Human Rights Statement

Respect for individuals and human rights is at the core of Kultera’s culture. We believe that each person has an obligation to respect human rights. We base our approach to human rights on international standards and agreements, including the United Nations’ Universal Declaration of Human Rights and the Guiding Principles on Business and Human Rights.

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Human rights are generally defined as the basic freedoms believed to be inherent to all people, and are outlined in the Universal Declaration for Human Rights, www.un.org/en/documents/udhr.

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The Universal Declaration focuses on dignity, respect, and equality, without discrimination. These are principles that lie at the core of Kultera’s values. We are committed to treating everyone – including our employees, clients and suppliers, and the communities in which we operate – with dignity, respect and equality, and also partnering with our stakeholders to help them to do the same.

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Our Human Rights Program

It is our policy to comply with all applicable laws, rules and available regulations concerning labor practice in all the countries in which we operate. In addition to our own employees, we expect all our partners, distributors, resellers, advisors, consultants, contractors, agents and other intermediaries representing us to adhere to the dictates contained in our Code of Business Ethics and in this Human Rights Policy Statement.

• We respect the rights of our employees to freely associate with anyone they choose and we support a constructive dialogue with our employees or their chosen representatives.

• We support a workplace that is free of violence and harassment. We shall not engage in or tolerate the use of corporal punishment, mental or physical coercion or verbal abuse of personnel. No harsh or inhumane treatment is allowed.

• The compensation of our employees meets or exceeds the legally required minimum.

• We comply with local minimum age laws and requirements (or those prescribed by international standards if more stringent). We will not employ child labor or permit forced labor.

• We limit the working hours per day and grant recovery time, according to labor laws.

• We provide a safe and health-promoting workplace for all our employees, according to local labor protection laws.

• We will not engage in human trafficking and will not knowingly work with those who do.

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Our Commitment to Integrity

• We work every day to ensure an open, inclusive and ethical work environment in which our employees strive to do the right thing to serve our many stakeholders and to ensure the long-term success of Kultera and our valued partners.

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Our Supply Chain

• Kultera is committed to high standards of ethical and business conduct as it relates to its procurement of goods and services.

• Kultera treats its suppliers with respect and integrity and is dedicated to serving as a good partner to the many companies who help us meet our mission.

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Training and Communication

Effective training and communication are critical to the success of our human rights program. Kultera provides periodic training to all employees on various elements of our human rights program.

Kultera communicates with employees about the importance of human rights and the underlying principles of respect, dignity and equality.

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Reporting, Investigation and Corrective Actions

Any employee who believes there may have been a violation of this Policy should report it through established channels, including to their supervisor or human resources.

Reports of potential violations will be investigated and, if substantiated, remedial action will be taken. Kultera will not tolerate any retaliatory action against someone who comes forward in good faith to raise concerns about possible violations of this Policy.

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Oversight

We assess potential human rights risks, the severity of the potential risk, and the relevant mitigation measures. We integrate relevant findings into our policies and procedures as needed, based upon assessments. We track various aspects of our progress as part of Kultera’s efforts to continuously improve.

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Assessment

Kultera may conduct additional audits or assessments, as appropriate, to measure compliance related to various of the above commitments.

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