Human rights policy

HUMAN RIGHTS AND GENDER EQUALITY POLICY

0. FOREWORD

No company, regardless of its size, international footprint, or purely local scope, can shirk its role; every enterprise is required to respond tangibly to the principles of Social Responsibility.
Therefore, E.D. Express Delivery S.r.l. aims to play a leading role in guaranteeing and safeguarding human rights—not only because it is mandated by the Universal Declaration of Human Rights, but also because it is demanded by the market and by policies governing fair worker relations.
Furthermore, E.D. Express Delivery S.r.l. is increasingly focusing on sustainable practices to comply with E.S.G. (Environmental, Social, and Governance) criteria, which represent the three essential factors for measuring corporate sustainability.
E.D. Express Delivery S.r.l. has chosen to impact human rights in various ways: through its core business activities, commercial relationships, and procurement processes. The definition of human rights encompasses the fundamental rights and freedoms recognized by international agreements, founded upon the principles of dignity, equity, equality, and respect. Within the company, these principles translate into the proper management of human capital, equal opportunities, fair working conditions, as well as issues related to health, freedom of expression and religion, workplace safety, and the prevention of all forms of discrimination.
E.D. Express Delivery S.r.l. believes that doing business today means continuously evaluating the impact of its operations on individuals and the communities in which it operates, while maintaining high levels of vigilance and control across the entire supply chain.
Respecting human rights makes it possible to provide concrete responses to the concerns of customers, workers, and the market. Moreover, recognizing and upholding employee rights directly enhances corporate performance, fostering greater worker retention and improving the overall quality of work and customer service.
Beyond this, by adopting these best practices, every company can become an active agent of positive change. In this context, E.D. Express Delivery S.r.l. is committed to promoting responsible business conduct at all levels of its supply chain, respecting and contributing to the protection of all individual rights.
This "Human Rights and Gender Equality Policy" (hereinafter referred to as the "Policy") defines the core principles underpinning this commitment to respect and promote fundamental human rights and to prevent or mitigate any adverse impacts of its activities through a risk assessment approach guided by leading national and international standards.

1. SCOPE OF APPLICATION

This Policy details the fundamental principles that our organization respects and strives to enforce wherever it operates, directly or indirectly, across each of the following stakeholder groups:

- Workers
These are the individuals whose professionalism, creativity, and dedication have shaped our history and continue to be key drivers of corporate success. Everyone working directly or indirectly for our organization is committed to adhering to this Policy.

- Customers
E.D. Express Delivery S.r.l. assigns a central role to the customer. Every touchpoint represents an opportunity to welcome, understand, engage, and collect valuable feedback for continuous improvement. In addition to delivering a sustainable customer experience, every corporate project and initiative is marked by deep customer care and respect for the individual.

- Community
E.D. Express Delivery S.r.l. has always been committed to respecting the communities adjacent to its operations and maintaining an open, collaborative dialogue. This active relationship stems from the awareness that corporate development can only occur in harmony with, and in full respect of, the local operating environment.

- Suppliers
E.D. Express Delivery S.r.l. requires its suppliers and any entity acting on its behalf to comply with the principles and content of this Policy. All suppliers must thoroughly review and adhere to the principles and conduct rules set forth herein. Our organization proactively promotes the rights established in this Policy and their associated social development. It does not tolerate or contribute to threats, intimidation, or attacks against human rights defenders, and expects its suppliers to demonstrate the same level of commitment.

2. INTERNATIONAL REFERENCE STANDARDS

This Human Rights Policy is inspired by key international and national legislation and regulations regarding human rights, including:

- The International Bill of Human Rights (UN)

- The Universal Declaration of Human Rights

- The International Covenant on Civil and Political Rights

- The International Covenant on Economic, Social and Cultural Rights

- The Charter of Fundamental Rights of the European Union

- Decent Work Standards established by ILO (International Labour Organization) Conventions

- The UN Convention on the Rights of the Child

- The UN Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW)

- The UN Guiding Principles on Business and Human Rights

- The UN Sustainable Development Goals (SDGs)

- Italian Legislative Decree 231/2001.

