Effective Date: May 1, 2023

Rev. 6.19.23

Introduction

MODE Global, LLC (MODE) understands that long-term success starts with a company’s value system and a principled approach to doing business. This policy strives to make clear and transparent how we define, approach, govern and support universal human rights and the dignity of people throughout our operations, our communities in which we operate, and our global supply chain.

Our Commitment

The United Nations Guiding Principles on Business and Human Rights (the UN Guiding Principles) serve as a guiding framework for our work related to human rights. It establishes that the role of government is to protect human rights, the role of business is to respect human rights, and that both can play important roles to remedy adverse human rights impacts if or when they occur. MODE is committed to respecting all internationally recognized human rights, including those described in the Universal Declaration of Human Rights, the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work (the ILO Core Conventions), the Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises, and the UN Global Compact.

Workers’ Rights

The International Labour Organization (ILO) has established eight fundamental Conventions that cover four fundamental rights at work. Collectively, these are covered in the ILO Declaration on Fundamental Principles and Rights at Work (1998) and are also referred to as the ILO Core Conventions.  MODE commits to respect these rights, which are:

• Freedom of association and the effective recognition of the right to collective bargaining;
• The elimination of all forms of forced or compulsory labor;
• The effective abolition of child labor; and
• The elimination of discrimination in respect of employment and occupation.

In addition, we are committed to the following and expect our suppliers and contractors to share in our commitment as may be set forth in our Supplier Code of Conduct:

• We will provide and maintain safe and healthy working conditions that meet or exceed applicable legal standards for occupational health and safety.
• We will not use or tolerate human trafficking.
• We will comply with all applicable laws concerning working hours.
• We view diversity and inclusion as a strength. We respect what each individual brings to our team. We will not tolerate harassment or discrimination on the basis of race, religion, age, national origin, disability, sexual orientation, gender identity or expression, family status, veteran status, or any other protected class.
• We employ ethical recruitment practices and prohibit recruiters from charging recruitment fees to potential employees and from withholding identity documents. Where our employees have employment contracts, we provide access to those contracts. We pay fair wages.

We expect our suppliers to commit to respecting each of the ILO Core Conventions as listed above, as well as other human rights, as detailed in our Supplier Code of Conduct.  As noted therein, MODE expects that its suppliers will cascade similar expectations throughout their own supply chains.

Rights of Vulnerable Groups

We recognize and respect the rights of vulnerable groups around the world, such as indigenous peoples, children, and migrant workers. We expect our suppliers to be similarly committed to protecting the rights of vulnerable groups. The rights of these groups have been established and codified in various international conventions, including:

• United Nations (UN) Convention on the Elimination of all Forms of Discrimination against Women (CEDAW), 1979
• UN Convention on the Rights of the Child (CRC), 1989
• International Convention on the Elimination of All Forms of Racial Discrimination (ICERD), 1965
• International Labour Organization (ILO) Convention 107, Indigenous and Tribal Populations Convention, 1957
• ILO Convention 169, Indigenous and Tribal Peoples Convention, 1991
• UN Declaration of the Rights of Indigenous Peoples (UNDRIP), 2007
• UN Convention on the Rights of Persons with Disabilities (CRPD), 2006

We recognize that around the world women face discrimination, lack access to skills and training, and often lack protection of basic rights and laws. We support women’s rights and economic inclusion, including support for equal pay.

We commit to neither tolerate nor knowingly contribute to threats, intimidation, or attacks against human rights defenders in relation to our operations. We encourage our suppliers to make the same commitment.

Addressing Impacts: Human Rights

We take seriously our responsibility to identify, prevent, mitigate, and remediate human rights related risks and impacts to which we may cause or contribute. We will implement the necessary policies and processes to fulfill each of these responsibilities.

Additional Impacts

We recognize that land, forest, and water rights are important issues affecting communities around the world. We are committed to respecting the rights of local communities and indigenous peoples in relation to their lands, territories, and natural resources. We will not knowingly engage in or support forced evictions, and we acknowledge the importance of obtaining free, prior, and informed consent from affected communities for any activities that may impact their rights. Furthermore, we condemn the use of private or public security forces to intimidate or harm individuals or communities. We believe in the importance of upholding the rights of all individuals, including human rights defenders, and will not knowingly contribute to threats, intimidation, or attacks against them in relation to our operations.

When we discover such adverse human rights or other material impacts, we will investigate, and where appropriate, we will engage with potentially affected stakeholders and/or their representatives with the aim of identifying mutually agreeable solutions or remedies and providing for or cooperating in their remediation through legitimate processes.

Similarly, we expect our suppliers to have processes in place to prevent, mitigate, and remediate adverse human rights or other impacts that they may cause or to which they may contribute, and we expect those suppliers to cascade that expectation as well through their own supply chains pursuant to our Supplier Code of Conduct.

Stakeholder Engagement

We support the communities in which we operate and are committed to engaging with our stakeholders considering their views as we conduct our business.

Privacy

We are committed to respecting the privacy of individuals, including employees and customers. We follow globally recognized privacy principles and strive to implement reasonable and appropriate practices in our collection, use, and sharing of personal information about individuals.

Reporting and Enforcement Mechanism

We put in place several reporting mechanisms and have strong anti-retaliation policies. We monitor our operations and information about our suppliers for potential violations and act if violations occur, up to and including termination of employment or contract. Employees, suppliers, contractors, or others can anonymously report any incidents or concerns using MODE’s ethics hotline available 24 hours per day, 7 days per week by phone, Web, or email.

We do not tolerate retaliation against anyone for raising a concern in good faith as reflected in our non-retaliation policy and our non-retaliation expectations are made clear to our suppliers in our Supplier Code of Conduct.

Disclosure

We report our actions and engagement on human rights in our annual sustainability report. We also make public on our website our values, principles, policies, and practices that this policy reinforces.

Addressing Potential Conflicts

MODE operates in many different jurisdictions subject to different laws and regulations. In situations where our human rights policies are more stringent than local laws, we adhere to our own policies. In situations where laws or regulations in a particular jurisdiction conflict with our policies, we strive to apply our policies and international standards as far as local law allows.