Human Rights Policy

LAST MODIFIED: May 2021 

POLICY PURPOSE

Entrustient, Inc. (“Entrustient”) believes in fundamental standards that support our commitment to value and respect our employees, our business partners, our customers, and our communities. We have adopted this Human Rights Policy across all of our operations in order to set forth our values related to working conditions and human rights, and to underscore our philosophy about the way we conduct our business. Entrustient complies with all applicable national laws and international treaties concerning human rights, social rights, and labor rights, consistent with the principles of the United Nations Universal Declaration of Human Rights.

All employees are responsible for complying with this Policy, which is publicly available on our website and communicated internally to all employees. Management will encourage employees to understand this Policy and applicable laws related to it. Non-compliance, depending upon the circumstances, may result in serious disciplinary action up to and including termination of employment.

Entrustient seeks to do business with partners – customers, suppliers and contractors – who share the same commitment to human rights that we have.

DIVERSITY AND DISCRIMINATION

Entrustient is an equal opportunity employer and prohibits discrimination based on race, color, religion, sex, national origin, age, disability, veteran status, pregnancy, sexual orientation, gender identity or expression, or any other reason prohibited by applicable law. In addition, in particular, Entrustient recognizes the benefits of diversity and inclusion and the need to respect and protect the rights of minority and women’s groups.

HARASSMENT PROHIBITION AND DISCIPLINARY PRACTICES

Entrustient is committed to treating employees with respect and dignity and providing a workplace free of sexual harassment or other unlawful harassment. We will not tolerate harassment of employees by managers or co-workers. We will also endeavor to protect employees from harassment by non-employees in the workplace. All Entrustient employees are expected to treat their coworkers, and employees of our customers and suppliers with dignity and respect. Any form of psychological, physical, sexual or verbal abuse, intimidation or corporal punishment will not be tolerated.

COMPENSATION AND WORKING HOURS

Entrustient requires compliance with all applicable compensation laws, including those related to minimum wage, working hours, rest periods and overtime work.

CHILD AND FORCED LABOR

Entrustient will not employ anyone under the age of 16 in any position. Workers under the age of 18 should not perform hazardous work. Where young workers are subject to compulsory education laws, they shall work only outside of school hours and should not work during night hours.

HEALTH, SAFETY AND ENVIRONMENT

Entrustient will seek to provide a safe and secure business environment for the protection of our employees, products, materials, equipment, systems and information. Entrustient will provide a safe and healthy work environment that complies with all applicable laws pertaining to health and safety in the workplace. In addition, effective steps shall be taken to prevent health and safety incidents and occupational injury and/or illness. We strive for continuous improvement in our products and processes to minimize waste and protect the environment. We also work with our suppliers to reduce environmental impact across the supply chain. In addition, Entrustient recognizes the right to water as a fundamental human right.

PROTECTING EMPLOYEE PRIVACY

Entrustient is committed to providing privacy protection of employee data maintained by us. Employee data will be used for the sole purpose of supporting our operations and providing employee benefits. Entrustient has safeguards in place to ensure personal data is protected from unauthorized access and disclosure, including limiting access to such data only to individuals with a legitimate business purpose.

FREEDOM OF ASSOCIATION

Entrustient considers relations with its employees to be good. While we do not believe employees need any third party to stand between them and Entrustient, we recognize that our employees have the right to choose which, if any, organizations they join.

EXPECTATIONS FOR OUR SUPPLIERS

Entrustient’s purchasing department is responsible for ensuring that purchases are made from sources that operate with ethical and responsible business practices. We conduct supply chain assessments when considered necessary in relation to the significance of the purchase and business opportunity. Assessments include in-person reviews and tours of operating facilities, and cover supplier quality, labor practices, compliance with government regulations, and safety.

GUIDANCE AND REPORTING FOR EMPLOYEES

Entrustient strives to create workplaces in which open and honest communications among all employees are valued and respected. We are committed to comply with applicable labor and employment laws wherever we operate. We also ensure employees are aware of this Policy through training. Any employee who has questions about this Policy or would like to confidentially report a potential violation of this Policy, should raise those questions and concerns with local management, Human Resources, or the Legal Department. Employees can also report suspected Policy violations through the Entrustient Governance email (governace@entrustient.com). No reprisal or retaliatory action will be taken against any employee for raising concerns under this Policy. Entrustient will investigate, address and respond to the concerns of employees and will take appropriate corrective action in response to any violation. This Policy is aligned with the Entrustient Company Code of Conduct and Ethics.