Group respects national legislation and international treaties and standards according to the stringent standards. The Policy is in force even though national law may not transpose the international treaties and standards.
B - Internal and external references
4. EDP’s REFERENCES
This Policy develops and implements the principles of respect for human and labor rights established in the following EDP fundamental policies:
a) Code of Ethics
b) Stakeholder Relationship Policy
c) Supplier Code of Conduct
5. INTERNATIONAL STANDARDS AND DIRECTIVES
This Policy transposes to EDP’s sphere of activity the human and labor rights commitments and procedures defined by international standards and directives, namely:
a) United Nations Global Compact
b) United Nations Guiding Principles on Business and Human Rights
c) OECD Due Diligence Guidance for Responsible Business Conduct
d) Directive of the European Parliament and of the Council on Corporate Due Diligence and Corporate Accountability
6. INTERNATIONAL TREATIES AND CONVENTIONS
The Policy sets out for the EDP Group’s sphere of activity its commitment to respect all internationally recognized human and labor rights, namely:
a) Within the scope of the United Nations Organization:
i. “International Bill of Human Rights”, including:
i. Universal Declaration of Human Rights, 1948
ii. International Covenant on Civil and Political Rights, 1966
iii. International Covenant on Economic, Social and Cultural Rights, 1966
ii. Instruments to protect vulnerable people and groups, including:
i. International Convention on the Elimination of All Forms of Racial Discrimination (1965)
ii. Convention on the Elimination of All Forms of Discrimination against Women, 1979
iii. Convention on the Rights of the Child, 1989
iv. International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, 1990
v. Convention on the Rights of Persons with Disabilities, 2006
vi. Declaration on the Rights of Indigenous Peoples, 2007
b) Within the scope of the International Labor Organization (ILO):
i. The eight Fundamental Principles and Rights at Work and related conventions, including:
i. Freedom of Association and Protection of the Right to Organize Convention, (No.87), and the Right to Organize and Collective Bargaining Convention, (No.98)
ii. The elimination of all forms of forced or compulsory labor (Conventions 29 and 105)
iii. The effective abolition of child labor (Conventions 138 and 182)
iv. The elimination of discrimination in relation to employment and occupation (Conventions 100 and 111)
v. Respect Labor Standards on Working time (Conventions 1, 14 and 106)
vi. Protection of Occupational Health and Safety (Conventions 155 and 187, Protocol 2002)
vii. The guarantee of payment of a minimum wage (2008 ILO Declaration on Social Justice for a Fair Globalization).
viii. Understanding the Indigenous and Tribal Peoples Convention, 1989 (No. 169)
ii. The Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy regarding the principles and conventions not included in the eight Fundamental Principles and Rights at Work where applicable.
C - Description and responsibilities
7. STRATEGIC COMMITMENTS
The EDP Group is committed to respecting and enforcing all internationally recognized human and labor rights, identified in article 6. This commitment means:
a) Support the International Bill of Human Rights, subscribe to and implement the Principles of the Global Compact and the instruments to protect vulnerable people and groups.
b) Apply the ILO Declaration on Fundamental Principles and Rights at Work and related conventions and the Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy.
c) Operate a human and labor rights management system that is active and present in all its activities, implementing the United Nations Guiding Principles on Business and Human Rights, the OECD Due Diligence Guidance for Responsible Business Conduct and the Directive of the European Parliament and of the Council on Corporate Due Diligence and Corporate Accountability.
8. ACTION PRINCIPLES
The EDP Group implements its strategic commitments to respect all internationally recognized human and labor rights, identified in article 6, through the application of the following action principles:
a) Identify, prevent and monitor the risks related to human and labor rights that are salient in its sector of activity, developing and keeping a Human and Labor Rights Risk Map up to date.
b) Guarantee it will not be complicit in human and labor rights abuses or disrespect.
c) Recognize as stakeholders: workers and their families, local communities, and any other person or group of people whose lives and environment may be influenced by EDP’s activities, including their legitimate representatives, labor unions, social or environmental organizations.
d) Engage constructively with its stakeholders, especially those affected or likely to be affected by its activities, incorporating their views and concerns within business decisions and the development of its approach to human and labor rights.
e) Avoid adverse impacts that may arise from business operations or relationships, ensuring remediation in the event of their occurrence and undertaking not to retaliate against accusations, and cooperating in initiatives that promote access to remediation through legitimate judicial or non-judicial mechanisms.
f) Ensure the proper functioning of a system to report occurrences and make complaints, with a guarantee of confidentiality and non-retaliation.
g) Communicate and report with transparency its approach to human and labor rights, identifying risks and impacts, mitigation, compensation and remediation measures taken and the results of such actions.
h) Extend the same commitments to its business partnerships and suppliers, working towards to extend these same commitments to their supply chains and their partnerships.
i) Work with its partners and suppliers to mitigate adverse impacts that are directly linked to its operations, products or services through its own mechanisms or through cooperation in the development of third-party non-judicial solutions.
