LAST UPDATED 4 APRIL2025

HUMAN RIGHTS POLICY

1. Introduction

Bale Capital is committed to conducting its business in a manner that respects the human rights and fundamental freedoms of all individuals. This Human Rights Policy sets out our commitment to upholding internationally recognised human rights throughout our operations, supply chains, and business relationships, in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs), the International Bill of Human Rights, and the International Labour Organization’s (ILO) core labour standards.

2. Scope and Application

This Policy applies to all Bale Capital directors, officers, employees, contractors, suppliers, and business partners. It covers all activities undertaken in connection with our operations, including the sourcing, trading, distribution, and transportation of raw materials such as minerals, rare earths, petrochemical products, and fertilizers.

3. Our Commitment

Bale Capital commits to:

  • Respecting all internationally recognised human rights as set out in the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work;

  • Preventing, mitigating, and addressing adverse human rights impacts through appropriate due diligence and remediation processes;

  • Embedding respect for human rights in our governance structures, risk management systems, and corporate decision-making;

  • Promoting human rights awareness among our employees, contractors, and partners through training and engagement;

  • Operating transparently and ethically, and engaging in meaningful consultation with stakeholders, especially affected communities.

4. Key Focus Areas

Our human rights due diligence process specifically addresses the following high-risk areas:

  • Forced Labour and Human Trafficking: We strictly prohibit the use of any form of forced, bonded, or involuntary labour across our operations and supply chain.

  • Child Labour: We do not engage in or support child labour. All suppliers must comply with the minimum age for employment as defined by applicable laws and ILO standards.

  • Non-Discrimination and Equal Opportunity: We support diversity, inclusion, and equal treatment regardless of race, gender, ethnicity, religion, disability, or other status.

  • Safe and Healthy Working Conditions: We are committed to providing and promoting safe, hygienic, and secure workplaces that meet or exceed national and international standards.

  • Freedom of Association and Collective Bargaining: We respect the rights of employees to form and join trade unions and to bargain collectively in accordance with applicable laws.

  • Indigenous and Community Rights: We respect the rights of indigenous peoples and local communities, including their rights to land, culture, and consultation on matters affecting them.

  • Environmental Impact and Health: We recognise the interconnection between environmental practices and human rights and strive to minimise adverse environmental impacts that may affect human health and livelihoods.

5. Human Rights Due Diligence

We conduct human rights due diligence as an ongoing process, which includes:

  • Assessing actual and potential human rights impacts;

  • Integrating findings and taking appropriate action;

  • Tracking effectiveness of responses;

  • Communicating how impacts are addressed to stakeholders;

  • Reviewing and updating risk assessments regularly in light of changing circumstances.

6. Grievance Mechanism and Remediation

We maintain a grievance mechanism accessible to all stakeholders, including workers, suppliers, and communities, to report concerns related to human rights violations. We ensure:

  • Confidentiality and protection from retaliation;

  • Timely, fair, and transparent investigation of grievances;

  • Appropriate remedial measures for substantiated claims.

7. Governance and Accountability

Oversight of this Policy is vested in Bale Capital’s senior management, with operational responsibility delegated to our Compliance and ESG functions. We monitor performance, review the effectiveness of this Policy regularly, and report progress through our ESG reporting frameworks.

8. Communication and Implementation

This Policy is communicated to all employees and relevant stakeholders and made publicly available on our website. It is integrated into our supplier contracts, codes of conduct, and audit frameworks.

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