Human Rights Policy
1 INTRODUCTION
2 OBJECTIVE
2.1 Scope
2.1 Revisions Made
3 DEFINITIONS, TERMINOLOGY AND ACRONYMS
4 HUMAN RIGHTS AGENDA GOVERNANCE
5 COMMITMENTS TO THE PROTECTION AND RESPECT OF HUMAN RIGHTS
6 SALIENT HUMAN RIGHTS RISKS
6.1 Labor Rights and Freedom of Association
6.2 Diversity, Equity, and Inclusion
6.3 Rights of Children and Adolescents
6.4 Rights of Indigenous Peoples, Traditional Communities, and Inclusion of Small Producers
6.5 Environmental Protection and Sustainable Use of Natural Resources
6.6 Local Development
6.7 Product and Food Safety
6.8 Anti-Corruption
7 HUMAN RIGHTS DUE DILIGENCE (HRDD)
8 GRIEVANCE MECHANISM
9 PROCESSES FOR THE INVESTIGATION AND REMEDIATION OF ADVERSE HUMAN RIGHTS IMPACTS
10 ZERO TOLERANCE FOR VIOLENCE AGAINST HUMAN RIGHTS DEFENDERS
11 STAKEHOLDER COMMUNICATION AND ENGAGEMENT
12 SECTORAL INITIATIVES
13 RESPONSIBILITIES, EXCEPTIONS, AND GENERAL PROVISIONS
14 REFERENCES
1. INTRODUCTION
AMAGGI believes that the pursuit of sustainable development is one of society’s greatest challenges and one of the most important factors for business longevity. Therefore, sustainability must permeate the entire management process, operations, and value chain.
Accordingly, through this Policy, the company commits to respecting and protecting human rights throughout its operations, value chain, and local communities, including employees, small producers, family farmers, Indigenous peoples, and traditional communities, as well as other stakeholders who may be impacted by AMAGGI’s activities in all locations where it operates.
2. OBJECTIVE
This Policy aims to establish general guidelines and principles to ensure that AMAGGI’s activities respect human rights throughout its entire production chain and in all regions where it operates.
AMAGGI’s Policy is aligned with the International Bill of Human Rights; the United Nations Guiding Principles on Business and Human Rights (UNGPs); the ILO Declaration on Fundamental Principles and Rights at Work; the United Nations Declaration on the Rights of Indigenous Peoples; and the principles of the United Nations Global Compact, of which AMAGGI is a signatory.
2.1 Scope
This Policy applies to all AMAGGI units in all regions where the company operates. Where differences exist between national laws and international human rights standards, AMAGGI will follow the higher standard. In cases of conflict between norms, the company will comply with national laws while always seeking to respect international human rights to the greatest extent possible.
2.2 Revisions Made
• The following topics were added: “Human Rights Agenda Governance,” “Processes for the Investigation and Remediation of Adverse Human Rights Impacts,” and “Zero Tolerance for Violence Against Human Rights Defenders.”
• Review of the texts related to Food Security; Environmental Protection and Sustainable Use of Natural Resources; Rights of Indigenous Peoples, Traditional Communities, and Inclusion of Small Producers; and Labor Rights and Freedom of Association.
• The term Food Security was added to the glossary.
3. DEFINITIONS, TERMINOLOGY AND ACRONYMS
Value chain: the range of activities carried out by the organization and by upstream (pre-production) and downstream (post-production) entities to bring the organization’s products and services from conception to final use. Note 1: The value chain includes the supply chain.
• Local community: individuals or groups of individuals living or working in areas impacted or potentially impacted by the organization’s activities.
• Traditional Communities: culturally distinct groups that recognize themselves as such, have their own forms of social organization, occupy and use territories and natural resources as a condition for their cultural, social, religious, ancestral, and economic reproduction, using knowledge, innovations, and practices generated and transmitted by tradition, such as quilombola and riverine communities.
• Human Rights Due Diligence: a process through which companies can identify, prevent, mitigate, and account for how they address their actual and potential adverse human rights impacts as an integral part of business decision-making and risk management systems.
• Integrity Due Diligence (IDD): a systematic procedure for researching public databases, information, documents, and processes in order to understand the organization or individual with whom the company intends to engage or interact. It is the systematic analysis of a company’s documents and information, enabling the assessment of actual and potential risks.
• Human Rights: rights inherent to all human beings, including, at a minimum, those set forth in the United Nations International Bill of Human Rights and the principles concerning fundamental rights established in the ILO Declaration on Fundamental Principles and Rights at Work.
