Amaggi Human Rights Policy

Introduction
2. Objective
3. Definitions, Terminology and Acronyms
4. AMAGGI Commitments
5. Salient Risks to Human Rights
6. Human Rights Due Diligence (HRDD)
7. Grievance and redress mechanisms
8. Communication and Stakeholder Engagement
9. Sector Initiatives
10. Responsibilities, Exceptionalities and General Provisions
11. References

1. INTRODUCTION

AMAGGI believes that the search for sustainable development is one of society’s biggest challenges and
one of the most important points for business continuity. Therefore, sustainability must permeate the
entire management process, operations, and value chain.

Therefore, the company commits in this policy to respect and protect human rights in its operations,
value chain, and local communities, including employees, small producers, family farmers, indigenous
peoples, traditional communities, and other interested parties that may be impacted by AMAGGI’s
activities in all locations where it is present.

2. OBJECTIVE

This Policy aims to establish guidelines and general principles so that AMAGGI’s operations occur with
respect for human rights throughout its production chain and in all regions where it operates.

AMAGGI’s Policy is aligned with the International Declaration of Human Rights, the Guiding Principles
on Business and Human Rights of the United Nations (UN), the Declaration on Fundamental Principles
and Rights at Work of the International Labor Organization (ILO), the UN Declaration of the Rights of
Indigenous Peoples, and the principles of the United Nations Global Compact, of which AMAGGI is a
signatory.

2.1 Scope
This policy applies to all AMAGGI units in all regions in which the company operates. Where national
laws differ from international human rights standards, AMAGGI will follow the highest standard. If
standards conflict, the company will comply with national laws; however, it will always seek ways to
respect international human rights to the greatest extent possible.

3. DEFINITIONS, TERMINOLOGY AND ACRONYMS

Value Chain: range of activities carried out by the organization and by entities upstream
(pre-production) and downstream (post-production) of the organization to bring the organization’s
products and services from conception to their final use. Note 1: The value chain includes the supply
chain.

Local Community: individuals or groups living or working in areas impacted or that could be impacted
by the organization’s activities.

Traditional Communities: culturally differentiated groups that recognize themselves as such, have their
forms of social organization, occupy, and use territories and natural resources as a condition for their
cultural, social, religious, ancestral, and economic reproduction, using knowledge, innovations and
practices generated and transmitted by tradition, e.g., quilombola and riverine communities.

Human Rights Due Diligence: process through which companies can identify, prevent, mitigate, and
take responsibility for addressing their actual and potential adverse impacts as an integral part of
business decision-making and risk management systems.

Integrity Due Diligence (IDD): Methodical research procedure in public databases of data, information,
documents, and processes to understand the organization or individual with which the company
intends to relate or interact. It systematically analyses a company’s records and information, which
allows for measuring actual and potential risks.

Human Rights: inherent rights of all human beings, which include, at a minimum, the rights set out in
the United Nations International Bill of Human Rights and the principles relating to fundamental rights
set out in the International Labor Organization (ILO) Declaration on Principles and Rights Fundamentals
at Work.

Adverse Impact: effect that an organization causes or could cause on the economy, the environment,
and people, including impacts on their human rights, which, in turn, may indicate its contribution
(positive or negative) to sustainable development.

Indigenous people: original peoples in independent countries whose social, cultural, and economic
conditions distinguish them from other sectors of the national community and whose situation is
regulated in whole or in part by their customs and traditions or by special laws and regulations.

Stakeholders: individuals or groups who have interests in or are impacted by the organization’s
activities.

4. COMMITMENTS TO THE PROTECTION AND RESPECT OF HUMAN RIGHTS

Within the framework of internationally recognized human rights, the international human rights
obligations of the countries in which we operate, as well as relevant national laws and regulations,
AMAGGI is committed to:
▪ Respecting human rights means avoiding violating the human rights of others and facing adverse
impacts on the human rights with which we are involved.
▪ In the context of our activities, avoid causing or contributing to adverse human rights impacts and
address those impacts when they occur.
▪ Seek ways to prevent or mitigate adverse impacts on human rights directly linked to our operations,
products, or services through a business relationship, even if we have not contributed to these
impacts.
▪ Conduct human rights due diligence as appropriate to the size, nature and context of our operations
and the severity of the risks of adverse human rights impacts.
▪ Provide or cooperate, through legitimate processes, in the remediation of adverse human rights
impacts when we identify that we caused or contributed to those impacts.
▪ Within the scope of our activities, we ensure that the human rights of all people are respected,
without distinction of any kind, such as race, color, gender, and sexual orientation.

