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Human Rights Policy

Introduction

At Guncast, we believe better business and a better world are inextricably linked. Business can flourish only when human rights are protected and respected, and we have a responsibility to contribute to and ensure positive human rights impacts. This Policy contains overarching principles that embody our commitment to ensure human rights are upheld within our operations and supply chain.

Human rights apply to all individuals regardless of race, color, religion, national origin, ethnicity, age, disability, sexual orientation, gender, gender identity or expression, marital status, military service, and any other status protected by law.  Each Guncast employee (“associate”) has an obligation to other individuals with whom they interact to honor and respect each other’s fundamental human rights.

Our Policy Statement

This Policy outlines the core standards and expectations we have for our business, associates, suppliers, and business partners. This Policy is founded on international standards including the Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, and the principles concerning fundamental rights set out in the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work.

Guncast complies with applicable international and local legal requirements in the countries where we operate.  Where local law conflicts with the requirements of this Policy, Guncast will comply with local requirements while striving to uphold the principles set forth in this Policy.

This Policy applies to Guncast and its related entities at all its facilities worldwide. Guncast also expects its suppliers, contractors, and agents to uphold these principles within their own businesses. Suppliers must also uphold the principles outlined in Guncast’s Supplier Code of Conduct.

Policy Oversight

The most senior Human Resources executive, Labor and Employment executive, and Compliance and Ethics executive are responsible for the interpretation and execution of the Policy. These executives, along with Guncast’s operating executives, will ensure that the Global Human Rights Policy is upheld in all aspects of Guncast’s business.

Our Commitment

Guncast strives to provide a respectful, safe, and healthy working environment for all our associates as stated in our Code of Ethical Conduct. Guncast recognizes its commitment and responsibility to the following:

Health and Safety: Guncast operates all its facilities in a safe and responsible manner that protects the health and safety of our associates and the communities in which we operate.  Guncast complies with applicable health and safety laws, regulations, and its own internal requirements.

Compensation: Guncast is committed to providing wages and benefits to our associates that are competitive in relation to the industry in which they work and the local labor market.  Guncast pays its associates equitably for all hours worked in full on a timely basis by following all relevant wage and hour laws and regulations.

Hours Worked and Rest Periods: Guncast follows all laws, regulations, and our internal policies on maximum hours worked, days of rest, and break periods to ensure that our associates can perform their work in a safe and healthy manner.

Diversity, Equity, and Inclusion and Non-Discrimination: Guncast prohibits discriminatory practices with respect to all aspects of the employment relationship and promotes and embraces equal opportunity and diversity, equity, and inclusion for all its associates within its business operations.  Guncast has zero tolerance for unlawful discrimination or conduct that negatively impacts an associate or group of associates based upon any legally protected characteristic.

Harassment and Respectful Workplace: Guncast will not tolerate individuals or groups of individuals creating an intimidating, hostile, abusive, or offensive work environment for Guncast associates or contractors.  Such conduct is considered harassing and disrespectful, and it is prohibited in all phases of the employment relationship.

Child Labor: Guncast prohibits the use of child labor in our operations and supply chain that is in violation of local laws and regulations or international standards.  Guncast condemns all forms of child exploitation and will never permit a child to perform work that may threaten their health and safety or negatively impact their educational training.

Freedom of Association: Guncast respects our associates’ right to join or not join a legally recognized organization, such as a labor union, without fear of reprisal, intimidation, or harassment.  We are committed to collective bargaining in good faith in situations where our associates have legally elected a freely chosen representative.

Forced Labor and Human Trafficking: Guncast prohibits the use of all forms of forced, bonded or compulsory labor, prison labor, indentured labor, and any form of human trafficking. All employment is freely chosen and associates are free to end their employment with us at any time.  Where required, associates have written contracts of employment that comply with local legislation and are clear about wages, benefits, notice, and other job-related requirements.

Freedom of Movement and Documentation: Guncast prohibits unreasonable restrictions on its associates’ freedom of movement in the facility and prohibits any unreasonable restrictions on associates entering or exiting company facilities.

As part of the hiring process, workers are provided with required documents relevant to their employment in a language they understand with a description of the terms and conditions of employment.  Guncast and its agents are prohibited from holding or otherwise destroying, concealing, confiscating, or denying access by associates to their identity or immigration documents, such as government-issued identification, passports, or work permits, unless such holdings are required by law.

Ethical Recruitment: Guncast maintains a “no fees” recruitment policy that applies to our internal operations as well as any agents that represent Guncast during the job recruiting process. We do not ask for or require money or charge fees to applicants or our associates or their families for the purpose of being hired or as a condition of maintaining employment. We require all third-party recruiting agencies to adhere to a “no fees” recruitment policy for applicants as well.

Responsible Sourcing

Guncast has an extensive and diverse supply chain, and our suppliers are an integral part of our business and a critical link to the fulfillment of our mission to source responsibly and sustainably. Our Supplier Code of Conduct communicates our expectations that our suppliers will practice the highest legal and ethical standards when conducting our business, including expectations with regards to the respect for the human rights, including labor rights, of the workers in our extended supply chain. We will only work with suppliers who certify they will follow our Supplier Code of Conduct or provide their own code that meets all minimum standards of Guncast’s Code.

Addressing Human Rights Impacts

We perform due diligence to identify and prevent human rights risks to people in our business and supply chain.  Human Rights due diligence is an ongoing process that requires keen attention during changing business conditions or the establishment of new business relationships.  We recognize that during these times it is necessary to perform additional due diligence to assess and mitigate the increased risks. When registering, suppliers are assessed on their human rights and forced labor risk. If deemed appropriate, further review will include self-assessments and onsite audits.

Reporting and Remedies

We continue to build the awareness and knowledge of our associates through training on human rights and encourage them to speak up through our reporting mechanisms. Guncast provides an Ethics Helpline for internal reporting that is available to our associates in their native language.  Our associates may also choose to report potential violations of this policy to management or human resources representative.

If we identify adverse human rights impacts resulting from or caused by our business activities, we are committed to provide for or cooperate in fair and equitable remediation. We are committed to increasing the capacity of our management team to effectively identify and respond to concerns if they arise.

Violations: Guncast associates who violate this policy will be subject to discipline, up to and including, termination of employment.  Suppliers and agents who fail to comply with this policy or the Supplier Code of Conduct, where applicable, will be subject to termination as a supplier or agent.