In addition to requiring compliance with applicable laws, this Policy sets out requirements based on international principles that may, in certain cases, be more stringent than local laws and regulations. Where the requirements of this Policy are stricter than applicable local laws without conflicting with them, the higher standards set forth in this Policy shall prevail.

3. PROMOTION AND RESPECT OF HUMAN RIGHTS

E.D. Express Delivery S.r.l. recognizes that long-term corporate growth cannot exist without responsibility and respect for fundamental human rights. Over the years, this awareness has led to a strengthened commitment through collaboration with all stakeholders to define and execute effective, concrete solutions. These include adopting specific measures to prevent or eliminate human rights violations, performing audits (both directly and via third parties), and implementing corrective measures or, in severe cases, terminating business relationships with non-compliant parties. Specifically, we are committed to promoting, respecting, and enforcing the following principles:

- Prohibition of Child Labour
The protection of children's rights is a non-negotiable principle. Neither child labor nor the exploitation of children in any activity—including the entire supply chain—is tolerated. No person below the legal minimum working age established by the laws of the country where the organization or its suppliers operate (and in any case, no person under 15 years of age) shall be employed. Furthermore, the nature of the work, duties, and working conditions for employees under 18 years of age must comply with applicable law and must never endanger their physical, mental, or moral health and safety, nor interfere with compulsory schooling.

- Prohibition of Forced/Compulsory Labour and Human Trafficking
E.D. Express Delivery S.r.l. rejects all forms of forced, compulsory, or bonded labor, debt bondage, modern slavery, and human trafficking, as well as any work performed under psychological and/or physical coercion. Workers shall not be forced to surrender personal identification documents, money deposits, or financial guarantees. Likewise, all workers are free to terminate their employment contracts in accordance with applicable legislation without fear of retaliation or punishment. This commitment requires even greater focus on vulnerable categories, such as migrant and refugee workers.

- Prohibition of Discrimination and Promotion of Diversity, Equity, and Inclusion (DE&I). Gender Equality Policies.
E.D. Express Delivery S.r.l. is committed to fostering an organizational culture centered on valuing diversity, enabling all individuals to express their identity in an inclusive work environment free from discrimination based on age, gender, skin color, sexual orientation, marital status, religious beliefs, language, ethnic or national origin, health status, physical or mental abilities, pregnancy, maternity/paternity (including adoption), personal beliefs, political opinions, trade union membership/activity, or any other form of diversity. As part of its commitment to advancing diversity, the organization pays special attention to gender equality and women's rights, adhering to these principles across all roles, professional categories, and business processes. Any form of intimidation, threat, harassment, or physical, psychological, or verbal abuse that creates a hostile work environment—including sexual harassment and violence—is strictly prohibited. Unfair or humiliating behavior, abuse of power, or offensive language regarding race, ethnicity, sex, or religion will not be tolerated. Promoting DE&I is a cross-cutting principle that extends beyond the corporate boundary.

- Respect for Minorities
E.D. Express Delivery S.r.l. recognizes and respects the rights of minorities, with particular regard to their cultures, customs, lifestyles, institutions, and development models.

- Freedom of Association and Collective Bargaining
.D. Express Delivery S.r.l. respects the right of workers to form or join trade unions of their choice. It is committed to protecting worker representatives and facilitating open dialogue with them and the broader workforce. Furthermore, it recognizes the right to collective bargaining for fair compensation and suitable working conditions, safeguarding the effective exercise of trade union rights in the workplace.

- Occupational Health and Safety
E.D. Express Delivery S.r.l. promotes a robust safety culture across its premises and supply chain, offering secure environments, workstations, and processes for all workers. In compliance with safety regulations, it aims to prevent accidents and occupational diseases by implementing safety management systems focused on risk assessment, prevention, mitigation, and safety awareness. To this end, it provides employees at all levels with training, clear guidelines, and necessary support. Emergency response plans are maintained for residual risks. Additionally, the company addresses holistic health by monitoring and preventing work-related stress while offering well-being initiatives. Suppliers are expected to replicate these health and safety management practices within their own operations.