9. ASSIGNMENTS
To ensure effective management of respect for Human and Labor Rights established in this Policy, the EDP Group:
a) Establishes the Human Rights Working Committee, chaired by a director of the EBD, managed by the corporate director responsible for Human and Labor Rights, and made up of the corporate directors with assigned responsibilities in the area of this policy, that is, ethics, sustainability, compliance, legal, auditing, management and labor relations, procurement and supplier management, prevention and safety, risk, and stakeholder management.
b) Assigns a corporate senior director to the strategic and operational management of the Policy implementation, that assumes direct responsibility to the EBD.
10. HUMAN RIGHTS WORKING COMMITTEE
The Human Rights Working Committee works closely together with the Policy director, giving statements on issues to be submitted to the EBD and ensuring consistency of the procedures across all departments and business units. The duties of the Human Rights Working Committee are:
a) Assess the Annual Report and the Improvement Plan, prepared by the Human and Labor Rights corporate director, submitting it to the EBD.
b) Analyze impact assessment and due diligence procedures.
c) Consider and contribute to the salient Human and Labor Rights Risk Map.
d) Advice on the development of performance indicators and provide an opinion on external assessments related to Human and Labor Rights.
e) Analyze negative occurrences relating to Human and Labor Rights and the measures taken.
f) Consider matters submitted to it by the corporate director of Human and Labor Rights.
11. OPERATIONAL PROCEDURES
Policy implementation in field activities is ensured through the adoption of operational procedures that include, in particular:
a) Adopting a risk mapping methodology involving the ongoing updating and quality control of the risk map and salient impacts on human rights related to the EDP Group’s activities, informed by international references, by proactive listening to stakeholders, by the complaints system and by the media.
b) Carrying out and publishing human rights impact assessments (HRIA) or environmental and social impact assessments (ESIA) covering human and labor rights, prepared by independent third parties, whenever substantial infrastructure projects or closures are undertaken, or when entering new businesses or geographies.
c) Communicating human and labor rights to its target audiences in an accessible and appropriate manner, especially to affected stakeholders who raise issues, providing quality information to assess the appropriateness of the response(s), in a way that does not pose risks to stakeholders or affected personnel.
d) Applying human and labor rights criteria when establishing investment partnerships, implementing a Due Diligence system ensuring the United Nations Guiding Principles on Business and Human Rights, as well as the OECD Guidelines for Multinational Enterprises.
e) Applying requirements for assessment, contracting, training, auditing, and exclusion of suppliers regarding human and labor rights practices. Specially for supply chains that are internationally recognized as being at risk, suppliers shall be bound to the following obligations:
i. The obligation to provide complaint channels or mechanisms (proprietary, third-party, or shared).
ii. The obligation to apply conflict minerals regulations and ensure import minerals and metals come from responsible sources.
iii. The obligation to certify contractors that provides infrastructure security.
iv. The application of a Human and Labor Rights Policy and a Due Diligence system implementing the United Nations Guiding Principles on Business and Human Rights, as well as the OECD Guidelines for Multinational Enterprises.
12. ETHICS CHANNEL
The Ethics Channel is accessible to all individuals, workers and citizens, and communities or organizations, that may be adversely impacted by the company or, irrespective of this, that wish to complain, denounce, clarify or expose any situation, i.e. those related to human and labor rights.
13. COMMUNICATION
The communication of this Policy is carried out on a permanent basis, as follows:
a) Published on the corporate website and intranet, as well on the institutional websites of the business units.
b) Communicated, explained, and explicitly made known to and acknowledged by the employees.
c) Integrated within the training plans on Ethics, with special attention given to decision-makers and managers and the salient issues of human and labor rights.
d) Included in the EDP Group’s business relationships with other companies, namely suppliers, equity stakes and joint ventures.
e) Published in the body of the annual report on Human and Labor Rights and disclosed together with the other policies of the EDP Group.
D - Final provisions
14. ENTRY INTO FORCE
a) This Policy replaces the Declaration of Respect for Human and Labor Rights approved in May 2017.
b) The Policy is effective from the date of its approval and for an indefinite period, and may be updated or revised, by deliberation of the EBD.
c) The EDP Group companies are responsible, within the scope of their action, to implement the necessary procedures and actions for the correct implementation of the Policy.
d) The internal standards and procedures impacted by the Policy should be updated to incorporate and ensure their full implementation and periodic updating.
15. ETHICS CHANNEL CONTACT
As of today, the Ethics Channel is available on the Internet at:
a) https://www.canaldeetica.com.br/edpbrasil/
b) https://www.edpr.com/en/make-a-complaint
c) https://www.edpr.com/pt-pt/fazer-uma-reclamacao
d) https://www.edpr.com/es/presentar-una-queja
e) https://www.edp.com/en/contact-ethics-ombudsperson
f) https://www.edp.com/pt-pt/contacte-o-provedor-de-etica
g) https://www.edp.com/es/contacto-con-el-defensor-de-etica
Executive Board of Directors
July 2021