5. SALIENT RISKS TO HUMAN RIGHTS

In line with the UN Guiding Principles for Business and Human Rights, AMAGGI identifies below the
topics related to human rights that present the most significant risk of suffering negative impacts
because of the company’s activities or its commercial relationships, referred to as salient risks:

5.1 Labor rights and free trade union association

Respecting fundamental national and international labor standards in our operations are AMAGGI
commitments:
▪ Provide a healthy and safe work environment;
▪ Ensure decent working conditions for employees and third parties;
▪ Adopt practices to prevent, investigate and combat any types of discrimination, harassment, or
violence in the workplace, whether related to ethnicity/race, gender, sexual orientation, disability,
or any other nature;
▪ Ensure that all employees have the right to free union association;
▪ Do not trade with any person, natural or legal, who is on the Blacklist of Slave Labor in Brazil.

5.2 Diversity and Inclusion

AMAGGI is committed to valuing and promoting diversity and equal employment opportunities for
all and not tolerating discrimination or harassment. AMAGGI’s efforts in relation to this topic are
formalized in a specific policy, DE-0093 INCLUSION AND DIVERSITY POLICY.

5.3 Rights of Children and Adolescents

The company’s commitment to this issue focuses on respecting the rights of children and
adolescents, as well as making all necessary efforts to prevent the occurrence of child labor,
violence or sexual exploitation against children and adolescents in our operations and value chain.

5.4 Rights of indigenous peoples, traditional communities, and inclusion of small producers

AMAGGI is committed to respecting and protecting the rights of traditional communities and
indigenous peoples and supporting the inclusion of small producers and family farmers in the local
economy. AMAGGI’s commitments concerning these audiences are referenced in the public
document “Towards a Deforestation and Native Vegetation Conversion Free Chain”, and they are:

● Not to sell grains from productive areas that fall on indigenous lands;
● Ensure that indigenous peoples and local communities have their rights to land use assured, as
well as free, prior, and informed consent (FPIC), with listening processes being able to be carried
out through proactive consultations carried out by the company or through investigation
handling complaints related to the topic;
● Support and promote the inclusion of small farmers in developing more sustainable production,
considering economic and productivity, social and environmental aspects through technical
assistance, dissemination of knowledge and good practices, and socioeconomic development
actions.

5.5 Environmental protection and sustainable use of natural resources

AMAGGI is committed to constantly maintaining its DE-0090 SOCIO-ENVIRONMENTAL POLICY and
Management System appropriate to the size and complexity of its operations and proportional to the
degree of potential environmental and social risks and impacts, aiming to prevent damage that may
impact the environment and the quality of life of employees and the local community. AMAGGI
encourages and stimulates the commitment to preserving and recovering the environment with
suppliers in its chain.

We will continually improve our environmental performance by:

▪ prevent, minimize, and remedy pollution and negative impacts and reduce greenhouse gas
emissions;
▪ ensure the sustainable use of natural resources and increase the efficiency of resource and
energy use;
▪ reduce food loss and waste, promote recycling, and ensure the correct disposal of waste;
▪ avoid the use of extremely and highly toxic substances, remediating or mitigating their effects
when use is necessary, as determined by national legislation;
▪ promote good agricultural practices, including to maintain or improve soil fertility and prevent
soil erosion;
▪ support and preserve biodiversity, genetic resources, and ecosystem services;
▪ take measures to support the long-term protection of forests and natural ecosystems,
encourage restoration and compensation in priority areas and promote sustainability in grain
production, especially through the promotion of regenerative agriculture;
▪ ensure the maintenance of responsible expansion of own agricultural production in areas
already open, as well as investing in transforming degraded areas into increasingly productive
properties, avoiding the need to carry out new conversions of native vegetation to enter
agriculture.

