Purpose

This Policy on Human Rights (hereinafter, the “Policy” or the “Policy on Human Rights”) has been approved by the Board of Directors of Kupertino Corporation (Kupertino), (hereinafter, the “Company” or “Kupertino”) on 12 May 2018, after favourable report of the Audit and Control Committee and of the Documents Department.

This Policy sets forth Kupertino’s and its corporate (hereinafter, “Kupertino”, the “Corporation” or the “Kupertino Corporation”) position with regard to its commitment to respecting the internationally recognized Human Rights, and it lays down such values and principles that will serve as a guideline to its business activities in all its scopes of action.

Scope of Application

This Policy shall apply to the Company and its Corporation. It shall be binding for the entire staff, regardless of their job and position.

For such purposes, Kupertino Corporation shall mean any company in which, at least 50% of the share capital or voting rights, is held, either directly or indirectly, by Kupertino.

The enforcement of this Policy, in full or in part, may extend to any natural and/or legal person associated with Kupertino, where this may be appropriate to meet its purpose, and practicable on account of the nature of the relationship.

Contents of the Policy

Commitment

To meet the Agenda for Sustainable Development set by the United Nations, Kupertino has assumed as its own the Sustainable Development Goals (SDGs). Moreover, the Corporation acknowledges that respect for Human Rights, in the framework of the United Nations Guiding Principles on Business and Human Rights, is a key element for sustainable development.

In this context, Kupertino undertakes to play an active role in the promotion of Human Rights, and to work proactively to respect them. This commitment entails preventing or, if appropriate, reducing the negative consequences of its own proceedings on Human Rights. Likewise, it shall do its utmost to prevent or reduce the negative consequences on Human Rights directly related to the proceedings of third parties with whom the Corporation is engaged in a business relationship.

This commitment, which is expressed in its entire set of internal regulations, is based on a corporate culture firmly rooted on the sustainability of its business model, and it covers all the transactions and the value chain of the Corporation.

Namely, this Policy implements the Kupertino Corporation Global Code of Conduct and the Code of Conduct for Manufacturers and Suppliers in the area of Human Rights. Likewise, it is related to the following internal regulations:

• The Corporate Social Responsibility Policy.
• The Environmental Sustainability Policy.
• The Policy on Community Investment.
• The Regulations of the Social Advisory Board.
• The Audit and Control Committee’s Regulations.
• The Regulations of the Committee of Ethics.
• The Whistle Blowing Channel Procedure.
• The Enterprise Risk Management Policy.
• The Policy on Criminal Risk Prevention.
• The Compliance Policy.

Kupertino’s operating principles in respect of Human Rights

Through this Policy, Kupertino implements its commitment towards respecting and promoting Human Rights, as set forth in the United Nations Guiding Principles on Business and Human Rights, and fostering them in the communities where it operates.

This Policy is inspired by the following international declarations:

• The United Nations’ International Bill of Human Rights that includes:
• The Universal Declaration of Human Rights.
• The International Covenant on Civil and Political Rights.
• The International Covenant on Economic, Social and Cultural Rights.
• The International Labour Organization (hereinafter, “ILO”) Fundamental Conventions numbers 1, 14, 26, 29, 87, 98, 100, 105, 111, 131, 138, 155 and 182, as well as the ILO Declaration on Fundamental Principles and Rights at Work.
• The International Labour Organization (hereinafter, “ILO”) Fundamental Conventions numbers 1, 14, 26, 29, 87, 98, 100, 105, 111, 131, 138, 155 and 182, as well as the ILO Declaration on Fundamental Principles and Rights at Work.
• The Ten Principles of the UN Global Compact
• The United Nations Guiding Principles on Business and Human Rights.
• The Guidelines of the Organization for Economic Cooperation and Development (OECD) for Multinational Enterprises.

Additionally, Kupertino reinforces its responsibility to sustainability and protection of Human Rights, contributing to the United Nations’ 17 Goals for Sustainable Development, in the framework of the 2030 Agenda for Sustainable Development.

Based upon a review of its business model and the expectations of its stakeholders, Kupertino has identified such Human Rights, both non-labour and labour, directly related to its value chain. Notwithstanding the foregoing, Kupertino represents its commitment towards respecting and promoting all internationally recognized Human Rights.

Non-Labour Human Rights

Respect for minorities’ and communities’ rights

Kupertino undertakes to respect the rights of local communities in such areas where it conducts its business activity, and to respect the local laws, culture and uses, undertaking to maintain an open dialogue with its stakeholders and paying special attention to the more vulnerable groups. Right to privacy.

