Human Rights Policy

This Policy arises from the need to identify and mitigate the risks presented by both Altano´s own workers and the company’s service providers (for distribution, maintenance, supply, etc.), throughout their value chains, in relation to respect for the Human Rights principles and regulations. The purpose of this Policy is to provide an overview of the approach of Altano to manage Human Rights risks across the organisation and in all of the assets that the company manages and develops. Furthermore, the way this will be implemented allows Altano to address its commitment to arising regulations such as European Union Taxonomy and the Corporate Sustainability Reporting Directive.

As a company operating in Spain and Italy, the commitment of Altano to respect Human Rights is inspired by the following international and European declarations and standards:

• United Nations International Bill of Human Rights.
• United Nations Guiding Principles on Business and Human Rights (PRNU).
• The Ten Principles of the United Nations Global Compact.
• OECD Guidelines for Multinational Enterprises.
• UN Women’s Principles.
• Global Standard of Conduct for the Protection of LGBTQ+ People in Businesses.
• Convention on the Rights of the Child.
• Principles and rights established in the key conventions of the International Labor Organization (ILO).
• ILO Declaration on Fundamental Principles and Rights at Work.
• United Nations Guiding Principles on Business and Human Rights (UN, 2011).
• Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises (OECD, 2011).
• Tripartite Declaration of the International Labor Organization on Principles for Sustainable Insurance (PSI).
• United Nations Principles for Responsible Investment (PRI).
• Modern Slavery Act.
• National Action Plans on Business and Human Rights.
• EU Corporate Sustainability Report Directive (CSRD).

Within the framework of the general strategy of Altano, specific commitments and principles of action have been defined with a focus on Human Rights.

This Policy reflects the determination of Altano to be a leader in the renewable energy sector, not only in terms of efficiency and sustainability, but also in terms of integrity and commitment to universal human values. Altano is committed to the following fundamental principles:

• Respect for Human Rights: Altano is committed to respect and protect Human Rights in all its operations and activities, avoiding any involvement in violations of fundamental rights. This should be reflected not only in the performance of Altano’s business, but also in that of its suppliers, those who are part of the company’s value chain and who are necessary for the energy that the company provides.

• Non-Discrimination: the company will not discriminate against employees, customers, local communities or other stakeholders on the basis of race, gender, sexual orientation, religion, nationality or other protected characteristics.

• Labour Rights: the company ensures that its employees enjoy fair working conditions, decent wages and a safe and healthy working environment in accordance with applicable laws and regulations. Renewable energy production workers are exposed to certain occupational risks that need to be assessed and controlled. Therefore, firm contribution to the mitigation of those risks is essential to provide an optimal commitment to labour rights.

• Consultation and Participation: Altano is committed to consulting and collaborating with local communities and other stakeholders in the areas where it operates to address their concerns and needs. In this regard, prior to the start of every journey workers are gathered in order to share their work procedures and recommendations.

• Environmental Sustainability: the company will minimise the environmental impacts of its operations and installations of renewable energy infrastructures, and will contribute to climate change mitigation, respecting biodiversity and promoting sustainable practices.

• Corporate Social Responsibility: Altano is committed to promote sustainable development in local communities, investing in social and economic projects that benefit the surrounding population.

• Due Diligence: due diligence will be conducted to identify and address potential Human Rights risks in its operations and supply chains.

• Transparency and Accountability: the company is committed to being transparent in its operations and accountable for any Human Rights violations, taking appropriate corrective action Regulatory Compliance: Altano will comply with all laws and regulations related to Human Rights in all jurisdictions in which it operates.

• Education and Training: training will be provided to the employees and stakeholders on the importance of Human Rights and how to comply with this Policy commitments.

The top management of Altano does ensure compliance with the Policy through the approval of specific plans.

The Policy will be documented in an online format available for all the interested parties and kept for every planned review. The document will be written in the required versions so our employees can read and understand it.

Altano does conduct an annual assessment of the activities and measures implemented by the companies and assets in which it invests. This assessment consists of an evaluation of the effectiveness of activities to detect, prevent, mitigate, minimise, and eliminate the extent of adverse Human Rights impacts, as well as to communicate the Human Rights philosophy to all their employees and stakeholders. It is the responsibility of Altano management to establish a monitoring procedure and to promote a culture of compliance.

In order to assure that the content of this Policy remains pertinent and appropriate for the organisation, Altano does develop a monitoring plan. The Board of Directors of Altano is responsible for the monitoring, updating and control of this Policy, which shall be reviewed at least annually by the Board of Directors.

The Policy will be adapted or modified in the following cases:

1. When international, European, or national regulations are approved that may include changes with respect to Human Rights.
2. At the proposal of the department responsible for Human Resources.
3. At the proposal of any supervisory body or authority.

This Human Rights Policy has been approved by Altano Energy’s Managing Directors on 16 November 2023 and ratified by the Board of Directors on 29th of November of 2023