Policy statement in accordance with the Supply Chain Due Diligence Act (LkSG) of PSI Transcom GmbH

We, PSI Transcom GmbH, are committed to respecting human rights and protecting the environment in our own operations and in our interactions with suppliers. As required by the Swiss Federal Supply Chain Due Diligence Act (SCSDL), we have developed this statement of principles to outline our commitment to human rights and the environment, as well as our approach to managing related risks in our own operations and in our interactions with suppliers.

This policy statement sets out our guiding principles, explains how we implement the law, describes our risk management process, the complaints procedure and our efforts to achieve continuous improvement.

While we/our employees lead by example, we expect our suppliers and other business partners to also commit to respecting human rights, to undertake to implement appropriate due diligence processes and to pass on these expectations to their own business partners.

This declaration of principles applies to PSI Transcom GmbH (hereafter PSI), based in Germany.

International guiding principles:

PSI respects international standards and guidelines for the protection of people and the environment. Our understanding and our human rights due diligence processes are based on the following international reference instruments:

UN Guiding Principles on Business and Human Rights

United Nations Universal Declaration of Human Rights (UN UDHR)

The core labor standards of the International Labor Organization (ILO) on labor and social standards

Convention on the Rights of the Child (UN Convention on the Rights of the Child)

OECD Guidelines for Multinational Enterprises

The Sustainable Development Goals (SDGs)

Responsibility:

We recognize the importance of clearly defining roles and rights to ensure effective implementation of the LkSG.

We have appointed a human rights officer for PSI, based in Germany, who is responsible for monitoring the implementation of the requirements of the law. She can be reached at untermenschenrechtsbeauftragte@psi.de.

The board of directors/management is responsible for ensuring compliance with the requirements of the law and, accordingly, regularly obtains information about the implementation of due diligence.

We expect our employees, suppliers and business partners to respect fundamental human and environmental rights and to stand up for them within the scope of their abilities. This applies in particular to the risks identified in our risk analysis. If you are unable to see any effective way of taking action in the event of perceived violations, you are encouraged to use the grievance mechanism described in this document.

Realization:

We endeavor to fulfill our human rights and environmental due diligence obligations by taking the following measures:

Regular and event-driven analysis of human rights and environmental risk situations, both in our own business area and among our suppliers (in accordance with Section 5 LkSG).

Implementation of effective preventive measures to counter identified risks and prevent future violations of the law (pursuant to Section 6 LkSG).

Establishing a grievance mechanism for reporting adverse impacts or risks of such impacts on people and the environment occurring in our supply chain (as required by Articles 8 and 9 of the Luxembourg Law on Sustainable Development).

Comprehensive documentation of our risk assessments, measures and the reporting based on them (pursuant to § 10 LkSG).

Risk analysis

As part of our risk management, we conduct regular and ad hoc risk assessments in accordance with § 3 and § 5 LkSG. Once risks are identified, they are prioritized and addressed based on their potential impact on those affected, the likelihood of their occurrence, and the reversibility of the risk.

On the basis of our analyses, we consider the following types of risk to be particularly relevant for our value chain:

Child labor

Forced labor and modern forms of slavery

Disregard of occupational safety and work-related health hazards

Violation of freedom of association, freedom of assembly and right to collective bargaining

Unequal treatment in employment

Withholding of an adequate wage

Illegal land grab / violation of land rights

Contracting or using private/public security forces that contribute to human or labor rights violations due to a lack of training or control

Water, soil and air pollution that can contribute to human rights violations

Mercury: Violation of a ban on the use of mercury under the Minamata Convention

Long-lived organic pollutants (POPs): violation of the ban on the production and/or use of substances within the scope of the Stockholm Convention (POP), non-environmentally sound management of substances containing POPs

Hazardous waste: Violation of the ban on the import and export of hazardous waste as defined by the Basel Convention

Measures:

Once we have identified and prioritized risks, we define the measures we will take to minimize the prioritized risks. We proactively inform and involve stakeholders that we consider important for the implementation of the measures.

In our own business, we communicate our expectations clearly and continuously to employees, and work to ensure that all identified risks are promptly eliminated.

We also communicate our expectations regarding our suppliers’ involvement in the prevention of human rights and environmental risks, and ensure that they understand and commit to these.

In this context, we refer, on the one hand, to the guiding principles mentioned at the beginning and, on the other hand, to the following standards and norms that are particularly relevant for our company and our industry:

ISO 9001 – Quality management

ISO 27001 – Information Security Management

In addition, we work with our suppliers to address identified risks and support improvements in their policies, competencies and procedures. We also encourage our suppliers to work with their own suppliers and to disseminate our expectations and best practices throughout their supply chain.

We regularly monitor and evaluate the effectiveness of our preventive measures to identify and continuously implement possible improvements.

Complaints procedure:

We have an effective grievance mechanism in place to collect information on human and environmental risks that arise in our business and supply chain. We have also appointed a grievance officer and a grievance team. Further details are set out in the publicly available rules of procedure in accordance with Section 8 (2) LkSG.

In the design and application of the process, we pay particular attention to the following features:

Clarity and easy accessibility for anyone who wants to report concerns or suspicions about possible human rights and environmental risks in our own business and supply chains.

Confidential treatment of all reports, with due care for the privacy and safety of the reporting person.

Preliminary assessment of reports to determine whether they relate to a potential human rights or environmental risk in our supply chain or our own operations.

Thorough investigation of all human rights and environmental complaints and taking appropriate action to remedy the risks identified.

Regular feedback to the reporting person about the status of his/her report and the result of the investigation, as far as legally permissible.

14. Detailed recording of all reports and investigations, including any corrective action taken, and retention of this record.

Ensure that whistleblowers are protected from reprisals.

Training our employees (complaint officers and members of the complaints team) to handle information responsibly and effectively.

The complaints procedure can be reached at complains.supply.chain@psi.de.

Continuous Improvement:

We will regularly review the effectiveness of our risk assessments, grievance process, and prevention and remediation measures, and work towards their continuous improvement. This is how we ensure that we remain in line with relevant laws and international standards on human rights and the environment over the long term.

Berlin, den 23.10.2024

PSI Transcom GmbH