5.6 Local Development

AMAGGI understands that it is an integral part of the different regions in which it is present, exerting a
significant influence on the social and economic context through its activities, operations, and
relationships with interested parties.

In addition to its international presence, AMAGGI is present in several regions of Brazil, each with its
own social, cultural, and economic characteristics. In all of them, the company acts with social
responsibility, preventing and monitoring possible negative impacts, especially aiming for respect and
the protection of human rights.

The company is committed to the sustainable development of the regions in which it is present, and
therefore, it periodically actively listens to local communities, per environmental licensing obligations or
the company’s periodic materiality process, to understand and address the demands faced by new
operations or possible impacts related to the activities of AMAGGI, its subsidiaries, and/or suppliers.

AMAGGI’s contribution to local and regional development is also directed by its DE-0057 PRIVATE
SOCIAL INVESTMENT POLICY, with actions planned and executed by the André and Lucia Maggi
Foundation. The company’s Private Social Investment portfolio is defined annually. It seeks to bring
together programs and projects capable of contributing to the UN Sustainable Development Goals and
AMAGGI’s ESG 2030 Goals, generating positive impacts on local communities. All resources are
provided for in the annual budget, according to planning carried out by the André and Lucia Maggi
Foundation’s executive team and approved by the Foundation’s Board of Trustees members.

5.7 Food Safety

The company is committed to making the necessary efforts to ensure that our operations contribute to
food safety and is constantly seeking improvements in the availability, accessibility, stability, and use of
safe food.

5.8 Combating Corruption

It is part of AMAGGI’s efforts to reinforce its culture of ethics, transparency, and compliance with laws,
rules, and good compliance practices that guide the conduct of its business. AMAGGI is guided by the
highest standards of compliance, transparency, and adherence to best corporate governance practices.
AMAGGI does not tolerate corruption, bribery, fraud, or paying or receiving bribes, directly or indirectly,
whether with the Public Administration, national or foreign, or private companies.

The company prohibits and does not tolerate the offering or payment of facilitations to accelerate or
favor business, obtain an advantage, or obtain licenses, authorizations, or permissions by its employees,
suppliers, customers, business partners, or any other third party acting in its name, interest, or benefit.
AMAGGI strives to act per the principles contained in the OECD Council Recommendation on the
Principles of Corporate Governance and ensures compliance with the commitments assumed in PG –
0015 ANTI-BRIBERY AND ANTI-CORRUPTION POLICY.

6. DUE DILIGENCE IN HUMAN RIGHTS

6.1 Assessment of Impacts and Risks to Human Rights

AMAGGI will carry out a formalized process of reviewing the assessment of impacts on Human Rights
every 3 years, and it is possible to bring this period forward when there is a significant change in the
company’s scope of action or strategy.

6.2 Integration, Action, and Monitoring

AMAGGI recognizes that human rights due diligence is an ongoing process and that it must consider
the context and size of its operations and the value chain, focusing especially on the most critical
processes. In this way, the company integrates due diligence results into its management system,
policies, and processes for a preventive approach to avoid or mitigate any impacts on Human Rights.

For impacts and risks to human rights to be considered a priority, based on assessing severity and
probability, action plans will also be established based on the impact of the company’s activities (cause,
contribution, or direct connection).

Actions will be monitored using appropriate qualitative and quantitative indicators, and internal audits
will be carried out to evaluate and complement due diligence.

6.3 Awareness and Training

All AMAGGI employees must be trained in this Human Rights Policy upon its publication and whenever
it is revised.

The Human Rights Policy will be made available to AMAGGI’s stakeholders, and information on its
implementation and maintenance will be disclosed annually through the company’s ESG Report.

6.4 Suppliers

The ethical conduct that guides AMAGGI’s activities extends to its entire production chain, including
agents, suppliers, customers, and business partners. In this way, all suppliers registered in the
management system are subject to comply with the provisions set out in the Term of Ethical Conduct
for Suppliers, in addition to those set out in this Corporate Human Rights Policy.

AMAGGI disseminates respect for human rights throughout the value chain, including the adoption of
contractual clauses and requirements for documentation proving legal compliance.

