HUMAN RIGHTS POLICY

Table of contents

Version 1.0 · Effective 2 November 2026

Our commitment

ECOFACTOR is committed to respecting internationally recognised human rights in everything we do. We accept our responsibility to avoid causing or contributing to adverse human rights impacts through our own activities, and to seek to prevent or mitigate impacts linked to our products and business relationships.

In this policy, “ECOFACTOR”, “we” and “us” mean the companies operating under the ECOFACTOR brand: ECOFACTOR Sp. z o.o. (Poland), ECOFACTOR TECH UK LIMITED (United Kingdom) and ТОВ «ЗАРЯДНІ МЕРЕЖІ» (Ukraine).

Frameworks we follow

This policy is based on:

  • the UN Guiding Principles on Business and Human Rights;
  • the Universal Declaration of Human Rights;
  • the ILO Declaration on Fundamental Principles and Rights at Work and the ILO fundamental conventions, covering freedom of association and collective bargaining, the elimination of forced labour, the abolition of child labour, the elimination of discrimination in employment and occupation, and a safe and healthy working environment;
  • the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.

We comply with the laws of each country where we operate. Where national law and international standards differ, we follow the higher standard to the extent permitted by law.

Where our risks lie

We supply EV charging equipment developed and produced within the ECOFACTOR group, including in Ukraine. We operate charging networks and software platforms and work with installers and other delivery partners. Based on this, we consider the following human rights issues the most relevant to our business:

  • Labour conditions — fair wages, reasonable working hours and lawful contracts in our own operations and among our installers and suppliers.
  • Forced labour and human trafficking — particularly in lower tiers of electronics, metals and battery-material supply chains, where our visibility is limited.
  • Child labour — particularly in the extraction of minerals used in electronic components.
  • Health and safety — electrical work, manufacturing and installation on public sites.
  • Non-discrimination — in recruitment, employment and access to our services.
  • Privacy — personal data processed through our charge point management system, mobile app and charging network.
  • Conflict-affected context — our people and operations in Ukraine (see below).

How we put this policy into practice

  • Policy commitments — this policy, our Code of Conduct, our Anti-Bribery and Corruption Statement and our Supplier Code of Conduct set clear standards for our people and partners.
  • Due diligence — we assess human rights risks when we select and review suppliers and partners, with closer attention to higher-risk countries, activities and materials. We seek to include human rights obligations in our supplier contracts and refer suppliers to our Supplier Code of Conduct.
  • Our own workplace — we provide lawful employment terms, pay at least the applicable legal minimum, respect working-time rules, provide safe workplaces and do not tolerate discrimination or harassment.
  • Freedom of association — we respect the right of workers to form and join trade unions or other representative bodies, and to bargain collectively, as provided by law.
  • No forced or child labour — we do not use forced, bonded, trafficked or prison labour, do not retain workers’ identity documents and do not charge recruitment fees to workers. We do not employ anyone below the legal minimum working age, and young workers are not given hazardous work.
  • Privacy by design — we build data protection into our software and services and process personal data in line with applicable law.
  • Awareness — managers make sure that people whose roles require it, such as procurement, HR and site management, know the human rights risks relevant to their work.

Operations in Ukraine

Part of our team and operations is in Ukraine, a country affected by the ongoing full-scale armed aggression of the Russian Federation. This creates heightened risks for the safety, wellbeing and rights of our people and those of our partners. In line with UN guidance on heightened human rights due diligence in conflict-affected contexts, we:

  • treat the physical safety and wellbeing of our people as the first consideration in all operational decisions;
  • take civil-defence alerts and safety instructions of the authorities into account in how and where work is carried out;
  • respect the rights of employees affected by mobilisation, displacement or other consequences of the war, in line with Ukrainian law;
  • pay closer attention to the labour practices and integrity of suppliers and partners operating in Ukraine;
  • regularly review how the conflict affects our operations, supply chain and the people connected to them.

Expectations of suppliers and partners

We expect our suppliers, contractors and business partners to respect human rights, comply with labour law, prohibit forced and child labour, provide safe working conditions, and cooperate with our due diligence, including by providing information and allowing audits where required. These expectations are set out in our Supplier Code of Conduct. Serious or persistent failure to meet them may lead to suspension or termination of the relationship.

Grievances and remedy

Anyone — employees, contractors, workers in our supply chain, customers, local communities or other third parties — can raise a concern about a possible human rights impact connected to ECOFACTOR through our speak-up channel at info@ecofactor.eu, including anonymously. See our Report a Concern page (https://ecofactortech.com/legal/report-a-concern/). We will look into every concern, protect the person reporting from retaliation and, where we have caused or contributed to an adverse impact, take steps to provide or cooperate in remedy.

Responsibility and review

The management of each issuing company is responsible for implementing this policy within its company. We review this policy at least once a year and whenever our operations, supply chain or the legal framework change materially, including as new due diligence legislation applies to us.

Document control

Version 1.0 · Effective 2 November 2026 · Owner: Legal (in-house) · Approved by: adopted by ECOFACTOR Sp. z o.o. (Management Board), ECOFACTOR TECH UK LIMITED (directors) and ТОВ «ЗАРЯДНІ МЕРЕЖІ» (Director)