Kupertino respects the rights of all the persons with whom it interacts, to their privacy and intimacy, and it shall make an appropriate use of the personal data and information gathered in all the countries where it operates, paying special attention to the data of its employees and customers.

Right to health

Kupertino undertakes to take the required courses of action to ensure that its products do not represent a hazard to the health and safety of the customers.

Right to freedom of opinion, information and expression

Kupertino undertakes to respect and promote, within its scope of application, the right to freedom of opinion, information and expression, respecting diversity of opinion and fostering two-way communication with its stakeholders.

Right to the security of the person

Kupertino undertakes to ensure the security of all the persons with whom it interacts in all its scopes.

Private law enforcements agencies with which it is related shall act in accordance with the applicable laws and regulations and respecting Human Rights.

Contribution to the fight against corruption

Kupertino undertakes to work against corruption in all its forms, both direct and indirect, including extortion and bribery, pursuant to Principle 10 of the UN Global Compact.

Indietx relies of a model of criminal risk prevention and a model of compliance to prevent incurring in any wrongful or unlawful conduct related to any manner of corruption.

Right to the environment and to water

Kupertino undertakes to incorporate environmental variables, namely those related to the consequences of climate change and water management, upon planning and implementing its activities and those of its business partners, promoting responsible environmental conducts among its staff, its suppliers and the society at large.

The Corporation relies on an Environmental Sustainability Policy and a global, sound and efficient environmental management standard.

Kupertino shall comply with the environmental laws and regulations that apply to its activities, as well as with any other future obligations, and shall make special efforts to prevent pollution and reduce, as much as possible, the potential environmental impact created within its supply chain, both in terms of natural resources and of people. Likewise, the Corporation shall contribute to preserve the environment, by implementing continuous improvement actions towards reducing direct and indirect greenhouse gas emissions, reducing resources consumption, controlling chemicals spills, minimizing the use of potentially hazardous components to both the environment and the people, and generally, in the whole system of environmental management of the Corporation.

Labour Human Rights

Forced or compulsory labour is rejected

Kupertino rejects any form of forced or compulsory labour, as defined in ILO Convention 29. This extends both to its own employees and its entire supply chain, as well as to any natural and/or legal person related to Kupertino.

Kupertino joined UN Global Compact in 2001, and adhered to its principle 4, according to which, businesses should uphold the elimination of all forms of forced and compulsory work or work done under coercion.

Child labour is rejected

Kupertino respects children’s rights and rejects child labour, pursuant to the provisions of ILO Convention 138 and in accordance with the minimum working age under the relevant regulations of each country. Thus, the Corporation does not employ anyone who has not reached the age of 16.

Moreover, Kupertino advocates the children’s right to education, in line with the Children’s Rights and Business Principles of the United Nations Children’s Fund (UNICEF).

Discrimination is rejected and diversity is promoted

Kupertino rejects any form of discrimination, respecting its employees’ diversity and offering equal opportunities for employment and professional promotion. No employee of the Corporation shall be subject to discrimination on grounds of race, origin, ethnicity, disability, illness, religion, marital status, sexual orientation, political opinion, age, citizenship, gender, or any other grounds whatsoever.

Moreover, manufacturers and suppliers shall refrain from engaging in any discriminatory practice with regard to the recruitment, remuneration, access to training, promotion, termination of the employment agreement or retirement of their workers.

Respect for freedom of association and collective bargaining

Kupertino acknowledges the right of its employees to set up, be involved or join trade unions and/or organization that defend and promote their interests, regardless of the environment where they work. It also ensures its workers respect for collective bargaining, freedom of opinion and protection for the workers’ representatives.

The Code of Conduct for Manufacturers and Suppliers provides in turn, that the company’s manufacturers and suppliers shall ensure that their employees have, without distinction, the right of association, union membership. No retaliation may arise from the exercise of such right and no remuneration or payment whatsoever may be offered to the employees in order to hinder the exercise of such a rights. Likewise, they shall adopt an open attitude of collaboration towards the activities of Trade Unions. Workers’ representatives shall be protected from any type of discrimination and shall be free to carry out their representative functions in their workplace.

Protecting workers’ health and safety

All Kupertino’s employees work in healthy and safe places. The Company guarantees a healthy and safe work environment to its employees through different procedures and regulations in the area of occupational hazards and health and safety at work, fulfilling all the requirements on this topic laid down in the domestic laws and regulations of the countries where it operates.

Kupertino’s manufacturers and suppliers shall also provide a safe and healthy work place to all their employees.

