Respect for Human Rights

NSG Group Commitment to Human Rights

At NSG Group, we are dedicated to upholding the highest standards of human rights in all aspects of our operations. We believe that respect for human rights is fundamental to our values and essential for sustainable business success. Our commitment is guided by international principles, including the Universal Declaration of Human Rights and the United Nations Guiding Principles on Business and Human Rights.

NSG Group Human Rights Policy

NSG Group is an International Company operating in many countries around the World. NSG recognizes business cultures and practices around the world are diverse. The NSG Group’s commitment to respecting human rights is reflected in the way we run and operate our business as well as in our polices and guidelines. We respect human rights in accordance with the United Nations (UN) Universal Declaration of Human Rights, the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work, the United Nations Guiding Principles on Business and Human Rights (UNGPs) and, the UN Global Compact including any related conventions.

NSG Group has further identified Human Rights areas which are most relevant for the Group.

• Data protection: NSG Group is committed to protecting the rights and privacy of past, present and prospective customers, suppliers and employees. Information about individuals must be collected and used fairly, stored safely and securely and only be disclosed in a way that is consistent with international best practices and applicable laws and will not be stored for longer than necessary.
• Equal treatment: As a diverse, multinational company, NSG Group aims to create equal opportunities for all employees regardless of any individual difference including, but not limited to, about personal background, race, color, creed, nationality, age, marital/partnership status, pregnancy and maternity, gender, gender reassignment, sexual orientation, religion or other beliefs, ethnic or national origins, disability, union membership, political affiliation, other status protected by law. NSG Group will treat all individuals equal considering the responsibilities of their position during recruitment and selection, compensation and benefits and training, promotion, transfer or termination of employment.
• Fair Wage Practices: NSG Group will pay workers a fair wage and benefits that meets their basic needs and enables them to have an adequate standard of living in the country of their employment, as defined by a credible authority such as the Global Living Wage Coalition.
• Harassment: NSG Group will not tolerate any form (physical or verbal) of sexual harassment, intimidation, and discrimination on the basis of any individual difference including, but not limited to, about personal background, race, color, creed, nationality, age, marital/partnership status, pregnancy and maternity, gender, gender reassignment, sexual orientation, religion or other beliefs, ethnic or national origins, disability, union membership, political affiliation, other status protected by law.
• Abuse of Labor: NSG Group will treat each employee with dignity and respect, and will not use corporal punishment, threats of violence or other forms of physical, sexual, psychological, or verbal harassment, abuse or intimidation.
• Forced Labor: NSG Group will not use forced, bonded, prison, military or compulsory labor.
• Child Labor:  NSG Group will not use child labor. The term "child" refers to any person employed under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest.
• Freedom of Association: NSG Group respects the rights of employees to associate, organize and bargain collectively in a lawful and peaceful manner, without penalty or interference.
• Supplier Principles: NSG Group expects all suppliers to adhere to local laws and regulations, to the articles of the United Nations Universal Declaration of Human Rights and the core standards of the International Labor Organization. Detailed expectations are outlined in the NSG Group Sustainable Supply Chain Charter and Supplier Code of Conduct. For details, click here.

Human Rights Management Framework

The Ethics and Compliance Committee, which is a subcommittee of the Management Committee, decided to form a Human Rights Working Group in 2025 to serve as a forum for discussing human rights issues. The HR, Procurement and Sustainability Departments will participate in this group, which will discuss a wide range of human rights issues both within our own company and along with the value chain. The content discussed within this working group will be reported to the Ethics and Compliance Committee, as well as to the Sustainability Committee which is chaired by the CEO and is overseen by the Board of Directors.

NSG Group's Governance structure for Human Rights

Human Rights Due Diligence

We are committed to conducting robust human rights due diligence to ensure our operations, supply chains, and business relationships respect and promote human rights. This includes:

• Identifying potential and actual human rights risks and impacts through regular risk assessments.
• Preventing and mitigating adverse impacts through targeted actions and policies.
• Monitoring and evaluating the effectiveness of our responses.
• Engaging stakeholders to understand concerns and expectations.
• Providing access to remedy where rights have been adversely affected.

This commitment aligns with international standards such as the UN Guiding Principles on Business and Human Rights and reflects our responsibility to act with integrity, transparency, and accountability.

