FRESHWAYS GROUP HUMAN RIGHTS POLICY

  1. Purpose and Commitment
    The Freshways Goup of Companies (“Freshways”) is committed to respecting and promoting
    human rights across all areas of our operations and business relationships. This policy sets out
    our approach to upholding the dignity and rights of individuals in accordance with the United
    Nations International Bill of Human Rights and also references the United Nations Guiding
    Principles on Business and Human Rights, and other relevant international standards including
    those from the International Labour Organization (“ILO”).
  2. Scope
    This policy applies to all employees, directors, contractors, suppliers, and business partners of
    Freshways with specific attention to UK legal frameworks and obligations.
  3. Core Principles
    3.1 Non-Discrimination and Equal Opportunity
    We are committed to providing a workplace free from discrimination on the grounds of race,
    gender, age, disability, sexual orientation, religion, nationality, or any other status protected under
    international human rights standards and UK law. The basis for recruitment, hiring, placement,
    training, compensation and advancement at Freshways is qualifications, performance, skills and
    experience. Freshways has a separate Equal Opportunities Policy.
    3.2 Freedom of Association and Collective Bargaining
    We respect the rights of employees to join or form trade unions and to bargain collectively, in line
    with ILO Conventions and UK legislation. Where employees are represented by a legally
    recognized union, we are committed to establishing a constructive dialogue with their freely
    chosen representatives.
    3.3 Safe and Healthy Working Conditions
    We ensure that all our employees work in a safe and healthy environment. Health and safety
    practices comply with UK law and international best practices. We are dedicated to maintaining a
    productive workplace by minimising the risk of accidents, injury and exposure to health risks. We
    are committed to engaging with our employees to continually improve health and safety in our
    workplaces, including the identification of hazards and remediation of health and safety issues,
    including medical conditions affecting staff within the workplace.

V2 June 2025
3.4 No Forced or Child Labour
We do not tolerate forced, bonded, or compulsory labour or child labour. We comply fully with the
UK Modern Slavery Act 2015 and conduct due diligence to prevent such practices within our
operations and supply chains.
3.5 Right to Privacy and Data Protection
We respect individual privacy and comply with the UK General Data Protection Regulation and
Data Protection Act 2018.
3.6 Living Wages and Working Hours
We pay at least the national minimum wage (or living wage where applicable) and adhere to fair
working hours and rest periods in line with the Working Time Regulations 1998.

  1. Implementation and Responsibilities
    Senior leadership is responsible for overseeing the implementation of this policy.
    The Human Resources team is tasked with integrating human rights considerations into company
    operations. All employees are expected to understand and uphold these commitments.
  2. Grievance Mechanisms
    We provide accessible and confidential grievance mechanisms for individuals and stakeholders to
    raise concerns related to human rights without fear of reprisal. This also extends to matters falling
    under the issue of harassment (in relation to defined protected characteristics). We commit to
    investigating all concerns promptly and fairly.

Approved by:
Ravinder Nijjar, Director
June 2025