• Adverse impact: an effect that an organization causes or may cause on the economy, the environment, and people, including impacts on their human rights, which may indicate its contribution to sustainable development.
• Indigenous peoples: original peoples in independent countries whose social, cultural, and economic conditions distinguish them from other sectors of the national community and whose status is regulated wholly or partially by their own customs and traditions or by special laws and regulations.
• Food Security: a condition in which all people, at all times, have physical, social, and economic access to sufficient, safe, and nutritious food, encompassing availability, access, utilization, and stability.
• Stakeholders: individuals or groups that have interests or are impacted by the organization’s activities.
4. HUMAN RIGHTS AGENDA GOVERNANCE
To ensure the effectiveness of the Human Rights Policy, AMAGGI has structured a governance model that integrates different areas of the company and promotes a coordinated and continuous approach.
The Human Rights Working Group (HRWG) is an interdisciplinary body responsible for defining strategies, coordinating the implementation of the Policy, monitoring results, reporting progress, and promoting continuous improvement of processes related to the topic. Executive responsibility is assigned to the Socioenvironmental Supervision, which coordinates both the Socioenvironmental Management System and the HRWG. Each area represented in the group must ensure the execution of the actions set forth in the plans and the achievement of established targets, ensuring integration with their respective operations.
5. COMMITMENTS TO THE PROTECTION AND RESPECT OF HUMAN RIGHTS
AMAGGI commits to acting in accordance with internationally recognized human rights, observing the obligations assumed by the countries where it operates, as well as applicable national laws and regulations. This commitment includes:
• Respecting human rights, meaning avoiding infringing on the human rights of others and addressing adverse human rights impacts with which we are involved.
• In the context of our own activities, avoiding causing or contributing to adverse human rights impacts and addressing such impacts when they occur.
• Seeking ways to prevent or mitigate adverse human rights impacts that are directly linked to our operations, products, or services through a business relationship, even if we have not contributed to those impacts.
• Conducting human rights due diligence appropriate to the size, nature, operational context, and severity of potential adverse human rights impacts.
• Providing or cooperating, through legitimate processes, in the remediation of adverse human rights impacts when we identify that we caused or contributed to such impacts.
• Within our own activities, ensuring that the human rights of all individuals are respected, without distinction of any kind, such as race, color, gender, or sexual orientation.
6. SALIENT HUMAN RIGHTS RISKS
Aligned with the United Nations Guiding Principles on Business and Human Rights, AMAGGI identifies below the human rights topics that present the greatest risk of negative impacts arising from the company’s activities or its business relationships:
6.1 Labor Rights and Freedom of Association
In compliance with fundamental national and international labor standards in our operations, AMAGGI commits to:
• Providing a healthy and safe working environment
• Ensuring decent working conditions and fair wages for employees and third parties;
• Respecting ILO conventions and Brazilian labor legislation regarding working hours
• Adopting practices to prevent, investigate, and combat any form of discrimination, harassment, or violence in the workplace, whether related to ethnicity/race, gender, sexual orientation, disability, or any other grounds
• Ensuring that all employees have the right to freedom of association and collective bargaining
• Not engaging in business with any individual or legal entity included on Brazil’s “Dirty List” of Slave Labor
• Not tolerating child labor, forced labor, or labor under degrading conditions.
6.2 Diversity, Equity, and Inclusion
AMAGGI is committed to valuing and promoting diversity, as well as ensuring equal employment opportunities for all, not tolerating any form of discrimination or harassment. AMAGGI’s efforts on this topic are formalized in a specific policy: DE-0093 – INCLUSION AND DIVERSITY POLICY.
6.3 Rights of Children and Adolescents
The company’s commitment in this area focuses on respecting the rights of children and adolescents, as well as making every necessary effort to prevent child labor, violence, or sexual exploitation of children and adolescents throughout its operations and value chain.
6.4 fights of Indigenous Peoples, Traditional Communities, and Inclusion of Small Producers
AMAGGI is committed to respecting and protecting the rights of traditional communities and Indigenous peoples, as well as supporting the inclusion of small producers and family farmers in the local economy. AMAGGI’s commitments in relation to these groups are referenced in the public document “Towards a Deforestation- and Conversion-Free Grain Supply Chain”, and include:
• Not trading grains sourced from productive areas overlapping demarcated or regularized Indigenous lands
• Ensuring that Indigenous peoples and local communities have their land-use rights safeguarded, as well as Free, Prior, and Informed Consent (FPIC), with listening processes carried out through company-led consultations or through the investigation of grievances related to the topic
• Respecting customary rights to land, resources, and territory, and refraining from or interrupting the acquisition, purchase, or development of land that does not comply with legal requirement
• Prioritizing local development through active listening and culturally appropriate measures
• Supporting and promoting the inclusion of small farmers in the development of more sustainable production, considering economic and productivity, social, and environmental aspects through technical assistance, knowledge dissemination, best practices, and socio-economic development actions.
