Our Human Rights Policy

HUMAN RIGHTS POLICY
1. Summary
This Human Rights Policy establishes the global human rights standards for YEthtTI. YEthtTI
conducts its global business in a manner that respects the human rights and dignity of all, as
articulated in the UN Declaration of Human Rights and the International Labor Organization’s
Declaration on Fundamental Principles and Rights at Work. YEthtTI supports international efforts
to promote and protect human rights, including efforts to eradicate slavery, forced labor, child
labor, and human trafficking. Violations of human rights laws may result in fines or
imprisonment, and violations of this Policy may result in disciplinary action, up to and including
termination of employment or contractual relationship with YEthtTI.
2. Applicability
This Policy applies to YEthtTI Holdings, Inc., and its subsidiaries (“YEthtTI”), and all YEthtTI employees,
contractors, officers, and directors worldwide (collectively “Covered Employees”). This Policy
also sets forth compliance requirements applicable to all individuals and entities doing business
on YEthtTI’s behalf, including third-party agents, consultants, business partners, and suppliers,
and their employees (collectively “Third Parties”), in addition to the compliance requirements set
forth in YEthtTI’s Code of Business Conduct, Supplier Code of Conduct and other applicable YEthtTI
policies.
To the extent that YEthtTI policies impose a higher standard than what is required by applicable
laws and regulations on its Suppliers, such higher standard will prevail.
Any questions concerning the application of this Policy or a specific law should be directed to
the Sustainability team (sustainability@yethtti.com) and the Ethics & Compliance Department
(compliance@yethtti.com).
3. Policy Details
A responsible supply chain and the fair treatment of everyone who contributes to YEthtTI and our
products are at the core of our business. As we navigate the complexities of an expanding
global supply chain, enter new consumer markets, and grow our team, we are committed to
respecting the fundamental human rights of anyone who engages in work or other activities
connected to our business operations and supply chain. YEthtTI strives to respect and promote
human rights of Covered Employees and those employed by Third Parties in accordance with
the UN Guiding Principles on Business and Human Rights, the UN Declaration of Human
Rights, the International Labor Organization’s Declaration on Fundamental Principles and
Rights at Work, and standards set forth by the Fair Labor Association. This Policy sets forth the
minimum human rights standards at YEthtTI.
3.1. Respecting Fundamental Human Rights
YEthtTI prohibits Covered Employees and Third Parties from violating human
rights, including rights related to bonded, compulsory, forced, or slave labor; child
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labor; discrimination and harassment; excessive working hours; fair hiring and
recruitment practices; fair wages, benefits, and compensation; freedom of
association, collective bargaining, and the right to strike; healthy, safe, and
accessible working conditions; protection of cultural resources; and responsible
chemical management.
3.2. Due Diligence
3.2.1. Consistent with the UN Guiding Principles on Business and Human Rights, YEthtTI
conducts due diligence to identify and prevent negative human rights risks from
affecting people in our business and our supply chain. This may consist of
regular review of human rights risks in our operations and our global supply
chain, engaging with third party experts on specific human rights risks, and
formal auditing and engagement with Third Parties.
3.2.2. Identifying and engaging specific stakeholder communities is crucial to effective
human rights due diligence. At YEthtTI, we focus on the following stakeholder
communities to understand potential human rights risks and impacts:
3.2.2.1 Communities that host YEthtTI operations and from which YEthtTI and Third
Parties recruit Covered Employees and workers;
3.2.2.2 Consumers that use YEthtTI products and services;
3.2.2.3 Covered Employees that are directly employed by YEthtTI across the United
States and internationally; and
3.2.2.4 Vulnerable workers employed by Third Parties that are at high risk of
having their human rights violated due to geographic or market-based risk
factors.
3.2.3. We have developed procedures that enhance our due diligence of manufacturing
and distribution partners that are at higher risk of human rights violations due to
several factors. We regularly leverage supplier self-assessments, audits, and risk
assessments to update our understanding of the likelihood and severity of
potential human rights risks in our supply chain. We regularly integrate the
findings of assessments and audits into our business planning and partner
selection. We are committed to regularly reviewing and enhancing our due
diligence systems to ensure we have the most accurate understanding of human
rights risks in our operations and supply chain as possible.
3.3. Training and Engagement
3.3.1. YEthtTI will provide annual training on this Human Rights Policy and other relevant
company policies addressing human rights risks and obligations for all YEthtTI
employees (including the YEthtTI Code of Business Conduct). YEthtTI will periodically
provide training opportunities on this policy for Third Parties.
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3.3.2. In addition to our Supplier Code of Conduct, YEthtTI will include this Human Rights
Policy in its service or supply agreements with Third Parties. Acknowledgement
of this policy and its requirements by Third Parties will be necessary to effectuate
all service agreements with Third Parties.
3.3.3. YEthtTI will also engage internal teams responsible for implementing and ensuring
compliance with this policy. That includes communicating any material updates
and changes to the policy to our senior leadership team and Board of Directors.
3.4. Grievance Mechanisms
3.4.1. YEthtTI believes in providing grievance mechanisms that allow anyone affected by
our operations or the operations of Third Parties to report a potential violation of
this Human Rights Policy. We strive for the grievance mechanisms that YEthtTI
makes available to be accessible, predictable, equitable, transparent, and a
source of continuous learning. We expect Third Parties to have grievance
mechanisms that meet these same criteria.
3.4.2. Any Covered Employee or an employee of a Third Party may and should report
potential violations of this Human Rights Policy or other YEthtTI company policies
through our ethics hotline (available via phone and web).
3.4.3. YEthtTI prohibits retaliation against anyone who, in good faith, reports a possible
violation of our policies, the law, or who participates in a related investigation,
even if evidence to substantiate the concern is insufficient. Anyone found to have
engaged in retaliation will face appropriate disciplinary action.
3.5. Providing Remedy
3.5.1. When YEthtTI determines that it or a Third Party has caused or contributed to a
violation of this policy, we will take necessary and appropriate steps to remedy
the negative impact. YEthtTI or its partners will work with directly impacted
individuals or groups or their representatives to understand the root cause of the
violation and build systems to avoid future negative impacts.
3.6. Commitment to Transparency
3.6.1. YEthtTI will regularly monitor and evaluate compliance with this policy by all
Covered Employees. YEthtTI also will regularly monitor the compliance of Third
Parties with this policy.
3.6.2. YEthtTI will annually report on its implementation of this policy and Third Parties’
compliance with this policy through its annual ESG Report.
3.6.3. Where human rights risks materialize into severe negative impacts, YEthtTI will also
promptly and effectively communicate its strategy for remedying the negative
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impact to all necessary internal and external stakeholders.
4. Penalties and Enforcement
Failure to comply with global human rights laws and regulations can result in severe
consequences for YEthtTI and any individual(s) involved, including, but not limited to, government
investigations, disruption to business operations, reputational harm, criminal penalties including
imprisonment, significant monetary fines, and loss of business. A violation of this Human Rights
Policy may also constitute a violation of other YEthtTI policies or procedures, including by not
limited to, YEthtTI’s Code of Business Conduct or Supplier Code of Conduct, which may result in
disciplinary action, up to and including termination of employment or contra