Kolmar Holdings

Human Rights Policy

1. Chapter 1 General Provisions
   Article 1 (Purpose)

   The purpose of this policy is to establish and implement measures to protect and promote the human rights of Kolmar Group's employees and stakeholders, and to outline other necessary provisions.

   Article 2 (Definitions)

   The terms used in this policy are defined as follows:

   • 1. "Human Rights" refers to the dignity, worth, freedom, and rights of individuals as guaranteed by the Constitution and laws of the Republic of Korea, as well as by international human rights treaties and customary international law to which Korea is a signatory.
   • 2. "Employees" refers to the executives and staff members of Kolmar Group, including both regular and non-regular employees, regardless of the form of their employment contracts.
   • 3. "Human Rights Management" refers to the prevention of human rights violations by Kolmar Group and the implementation of business practices that respect human rights. This includes Kolmar Group's declaration of its human rights policy, implementation of Human Rights Due Diligence, and provision of remedies for victims of human rights violations.
   • 4. "Partner Companies" refers to companies engaged in business relationships with Kolmar Group in connection with its business activities, including domestic and international subsidiaries, invested companies, supply chain partners, and clients.
   • 5. "Stakeholders" refers to individuals or entities related to Kolmar Group's business activities, including customers, partner companies, local residents, and all other corporations or individuals associated with Kolmar Group.
   • 6. "Complainants" refers to individuals or entities who have suffered human rights violations or are aware of human rights risks, including employees, other individuals, or organizations, who report such violations through the human rights violation reporting channel.

   Article 3 (Scope of Application)

   • ① This policy applies to the employees of Kolmar Group's domestic and international entities.
   • ② Kolmar Group shall adhere to the human rights policy in its transactions with partner companies and encourage all stakeholders involved in business relationships to comply with this human rights policy.
   • ③ In cases where the matters addressed in this policy conflict with the laws of the local country, the local laws shall take precedence. This policy may be revised to reflect the legal requirements and industry characteristics of the respective country, and separate detailed policies may be established if necessary.
   • ④ Unless otherwise specified by the laws of the respective country, the articles of association, or internal regulations of the organization, all employees of Kolmar Group shall perform their duties in accordance with this policy.
2. Chapter 2 Operation of the Human Rights Policy
   Article 4 (Prohibition of Discrimination)

   Kolmar Group prohibits discrimination against any employee on the basis of gender, race, religion, disability, age, place of birth, political opinion, or social status in all aspects of work, unless objectively justified. The Group is committed to fostering an organizational culture that respects and embraces the diversity of its employees.

   Article 5 (Compliance with Working Conditions)

   • ① Kolmar Group complies with the statutory working hours of the countries in which it operates, provides fair compensation to all employees for their work, and issues pay statements alongside their wages.
   • ② Kolmar Group provides employees with ample educational opportunities and a suitable work environment for job performance, aiming to enhance their professional development and improve their quality of life.

   Article 6 (Humane Treatment)

   Kolmar Group respects the privacy of all employees, strictly protects their personal information, and prohibits any form of coercion, abuse, or inhumane treatment, whether physical or psychological.

   Article 7 (Guarantee of Freedom of Association and Collective Bargaining)

   Kolmar Group complies with the labor relations laws of the countries where this policy applies and provides all employees with ample opportunities for communication regarding working conditions.

   Article 8 (Prohibition of Forced Labor and Child Labor)

   • ① Kolmar Group strictly prohibits all forms of forced labor and ensures that no business benefits are derived from forced labor, either directly or indirectly.
   • ② Kolmar Group strictly prohibits child labor and takes measures to ensure educational opportunities and safety for young individuals.

   Article 9 (Guarantee of Occupational Safety)

   • ① Kolmar Group provides employees with a safe and hygienic working environment. In cases where employees are required to work in hazardous conditions, the Group ensures the provision of appropriate protective equipment and safety training.
   • ② Kolmar Group promptly provides appropriate compensation and other measures for accidents or illnesses occurring in the workplace.

   Article 10 (Responsible Supply Chain Management)

   Kolmar Group treats its partner companies fairly to ensure responsible supply chain management and encourages all partner companies to practice human rights management.

   Article 11 (Protection of Human Rights for Local Residents)

   All employees of Kolmar Group shall ensure that the human rights of local residents are not violated during the performance of their duties. In particular, the Group guarantees the protection of local residents' rights to safety, health, and freedom of residence.