For suppliers of supplies considered to be socially and/or environmentally critical, AMAGGI follows
what is established in its procedure PO-0395 SOCIO-ENVIRONMENTAL ASSESSMENT OF CRITICAL
SUPPLIERS And, for acquisitions related to grains and fibers, AMAGGI follows what is established in its
IT- 0533 SOCIO-ENVIRONMENTAL ASSESSMENT OF GRAIN AND FIBER SUPPLIERS, which must follow
the following criteria:

● No embargoes from Ibama and state environmental agencies for deforestation;
● Not affect Indigenous Lands and Full Protection Conservation Units;
● Not focus on areas deforested after 2008 in the Amazon biome that do not comply with the
Soy Moratorium;
● Comply with the requirements of the Pará Green Grains Protocol;
● Not have CPF or CNPJ linked to the Slave Labor Dirty List.

AMAGGI ensures productive and, above all, ethical relationships. Therefore, compliance measures with
business partners are carried out before the effective relationship or contracting is established
according to the eligible categories.

The “DDI” Integrity Due Diligence procedure comprises AMAGGI’s Compliance Program and seeks to
assess the integrity risk to which the company may be exposed in the relationship with its business
partners, as provided for by Decree 11,129/22 and aligned with best practices international.

In case of potential disrespect for human rights, AMAGGI may notify, carry out on-site visits, provide
training, demand an action plan, or even engage its partners so that immediate measures can be taken.
The company will execute the applicable contractual provisions if a right infringement is proven

7. COMPLAINTS AND REMEDY MECHANISMS

AMAGGI provides all its interested parties with a specific channel for receiving, recording, dealing with,
and responding to manifestations (such as complaints, grievances, and reports) to quickly respond to
and repair the adverse impacts that activities may cause.

AMAGGI’s Confidential Channel can be accessed via the link available on AMAGGI’s Intranet, on the
web at https://www.canalconfidencial.com.br/amaggi/ or via the toll-free number 0800 647 0004, 24
hours a day, seven days a week, which will be received and analyzed by an outsourced company
specializing in confidential channels and will then be sent to AMAGGI’s internal processing according to
the report handling flow.

In cases of sexual harassment, discrimination, or any act of violence against women, AMAGGI provides
an exclusive channel for complaints through the website
https://canalconfidencial.com.br/canalmulheramaggi/ which can be found on AMAGGI’s Confidential
Channel website or assistance via telephone 0800 647 0004. Assistance for this type of complaint will
be provided exclusively by women. It is worth noting that the entire customer service team is trained
and capable of handling complaints of this nature.

In addition, AMAGGI is also committed to widely disseminating to the main interested parties, the
public and specific channels for complaints related to human rights violations, such as Dial 100 and Call
180.

8. COMMUNICATION AND STAKEHOLDER ENGAGEMENT

AMAGGI understands the importance of maintaining effective relationships with interested parties,
especially those potentially affected, which is why it maintains procedure PO 0383 – IDENTIFICATION
AND ENGAGEMENT OF INTERESTED PARTIES that guides the process of identifying the main audiences
and the engagement plan with the parties interested parties to meet their expectations.

AMAGGI will regularly report its progress related to Human Rights commitments in its annual ESG
report or a specific report aligned with the UN Guiding Principles Reporting Framework.

9. SECTOR INITIATIVES

Aiming to enhance and accelerate this agenda at AMAGGI, the company participates in several
multi-stakeholder initiatives such as:

● National Pact for the Eradication of Slave Labor – INPACTO: Since 2005, AMAGGI has been a
signatory to this commitment, which seeks to eradicate all forms of work analogous to slavery in
the country.

● Soy Moratorium – ABIOVE: Commitment established with the Brazilian Association of
Vegetable Oil Industries (Abiove) and the National Association of Cereal Exporters (Anec) not to
sell soy from areas of the Amazon biome deforested after 2008.

● Global Compact – UN: Since 2009, AMAGGI has participated in this UN initiative. It aims to
engage and sensitize signatory organizations to implement and disseminate the Ten Principles of
the Compact and the Sustainable Development Goals in their operations and value chains.

● Business Pact for Integrity and against Corruption – Instituto Ethos: Initiative that promotes an
honest and ethical business environment. It brings together companies that annually disclose
their results in eradicating bribery and corruption on the Pact’s platform. AMAGGI has been
part of the Pact since 2009.

