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Effective Date: January 1, 2026

Commitment Against Harassment

Every individual has the right to work in an environment free from intimidation, hostility, and offensive behavior.

Saporina maintains a zero-tolerance policy towards harassment in all its forms — regardless of who is involved.

1. Institutional Declaration

At Saporina, we believe that every individual has the right to work in an environment free from intimidation, hostility, and offensive behavior. Our commitment to excellence includes a zero-tolerance policy towards harassment in all its forms.

This declaration formalizes our pledge to prevent, detect, and sanction any conduct that violates the dignity of our employees, collaborators, or partners.

Equality Agent: Saporina designates an Equality Agent — an independent, trained professional appointed by the Compliance and Audit Committee — who is responsible for receiving harassment complaints, providing initial guidance to victims, and ensuring investigations are conducted impartially. The Equality Agent operates independently of all business units.

2. Scope of Commitment

This commitment extends beyond the physical walls of our offices. It applies to:

Workplace Interactions

Between colleagues, managers, and subordinates.

Professional Relations

Interactions with suppliers, customers, and manufacturing partners.

Digital Spaces

Communications via email, messaging apps, or social media related to work.

3. Definition of Unacceptable Conduct

Saporina explicitly prohibits the following behaviors:

Sexual Harassment

Any verbal, non-verbal, or physical conduct of a sexual nature that is unwanted and creates an intimidating, hostile, or offensive environment. This includes unwanted advances, requests for sexual favors, or sexist remarks.

Harassment Based on Sex/Gender

Behavior related to a person's gender or gender identity that violates their dignity or creates an offensive environment, even if not explicitly sexual in nature.

Moral Harassment (Mobbing)

Persistent and systematic abusive behavior (words, acts, gestures) that degrades the working conditions or psychological integrity of an individual.

Harassment Based on Protected Characteristics

Any unwanted conduct related to a person's race, ethnicity, national origin, religion or belief, disability, age, or sexual orientation that has the purpose or effect of violating their dignity or creating an intimidating, hostile, degrading, or offensive environment.

4. Our Protocol in Action

Saporina has implemented a specific Protocol for the Prevention and Management of Harassment. Through this protocol, we commit to:

A

Prevention (Proactive)

  • We do not wait for a complaint to act. We conduct regular sensitivity training to identify "micro-aggressions" and unconscious biases before they escalate.
  • We promote a culture where "speaking up" is viewed as a loyalty to the company's values, not as disruption.
B

Protection (Safe Reporting)

We have established a Confidential Reporting Channel managed by the designated Equality Agent (see Section 1). If you experience or witness harassment, you can report via:

For full details on the reporting procedure, timelines, and guarantees, see the Whistleblowing Policy. Reports are acknowledged within 7 days and investigations are concluded within 3 months.

Guarantee of Non-Retaliation

Saporina guarantees that no employee will suffer adverse consequences for reporting a suspicion of harassment in good faith. Retaliation against a whistleblower is itself a serious disciplinary offense.

C

Resolution (Decisive Action)

  • All complaints will be investigated promptly, impartially, and with absolute confidentiality.
  • If harassment is proven, Saporina will apply disciplinary measures proportional to the offense, up to and including termination of employment or cancellation of commercial contracts with offending partners.

5. A Shared Responsibility

Preventing harassment is not just the job of HR; it is the duty of every person at Saporina. We expect our leaders to set the example and our partners to respect our standards.

If you witness or experience conduct that violates this commitment, please do not stay silent. Use our Responsible Channel or contact the Equality Agent directly. Your voice matters.

6. Contact

For questions about this commitment, or to speak with someone directly:

Equality Agent

For confidential guidance, questions, or to report harassment directly.
equality@saporina.com

Ethics & Compliance Channel

Anonymous and confidential. Available 24/7.
ethics@saporina.com  |  +1 (000) 000-0000