   Article 12 (Guarantee of Environmental Rights)

   • ① Kolmar Group complies with domestic and international environmental regulations and strives to protect the environment and prevent pollution.
   • ② Kolmar Group encourages all partner companies to pursue environmentally friendly business practices.

   Article 13 (Protection of Customer Human Rights)

   All employees of Kolmar Group prioritize the protection of customers' lives, health, and property as the highest value when providing products and services. The Group also takes all necessary measures to safeguard personal information collected through business activities.
3. Chapter 3 Framework of the Human Rights Policy
   Article 14 (Declaration of the Human Rights Policy)

   Kolmar Group declares its human rights policy to ensure the dignity and value of humanity in all business activities. Employees shall adopt this policy as a code of conduct and a standard for value judgment in practicing human rights management.

   Article 15 (Human Rights Management Education)

   Kolmar Group conducts internal human rights management education to enhance employees' understanding of human rights, improve awareness, and communicate the direction and goals of human rights management initiatives. Through this education, the Group aims to prevent discriminatory practices among employees and encourage the active reporting of identified cases of human rights violations and associated risks.

   Article 16 (Human Rights Impact Assessment)

   • ① Kolmar Group conducts human rights impact assessments to identify and prevent actual and potential human rights risks that may arise from its business activities.
   • ② Human rights impact assessments are conducted annually as a general principle. However, the frequency may be adjusted as necessary.
   • ③ Kolmar Group discloses the results of human rights impact assessments, along with information on risk mitigation and improvement measures, through accessible formats such as the Sustainability Report for employees and stakeholders.
4. Chapter 4 Remedies for Human Rights
   Article 17 (Reporting and Receiving Human Rights Violations)

   • ① Kolmar Group operates channels for receiving reports of human rights violations. Complainants are not limited to victims of human rights violations but may include employees, other individuals, or entities who are aware of human rights risks.
   • ② Upon receiving reports of human rights violations, the relevant departments and authorities shall discuss specific remedies, taking into account the unique characteristics of each individual case.

   Article 18 (Handling Reports of Human Rights Violations)

   • ① When handling reports of human rights violations, Kolmar Group shall refer to laws, regulations, judicial precedents, guidelines from relevant authorities, internal company practices, and industry standards. The Group shall seek the best possible remedies with the support of the legal department.
   • ② In cases where human rights violations significantly restrict the victim's freedom and rights or pose a potential risk to the company's reputation, remedies may be discussed in committees, management meetings, or working-level meetings involving top decision-makers.

   Article 19 (Protection of Whistleblower Identity)

   • ① All employees of Kolmar Group must not disclose, leak, publicize, or report the personal information of whistleblowers or any details that could infer their identity.
   • ② In all procedures related to the reporting, receipt, handling, and notification of results regarding human rights violations, all information that could infer the identity of the whistleblower—such as the victim, details of the violation, date of the report, and progress outcomes—must be kept confidential and protected.
   • ③ Kolmar Group ensures that whistleblowers are protected from any disadvantages or retaliation resulting from their reports and guarantees the necessary measures to safeguard them.

   Article 20 (Human Rights Violation Reporting Channel)

   Kolmar Group's reporting channel for human rights violations is as follows:

   • [Human Rights Violation Reporting Channel]
   • ■ Department: Kolmar Group HR & General Affairs Team
   • ■ Email: humanright@kolmar.co.kr
5. Chapter 5 Amendments
   Article 21 (Necessity of Amendments)

   Kolmar Group shall amend this policy as necessary to reflect changes in relevant laws, regulations, or company circumstances when the need for revision is recognized.

   Article 22 (Amendment Procedure)

   If partial amendments to this policy are deemed necessary due to changes in relevant laws, regulations, or company circumstances, the amendments may be made through reporting to and approval by the CEO. However, in the case of comprehensive amendments, the changes must be reported to and approved by the Board of Directors
6. Addendum
   Article 1 (Effective Date)

   • ① This policy shall take effect on November 1, 2021.
   • ② This policy shall take effect on May 2, 2024.

   Article 2 (Relationship with Other Regulations)

   When enacting or amending other regulations related to the human rights of employees and stakeholders, or establishing related systems and policies, they must align with this policy.