- Promotion of Fair Remuneration
E.D. Express Delivery S.r.l. designs and updates its compensation system based on objective criteria—such as external market benchmarks, internal equity, role responsibilities, and individual skills—ensuring impartiality, equal opportunities, and meritocracy without discrimination. Entry-level wages for all genders meet or exceed statutory or collective bargaining minimums, covering overtime pay and benefits, aimed at guaranteeing a decent standard of living for workers and their families. Compensation accounts for living costs and basic needs (food, water, housing, education, healthcare, transport). Timely payment of wages as contractually agreed is strictly guaranteed.

- Work-Life Balance
E.D. Express Delivery S.r.l. ensures working conditions that respect personal well-being, recognizing the right to rest, leisure, and a balance between professional responsibilities and personal life. The company complies with applicable laws and collective agreements regarding working hours and paid leave. Regular work hours shall not exceed 48 hours per week, with at least 24 consecutive hours of rest every seven days alongside paid annual leave. Overtime must not exceed 12 hours per week and must remain exceptional, consensual, and compensated at premium rates. If work hours consistently exceed 60 hours per week, a corrective plan will be deployed. Healthy lifestyle choices are promoted via parental leave, wellness training, and stress mitigation programs.

- Anti-Corruption
E.D. Express Delivery S.r.l. insists on an ethical work environment, condemning all forms of active or passive corruption, unlawful favors, collusive behavior, or improper material/immaterial benefits intended to influence decisions. The organization refuses business dealings with any entity engaged in corrupt practices.

- Responsible Communication & Advertising
Trust and transparency underpin our commercial relationships. Marketing and communication efforts across all online and offline channels are conducted responsibly. E.D. Express Delivery S.r.l. provides clear, accessible, and transparent information to allow consumers to make informed choices. Images and messaging are selected to respect human dignity, avoid discrimination, and refrain from promoting violence or hazardous behaviors.

- Privacy and Data Protection
E.D. Express Delivery S.r.l. respects the privacy rights of all stakeholders (employees, contractors, customers, suppliers) and complies with applicable legal frameworks regarding the lawful, transparent, and secure processing of personal data.

- Environmental Protection
Across its operations and supply chain, E.D. Express Delivery S.r.l. is dedicated to reducing greenhouse gas emissions, protecting biodiversity, managing water resources and waste responsibly, advancing circular economy practices, and prioritizing low-impact materials. The transition to sustainable energy and business models is conducted in a fair, inclusive manner that supports affected communities.

4. APPLICATION OF THE POLICY

To ensure effective implementation of these human rights principles, the organization employs a comprehensive framework consisting of: policy adoption, risk and impact identification, prevention/mitigation, corrective action, monitoring, transparent reporting, and training.

- Risk Assessment
Proactive risk identification is fundamental. Risk analysis covers internal operations, facilities, existing and prospective business relationships, suppliers, and affected stakeholders (including women, children, and local communities). Risk assessments are updated periodically to capture emerging risks and trigger prompt mitigation.

- Prevention and Mitigation of Adverse Impacts
Control processes are embedded across operations and supply chains—where human rights risks are often heightened. Ethical, social, and environmental evaluations are conducted during supplier selection (via pre-qualification audits and detailed questionnaires). Post-contract engagement includes awareness initiatives, best-practice sharing, and performance monitoring to promote sustainable business practices.

- Remediation of Human Rights Violations
If human rights breaches occur, the company commits to implementing suitable remedies for affected workers, customers, or communities. It co-operates with relevant authorities, institutions, and partners to resolve incidents appropriately. Internally, reports received via internal controls or whistleblowing channels trigger dedicated investigations (supported by external experts where necessary). Depending on severity, disciplinary or contractual actions—up to agreement termination—will be taken.

- Training and Awareness
Recognizing that policy adherence relies on clear understanding, regular training and awareness programs are conducted for employees and suppliers. Periodic updates on risk management outcomes are shared to drive continuous improvement and inform strategic refinements.

- Roles and Responsibilities
The Board of Directors holds primary responsibility for approving, adopting, and overseeing the execution of this Policy. Any individual aware of an actual or suspected violation of applicable laws or this Policy must report it promptly. This includes non-compliance by employees, consultants, suppliers, or third parties acting on behalf of the organization.

5. POLICY UPDATES

This Policy is reviewed and updated periodically—at least once a year—based on risk assessment findings, industry best practices, and stakeholder dialogue.

The Human Rights Policy was approved by the Board of Directors on 20/05/2024.