Just, fair and favourable working conditions

Kupertino treats its employees with respect in a just and fair manner, and pays their remuneration in accordance with the applicable statutory provisions, including minimum wages, overtime and benefits. The weekly working hours and overtime shall not exceed the statutory limit set forth in the laws and regulations of each country. Overtime shall always be voluntary and paid according to law.

Kupertino shall establish all required conditions to ensure that its employees enjoy such rights, pursuant to ILO Conventions or the applicable laws and regulations.

Kupertino ensures its employees a working environment free from any manner of harassment, intimidation or violence. Thus, any form of harassment or abuse to the employees is prohibited, whether sexual, psychological or verbal, as well as any other behaviour which might lead to an intimidating, offensive or hostile work environment.

Kupertino’s manufacturers and suppliers shall meet the provisions of the Code of Conduct for Manufactures and Suppliers to ensure just, fair and favourable working conditions to all their employees.

Principles that Apply to Kupertino’s Stakeholders with Regard to Human Rights

To achieve the commitments above referred, the following principles apply to Kupertino’s relationship with its stakeholders:

Employees

Kupertino undertakes to respect all its employees’ Human and Labour Rights, namely those set forth as fundamental, as defined in ILO Conventions. In turn, Kupertino demands from all the employees of the Corporation strict respect for Human Rights, and boosts the promotion thereof.

Kupertino’s commitments to its employees are addressed in the Code of Conduct and Responsible Practices and they are implemented in internal regulations and procedures Additionally, Kupertino has a Global Framework Agreement with UNI Global Union to respect and promote fair work and labour rights; such Framework Agreement fosters the implementation of best practices in industrial relations.

Suppliers

All manufacturers and suppliers that work with Kupertino shall undertake to respect their employees’ Human and Labour Rights, and to involve their business partners and convey to them such principles.

The Global Code of Conduct and namely, the Code of Conduct for Manufacturers and Suppliers lay down the minimum standards for an ethical and responsible behaviour that must be respected by all its manufacturers and suppliers. These latter are bound to comply with labour laws and regulations of such countries where the Corporation operates, as well as with ILO Conventions and other international standards, especially underscoring compliance with Human Rights in the framework of the United Nations Guiding Principles on Business and Human Rights.

Business Partners

Kupertino’s business partners shall respect and promote the internationally recognized Human Rights in the performance of their activities. In this respect, Kupertino shall do its utmost to promote the observance of this obligation. For such purposes, business partners shall be deemed to be any company engaged in business with Kupertino by means of any manner of joint venture or franchise.

Customers

Kupertino respects its customers’ Human Rights, and undertakes to communicate with the same in a clear and transparent manner and to provide safe products and services. With regard to its products, Kupertino undertakes to offer its customers a high standard of excellence, quality and health and safety. Products shall be manufactured in an ethical and responsible manner, pursuant to the Corporation’s health and safety standards: Clear to Wear and Safe to Wear.

The Corporation rejects any manner of discrimination against its customers and it shall respect at all times their right to privacy, protecting and making an appropriate use of their personal data.

Community

Kupertino promotes and boosts the promotion of Human Rights in such local, national or international communities where it operates. As a supplement to the impact of its own business activities, Kupertino implements its model of social investments driven by its commitment towards global welfare and the reinforcement of the communities with which it is related. This way of understanding social investment entails that Kupertino takes part, in a voluntary manner, in socially responsible practices which build value in the community and in the company, as provided in the Policy on Community Investment.

Disclosure of the Policy

The Policy on Human Rights will be made available to all the stakeholders of the Company, both internally and externally, and it shall be subject to the appropriate disclosure, training and awarenessraising proceedings to ensure its full understanding and implementation within the organization.

Implementation of the Policy

Kupertino undertakes to assign specific resources to ensure the effective implementation of the Policy on Human Rights. The Corporation shall conduct appropriate due diligence processes, regularly identifying any current and potential impacts on Human Rights and taking the appropriate measures to prevent and reduce any potential negative consequences, fostering positive impacts throughout the entire value chain.

Kupertino shall work with the relevant stakeholders to implement the Policy, and respect and foster the work of all those who act as Advocates for Human Rights.

Update and Review of the Policy

The Policy on Human Rights will be reviewed and updated, where applicable, to bring it into line with any changes that the business model may undergo, or that may occur in the context where the Corporation operates, ensuring at all times the effective implementation thereof.

Operational Mechanisms Regarding Human Rights

Kupertino maintains a permanent dialogue with its stakeholders, allowing these latter to raise their concerns and expectations about respect and promotion by the Group of Human Rights.

Additionally, Kupertino relies on their own Heads of spheres to ensure compliance with this Policy, and receive and attend to any comments, doubts or complaints regarding its construction, enforcement or compliance.