LM_Sustainability_Report_2022

People and society Carbon neutrality Circularity Introduction LM Wind Power Sustainability Performance 2022 Wind Power’s ethics & compliance team runs an annual assessment that focuses on evaluating the inherent risks, which take into account a range of risks such as anti-corrup- tion and anti-competition risks, and the strength of our inter- nal controls across all our operations. The assessment bench- marks LM Wind Power’s ethics & compliance programs against the 19 Spirit & Letter policies, which the team includes in an overall assessment as to how LM Wind Power performs in each key policy area. Insights from this process are used in many aspects of the compliance program includ- ing by identifying additional training needs, control improve- ments, and other areas that may need remediation efforts. Training on business ethics is generally delivered in two ways – online and in person. Online training is assigned to the majority of salaried staff, mostly office or home-based. Some categories of employees are excluded from this online training such as warehouse staff who may not have regular access to a computer to carry out the training, some clerical and adminis- trative staff, interns etc. The workers in scope are assigned training on the main policies in our code of conduct The Spirit & the Letter – such as supplier relationships, conflict of inter- ests, anti-money laundering, competition law, and improper payments – on hire, and every two years. In the intervening years they are assigned a shorter acknowledgement. Shop floor workers are not in scope for training on business ethics (although they do receive information on ethics through their supervisors). In 2022, of the employees in scope, approxi- mately 95% have completed their ethics training. Labor and Human Rights Human rights are the heart of LM Wind Power’s culture of integrity. Our commitment is grounded in the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the Ten Principles of the United Nations Global Compact which we signed up to in 2010 when we published our first sustainability report. Driven by those standards, we strive to respect the fundamental digni- ty of everyone we might affect directly through our operations, products and services and indirectly through our business rela- tionships across the globe. Our ideals flow from the Interna- tional Bill of Human Rights, the International Labor Organiza- tion Declaration on Fundamental Principles and Rights at Work and the Sustainable Development Goals. At LM Wind Power, we are committed to working with all our business partners and entities throughout our value chain, including agents, suppliers and vendors, to align their policies and practices with the expectations set in this Statement of Principles. Commitment The cornerstone of our commitment is constant vigilance to identify and address human rights risks across our value chain in good faith and to the best of our ability. We endeavor to develop and continuously improve our procedures to identify, prevent, mitigate and remedy our salient human rights impacts. The following principles are foundational to the way we con- duct our business and to our expectations of business part- ners, suppliers, agents and vendors: Decent work : We provide all workers a safe and healthy work environment. We observe all applicable laws and regulations governing wages and hours, recruitment and employment contracts. Workers receive wages at least in line with mini- mum legal standards and adequate rest time. All overtime is voluntary. Gender equality: At LM Wind Power, we take pride in provid- ing a safe, diverse, and respectful workplace that promotes gender equality. We apply competitive pay practice where on average, men and women performing similar work are paid within 1% of each other across each of our sister companies in GE. Our goal remains 100% pay equity. In addition, we con- tinue to offer benefits that support a gender diverse workforce, including flexible work policies, maternity, and other family benefits, and more. Inclusion of Persons with Disabilities (PwDs): We are proud to include Persons with Disabilities in our workforce, provid- ing them access to opportunities while identifying and plug- ging the gaps that makes integration a challenge for them. With the help of our Disability Advocacy Network we are driv- ing the inclusion of more distinct and skilled talent, engaging in various programs to raise awareness and recognizing the needs of those affected by disabilities in addition to conduct- ing effective trainings for teams to collaborate better. Freedom of association and collective bargaining : We allow workers to choose freely whether to organize or join associa- tions of their own choosing for the purpose of collective bar- gaining as provided by local law or regulation Forced labor : We prohibit reliance on forced, prison or indentured labor, or workers subject to any form of physical, sexual or psychological compulsion, exploitation or coercion. We take all reasonable measures to avoid being complicit in modern slavery and trafficking in persons and to prevent workers being charged recruitment fees and expenses. Child Labor : We prohibit employing workers younger than sixteen (16) years of age or below the applicable minimum age, whichever is higher, and we prohibit employing workers younger than eighteen (18) for any hazardous tasks. Responsible Mineral Sourcing : We are committed to respon- sible sourcing of tantalum, tin, tungsten and gold and other minerals found in conflict-affected and high-risk areas in line with our Responsible Mineral Sourcing Principles. Privacy : We respect the confidential information with which we are trusted. We set clear expectations for all employees and business partners about collecting, sharing, storing, transfer- ring, and disposing of personal data in order to protect privacy. Security : We strive to ensure a safe environment for all work- ers and do not tolerate harassment, violence or intimidation. Our security operations are carried out with respect for the dignity and privacy of LM Wind Power workers and the com- munities in which we operate. Community rights : We respect the dignity of communities affected by our operations, products and services. We imple- ment strict protocols to protect the local environment from pollution and waste, and we strive continuously to optimize consumption of natural resources. Governance At LM Wind Power, we implement the mechanisms listed below to ensure that labor and human rights commitments are upheld effectively within the organization. Human rights risk and impact assessments globally, by country or region, by business or function, or by product line through- out our value chain. Such assessments may be standalone or integrated in existing protocols and processes. Where reasona- ble, we will seek to engage with stakeholders affected by our activities to understand and address their concerns in good faith and in line with our human rights commitment. Integration of impact and risk assessment findings in LM Wind Power operations, and to the extent possible, where relevant in LM Wind Power’s value chain. Integration will include the development and implementation of practi- cal guidance, training, process improvements, discrete pro- grams, and other reasonable measures to address salient human rights risks. 23