NSG Group's Salient Human Rights Issues

The Ethics & Compliance Committee has identified the following human rights issues as focus area to the Group. We are committed to proactively addressing these areas to ensure our operations uphold the highest standards of human rights and ethical conduct:

1. Gender equality: We are committed to identifying and eliminating barriers that contribute to gender inequality across our operations. This includes promoting equitable access to opportunities, fair compensation, inclusive leadership development, and a workplace culture that values and respects all gender identities.
2. Equal Treatment and Harassment: We uphold the principle of equal treatment as a core component of our human rights commitment. This means actively ensuring that all individuals-regardless of race, gender, age, religion, disability, or other protected characteristics-are treated with fairness, dignity, and respect.
3. Fair Labor Practices: We are committed to fair labor practices, including the prohibition of forced labor, child labor, and human trafficking. We ensure fair wages, reasonable working hours, and safe working conditions for all employees.

Implementation and Accountability:

1. Training and Awareness: We provide regular training to our employees on human rights issues and our policies, ensuring awareness and understanding at all levels of the organization.
2. Monitoring and Reporting: We continuously monitor our operations and supply chains to ensure compliance with our human rights commitments. We encourage reporting of any human rights concerns including through our confidential Ethics and Compliance Hotline.
3. Collaboration: We collaborate with stakeholders, including governments, NGOs, and industry peers, to promote and uphold human rights standards.
4. Continuous Improvement: We are committed to continuous improvement, regularly reviewing and updating our policies and practices to align with evolving human rights standards.

At NSG Group, we believe that respecting human rights is not just a legal obligation but a moral imperative. We are committed to making a positive impact on the lives of our employees, customers, and communities, and we hold ourselves accountable to the highest standards of ethical conduct.

• Human Rights Policy
• Code of Ethics
• Supply Chain Charter
• Conflict Minerals - Statement
• Supplier Code of Conduct
• NSG Group Health and Safety Policy
• Promoting Diversity, Equity & Inclusion
• Environmental protection
• Modern Slavery Transparency Statement
• Policy statement on the Supply Chain Due Diligence Act issued by German entities (in German only)

Speaking Up (Grievance mechanism)

If any employee (current or potential), third party, contractor, supplier or other external parties believe someone is violating the Human Rights Policy or the law, they are asked to report it immediately to the line or relevant manager, Human Resources, Group Internal Audit, Group Legal, Group Ethics and Compliance or the NSG Group Ethics and Compliance Hotline in accordance with the NSG Group Reporting of Concerns Policy. NSG Group takes concerns seriously and handles them promptly. NSG Group has zero tolerance for retaliation against anyone who speaks openly, in good faith, about conduct they believe is unethical, illegal, or not in line with our Code of Ethics and policies, even if the concern is not substantiated.

For details, click here.

ESG Activities to Highlight:

"End Poverty in all its forms everywhere" - United Nations

We actively support local communities to foster economic resilience and social inclusion. For instance:

• Community Investments: In San Salvo, Italy, we've supported local organizations and communities through various initiatives, such as rebuilding schools after natural disasters and providing scholarships to students.
• Employee Engagement: Our employees actively participate in community projects, exemplifying our core values of mutual respect and social responsibility.

"Ensure healthy lives and promote well-being for all at all ages." - United Nations

We promote health through various global and local initiatives:

• Workplace Health & Safety
  • Each October, we host global Safety Day events centred around a changing annual theme-such as mental health or back-to-basics. These activities promote awareness and support our goal of a zero-incident workplace.
• Mental Health Awareness
  • We actively mark World Mental Health Day, as well as Mental Health Week recognizing the importance of emotional support and mental resilience.
  • In the UK, there is the Wellbeing Hub, bringing together resources and partnerships focused on mental, physical, and financial wellness.
  • Poland is implementing a new wellbeing policy.
  • South America is planning to start a new wellbeing / mental care incentive.
  • In Japan, employees take the Stress Check annually and each department prepares and implements their action plans based on that result accordingly.
• Harassment Prevention Training

  In alignment with our commitment to a respectful and inclusive workplace, harassment prevention training was conducted following the identification of harassment as a key focus area.

  This training reinforces our zero-tolerance policy toward harassment of any kind-whether verbal, physical, visual, or digital-and ensures all employees understand their responsibilities in maintaining a safe and respectful environment.

  The training includes:

  • Clear definitions and examples of prohibited conduct
  • Guidance on how to report concerns confidentially
  • Leadership accountability
  • Resources for support and follow-up

  Ongoing education and reinforcement of these principles are essential to fostering a culture of trust, dignity, and ethical behavior.