Human Rights Policy

This Human Rights Policy outlines Enersense’s commitment to respecting human rights, key human rights impacts and the company’s practices for mitigating human rights risks in its own operations and supply chain.

We expect our employees, suppliers and other business partners, whose activities and omissions may directly affect our operations, products or services, to respect human rights.

Enersense is committed to respecting all internationally recognised labour and human rights standards, including:

• Universal Declaration of Human Rights
• UN Guiding Principles on Business and Human Rights
• Fundamental rights of workers as set out by the International Labour Organisation (ILO), including the ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises

We respect and support human rights and the realisation of employee rights throughout our supply chain, which includes our own operations, our suppliers and other partners. In our business operations, we comply with all applicable laws, regulations, rules and official guidelines. We continuously seek to increase our understanding of our human rights impact and are committed to taking action to address any negative impacts we may identify.

Enersense does not tolerate any form of human rights or labour rights violations. We develop our procedures and business practices to ensure that human rights are respected in all our activities. We also require our partners to commit to respecting human rights and the fundamental rights at work defined by the ILO as part of our Supplier Code of Conduct.

We respect the right of employees to organise, to join or not to join associations and trade unions, and to negotiate collectively with their employer. We do not accept any kind of forced labour, child labour or other forms of modern slavery.

The equal treatment of all employees is one of Enersense’s core principles. We do not discriminate anyone on the basis of ethnic origin, age, gender, family situation, sexual orientation, belief, disability, political views or other similar factors. Furthermore, we do not tolerate any form of bullying or harassment, such as violence, sexual harassment, inappropriate punishment or any type of abuse. All employees must treat other employees with respect and dignity.

Enersense’s Board of Directors approves the company’s Human Rights Policy and is responsible for approving the determination of human rights impacts as part of the double materiality assessment. The members of Enersense’s Group Leadership Team are responsible for ensuring that the personnel in the units they manage are familiar with the Human Rights Policy and comply with it and the operating practices based on Enersense’s Sustainability Team is responsible for drafting and regularly reviewing the Human Rights Policy and developing practices.

Enersense operates in accordance with its human rights due diligence process in its own activities and supply chain. We identify and assess the human rights impacts of our business and aim to prevent and mitigate any negative impacts.

We understand that there are human rights risks in our operations and supply chain, which we identify and assess annually as part of our double materiality assessment.

We monitor the human rights impacts related to our own personnel by means of our WeSense personnel survey, for example. With the survey, we measure employee commitment and identify risks related to discrimination, bullying and harassment. In cooperation with our occupational health care partner, we conduct role- and location- specific workplace surveys in Finland. We monitor occupational safety using our WeCare system, reporting all safety observations, near misses and accidents, among others. We record and assign responsibilities in the system for matters related to accident investigations and corrective measures.

We require that Enersense’s suppliers commit to the company’s Supplier Code of Conduct. Before starting cooperation, we check that our suppliers fulfil their legal obligations. We monitor our key suppliers through audits that include a section focusing on occupational health, safety and rights, the environment and quality. We classify suppliers based on risk, which forms the basis for our audit plans, for example.

We describe our operating practices related to the management of human rights impacts and risks in the section of this Policy entitled Enersense’s most material human rights impacts. We continuously develop our operating practices to mitigate potential negative impacts and risks.

We regularly communicate our commitment to respecting human rights and our efforts to mitigate the most material human rights impacts internally and externally. We report on our human rights efforts in Enersense’s Sustainability Report, published annually as part of the Board of Directors’ Report. Our Human Rights Policy is available on our website at www.enersense.com.

All our stakeholders, such as employees and suppliers, can report suspected abuses or violations of our Human Rights Policy confidentially through Enersense’s ethical channel (Whistleblowing). Reports can be made anonymously through this channel, which is maintained by a third party. The principles of the ethical channel are described in more detail on Enersense’s website in the whistleblowing guidelines.

We encourage our own employees to report any concerns to their superior or his/her superior. In addition, our own personnel can communicate their concerns regarding ethical business practices to the company’s ethics email address, matters concerning harassment or other inappropriate behaviour to the HR email address and security matters to our WeCare system.

We investigate all human rights observations and concerns thoroughly. We clarify and implement corrective measures on a case-by-case basis. We also expect our suppliers and partners to take corrective measures if their activities have negative human rights impacts. We are committed to cooperating with legal entities and organisations, for example, to remedy human rights impacts.

Enersense’s key human rights impacts relate to the health and safety of employees and respect for employee rights in the value chain.

Occupational safety and employee health are top priorities to Enersense. We recognise that our industry involves specific occupational safety risks, for example on construction sites. In addition, some of our personnel and supply chain employees work in challenging conditions, such as at heights or in confined spaces, and in varying weather conditions. To manage safety risks, we continuously develop our safety practices and train our personnel and partners. We conduct safety risk assessments, report all safety incidents, investigate accidents and take corrective measures. We also require our suppliers to commit to the safety of their employees.

We offer preventive occupational safety services, such as health checks and work ability support, taking into account the physical and mental stress factors of the industry. We promote wellbeing at work through open communication, feedback channels and competence development. We are committed to continuously improving our practices in terms of occupational safety, health and well-being, and we regularly monitor the impact of our activities using indicators such as accident frequency, sickness absences and job satisfaction indices. We audit our operations and supply chain in order to ensure that standards are met.

We are aware that we source materials from countries where employee rights may be violated. Some parts of our subcontracting chain may be at increased risk of violations of appropriate working conditions. We take active measures to ensure that the labour rights of our personnel and supply chain employees are realised, including freedom of association, freedom to negotiate collective agreements and appropriate working conditions, and to prevent discrimination, bullying and harassment. We do not accept child labour or forced labour. We also require that our suppliers respect the same principles with regard to their own employees.

Enersense International Plc’s Board of Directors has approved this Human Rights Policy on 3 June 2025.