Ethical Channel

Declaration of Principles

1. Fundamentals

As a responsible family-owned company, our aim is to promote and protect human and environmental rights and to prevent, minimize and, wherever possible, avoid any infringements of these rights. This is the only way for the Mederer Group to be successful as a company in the long term.

The following Statement of Principles on the human rights and environmental strategy of the Mederer Group applies to all activities of the parent company Mederer GmbH as well as its subsidiaries globally.

1.1 Commitment to international standards

The Mederer Group is committed to complying with the following recognized international human rights and environmental standards:

• The United Nations (UN) Universal Declaration of Human Rights.
• The United Nations Guiding Principles on Business and Human Rights (UNGPs) of 2011.
• The Five Fundamental Rights Principles of the International Labour Organization (ILO)
• The United Nations Global Compact Principles (UNGC)
• The United Nations Convention on the Rights of the Child (UNCRC)
• The United Nations International Conventions on the Elimination of all forms of Discrimination against Women (CEDAW)
• The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
• The United Nations Women’s Empowerment Principles
• The United Nations International Covenant on Civil and Political Rights of 1966
• The United Nations International Covenant on Economic, Social and Cultural Rights of 1966.

It is our aim and duty to ensure the best possible compliance with internationally recognized standards.

1.2 Zero tolerance for discrimination, harassment and abuse

Tolerance, openness and respect are practiced in the Mederer Group. Discrimination on the grounds of nationality, citizenship, pregnancy, maternity or paternity, marital status, sexual orientation, skin color, gender, disability, veteran status, religion or belief, age, racist motives, social/ethnic origin or political opinions, as well as on other grounds protected by law, will not be tolerated.

The Mederer Group maintains a zero tolerance policy towards sexual exploitation and abuse, harassment, abuse of power, fraud and corruption in the context of all its business activities and responsibilities.

Violations of this Statement of Principles will not be tolerated and will be assessed on a case-by-case basis. As a result of the assessment, appropriate measures will be taken, which may range from raising awareness to imposing consequences in accordance with labor legislation.

1.4 Equality, diversity and non-discrimination

TROLLI IBERICA SAU respects and guarantees equal treatment and opportunities in the workplace between men and women, as well as non-discrimination based on race, nationality, gender, religion, sexual orientation, gender identity and/or expression, family responsibilities, marital status or any other condition that may give rise to actions constituting discrimination.

It expresses its policy of zero tolerance to discriminatory behavior, harassment or sexual or gender-based harassment or any of the conditions mentioned in the previous paragraph in its company with respect to its employees or people who are not part of the company but are directly related to it (customers, suppliers and job applicants).

1.5 Ethical channel of complaints

Trolli Ibérica, S.A. is firmly committed to offering the best service to its customers, the best treatment to its suppliers and the best working environment for its employees. In short, that our behavior serves to build a better society for everyone.

Trolli Ibérica, S.A., offers you this place where you can report any criminal or administrative infringement, irregular conduct, breaches of our code of ethics or internal rules, illegal acts (any crime such as fraud, theft, corruption, embezzlement, etc.), and any other event that directly or indirectly affects our company in a negative way.

Our Channel guarantees confidentiality, both of the information communicated, the personal data of the person reporting, as well as those of the reported or affected persons, complying with Law 2/2023, of February 20, on Whistleblower Protection, Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, as well as Organic Law 3/2018, of December 5.

Compliance with all of the above and the management of the receipt of complaints sent from our Internal Whistleblower Channel is outsourced to the independent consulting firm, Business Adapter®.

Before reporting, remember that you must have reasonable grounds to believe, according to the information and circumstances available to you at the time of the report, that the facts reported are true. Our entity will analyze the plausibility of your complaint and may reject it if it does not comply with the provisions of Law 2/2023 of February 20.

Before reporting, remember that you must have reasonable grounds to believe, based on the information and circumstances available to you at the time of the report, that the facts reported are true. Our entity will analyze the plausibility of your complaint and may reject it if it does not comply with the provisions of Law 2/2023 of February 20.

Human rights and environmental strategy

2.1 Overall responsibility

The general management of the Mederer Group, together with the management of the corporate areas at the various locations and the Corporate Social Responsibility (CSR) department, is responsible for ensuring compliance with this Statement of Principles. This integrated approach ensures that each area of the company is fully aware of its responsibility to respect human rights and that these standards are effectively applied in its daily work.

2.2 Social responsibility

As an international company with extensive supply chains, we are aware that our activities carry the risk that human rights and environmental standards may be compromised or even violated at some point in the supply chain. We therefore aim to identify potential risks in advance, minimize them, prevent violations or respond to them appropriately.

2.3 Focus on customer needs

The satisfaction of our customers is our top priority. The needs and wishes of our customers and the market guide our strategic decisions and our daily actions. To ensure the job stability of our employees, we strive to maintain long-term and economically viable business relationships with our business partners.

2.4 Standards of coexistence

We expect our employees to act in accordance with the law and to behave in a respectful and tolerant manner towards all people. Every employee is part of our corporate family and contributes to the external image of the company at all times. All information, guidelines and behaviors specified in this Statement of Principles and in our Code of Conduct (CoC) are binding for all employees of the Mederer Group, regardless of their level in the company. Employees are requested to comply with these guidelines and to contact their line manager or the management at any time if they have questions or suggestions.

2.5 Cooperation with business partners

The Mederer Group cooperates with qualified suppliers, distributors and service providers (“business partners”), whom it selects carefully on the basis of objective criteria. It demands the same level of compliance from its business partners as it does from itself. The principles and values set out in the Mederer Group Code of Conduct (CoC) as well as in this Declaration of Principles form the basis of our cooperation with our business partners.

2.6 Environmental responsibility

Trolli Ibérica, S.A.U., successfully operates an energy management system to actively meet the company’s goal of a livable environment. In the short term, we will be working on the establishment of an environmental management system certified in accordance with the ISO 14001 standard, which we hope to implement shortly.

At the moment we have obtained a contract where all our energy will be 100% renewable.

2.7 Product packaging recyclability

The packaging materials used must comply with specific properties to ensure food safety and maintain excellent quality throughout the period guaranteed by the minimum expiration date. This enables us to preserve the high quality of our products throughout the entire supply chain. As a result, most of our primary packaging is made from recyclable plastics, which contributes to sustainability. In addition, our cartons are 100% recyclable and contain at least 30% recycled material.

To further improve the recyclability of our products, we are continuously working on possible improvement options and more environmentally friendly alternatives.