● Child-Friendly Company Program – Abrinq Foundation: action to mobilize companies around
social action for the benefit of children and adolescents in Brazil. AMAGGI and the André and
Lucia Maggi Foundation have been participants since 2009 in recognition of their commitment
to defending children and adolescents.

● Na Mão Certa Program (On the right path) – Business Pact against the Sexual Exploitation of
Children and Adolescents on Brazilian Highways: Since 2014, the company has supported this
Childhood Brasil program, which mobilizes companies and entities to promote the fight against
sexual exploitation of children and adolescents on the roads Brazilians.

● Green Protocol for Grains – Federal Public Ministry, Government of Pará: Ministry of the
Environment (MMA): initiative that seeks to avoid the commercialization of products from
illegally deforested areas, with an environmental embargo or the occurrence of slave labor in
the state of Pará. It also aims to strengthen the Rural Environmental Registry (CAR) as an
environmental planning tool. AMAGGI has been a signatory since 2018, due to the beginning of
its operations in Pará.

Aiming to enhance and accelerate this agenda at AMAGGI, the company participates in several
multi-stakeholder initiatives such as:

● National Pact for the Eradication of Slave Labor – INPACTO: Since 2005, AMAGGI has been a
signatory to this commitment, which seeks to eradicate all forms of work analogous to slavery in
the country.

● Soy Moratorium – ABIOVE: Commitment established with the Brazilian Association of
Vegetable Oil Industries (Abiove) and the National Association of Cereal Exporters (Anec) not to
sell soy from areas of the Amazon biome deforested after 2008.

● Global Compact – UN: Since 2009, AMAGGI has participated in this UN initiative. It aims to
engage and sensitize signatory organizations to implement and disseminate the Ten Principles of
the Compact and the Sustainable Development Goals in their operations and value chains.

● Business Pact for Integrity and against Corruption – Instituto Ethos: Initiative that promotes an
honest and ethical business environment. It brings together companies that annually disclose
their results in eradicating bribery and corruption on the Pact’s platform. AMAGGI has been
part of the Pact since 2009.

● Child-Friendly Company Program – Abrinq Foundation: action to mobilize companies around
social action for the benefit of children and adolescents in Brazil. AMAGGI and the André and
Lucia Maggi Foundation have been participants since 2009 in recognition of their commitment
to defending children and adolescents.

● Na Mão Certa Program (On the right path) – Business Pact against the Sexual Exploitation of
Children and Adolescents on Brazilian Highways: Since 2014, the company has supported this
Childhood Brasil program, which mobilizes companies and entities to promote the fight against
sexual exploitation of children and adolescents on the roads Brazilians.

● Green Protocol for Grains – Federal Public Ministry, Government of Pará: Ministry of the
Environment (MMA): initiative that seeks to avoid the commercialization of products from
illegally deforested areas, with an environmental embargo or the occurrence of slave labor in
the state of Pará. It also aims to strengthen the Rural Environmental Registry (CAR) as an
environmental planning tool. AMAGGI has been a signatory since 2018, due to the beginning of
its operations in Pará.

10. RESPONSIBILITIES, EXCEPTIONS AND GENERAL PROVISIONS

All employees are individually responsible for ensuring compliance with this document, the Code of
Ethics and Conduct, and the laws and regulations in force.

Immediate superiors must ensure that their subordinates receive the necessary guidance to meet
the requirements of this document.

This document and its updating, whenever necessary, are the responsibility of the
Socio-Environmental area. Any exception to the provisions must be forwarded to
Socio-Environmental Management.

11. REFERENCES

● DE-0090 SOCIAL AND ENVIRONMENTAL POLICY
● DE-0093 INCLUSION AND DIVERSITY POLICY
● DE-0057 PRIVATE SOCIAL INVESTMENT POLICY
● PG – 0015 ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
● PO 0383 – IDENTIFICATION AND ENGAGEMENT OF INTERESTED PARTIES
● PO-0395 SOCIO-ENVIRONMENTAL ASSESSMENT OF CRITICAL SUPPLIERS
● IT-0533 SOCIO-ENVIRONMENTAL ASSESSMENT OF GRAIN AND FIBER SUPPLIERS