6.5 Environmental Protection and Sustainable Use of Natural Resources
AMAGGI commits to continuously maintaining its DE-0090 – SOCIOENVIRONMENTAL POLICY and Management System appropriate to the size and complexity of its operations and proportional to the level of potential environmental and social risks and impacts, aiming to prevent damage that could affect the environment and the quality of life of employees and local communities. The commitment to environmental preservation and restoration is also encouraged and promoted among suppliers in the value chain. AMAGGI’s commitments in this area include:
• Complying with applicable legal requirements and other requirements subscribed to by the organization related to its socioenvironmental aspects
• Continuously improving processes, seeking pollution prevention and the prevention of social impacts, managing greenhouse gas emissions, and improving socioenvironmental performance across its operations and value chain
• Adopting good socioenvironmental practices to minimize accidents, negative impacts, and generate shared value
• Promoting engagement with business partners and key stakeholders on socioenvironmental responsibility
• Promoting respect for Human Rights and decent work throughout its operations and legal value chain.
6.6 Local Development
AMAGGI understands that it is an integral part of the regions where it operates, exerting significant influence on the social and economic context through its activities, operations, and relationships with stakeholders.
In addition to its international presence, AMAGGI operates in several regions of Brazil, each with distinct social, cultural, and economic characteristics. In all of them, the company acts with social responsibility, preventing and monitoring potential negative impacts, with particular emphasis on respecting and protecting human rights.
The company’s commitment is to the sustainable development of the regions where it operates. For this reason, it periodically conducts active listening with local communities, in accordance with environmental licensing obligations, periodic materiality processes, or community engagement programs (AMAGGI in Community), in order to understand and address demands related to new operations or potential impacts associated with AMAGGI’s activities, its subsidiaries, and/or suppliers.
AMAGGI’s contribution to local and regional development is also guided by its DE-0057 – PRIVATE SOCIAL INVESTMENT POLICY, with actions planned and executed by the André and Lucia Maggi Foundation. The company’s Private Social Investment portfolio is defined annually and seeks to bring together programs and projects capable of contributing to the UN Sustainable Development Goals and AMAGGI’s ESG 2030 Targets, generating positive impacts in local communities. All resources are allocated through the annual budget, in accordance with planning carried out by the executive team of the André and Lucia Maggi Foundation and approved by the members of the Foundation’s Board of Trustees.
6.7 Product and Food Safety
The company commits to maintaining practices and controls that ensure compliance with international food safety standards, guaranteeing product traceability, quality, and integrity. In addition, it seeks to contribute to global food security by promoting the availability and accessibility of safe and nutritious food, supporting resilient supply chains and reducing post-harvest losses.
6.8 Anti-Corruption
As part of its efforts, AMAGGI reinforces its culture of ethics, transparency, and compliance with laws, rules, and good compliance practices that guide its business activities, based on the highest standards of compliance, transparency, and adherence to best practices in corporate governance.
AMAGGI does not tolerate any practice of corruption, bribery, fraud, or the payment or receipt of improper advantages, directly or indirectly, whether involving public administration (domestic or foreign) or private companies.
The company prohibits and does not tolerate facilitation payments intended to accelerate or favor business, obtain advantages, licenses, authorizations, or permits by its employees, suppliers, customers, business partners, or any other third party acting on its behalf, interest, or benefit.
AMAGGI endeavors to act in accordance with the principles contained in the OECD Council Recommendation on Corporate Governance Principles and ensures compliance with the commitments assumed in PG-0015 – ANTI-BRIBERY AND ANTI-CORRUPTION POLICY.
7 HUMAN RIGHTS DUE DILIGENCE
7.1 Human Rights Impact and Risk Assessment
AMAGGI conducts a formal Human Rights Due Diligence process aligned with the OECD Guidance on Business and Human Rights, considering risks by topic, affected stakeholders, and geography. The review of human rights impact assessments takes place every three years or whenever there is a significant change in the external context or in the scope of the company’s operations and strategy.
7.2 Integration, Action, and Monitoring
AMAGGI recognizes that human rights due diligence is a continuous process and must consider the context and scale of its own operations and those of its value chain, focusing especially on the most critical processes. Accordingly, the company commits to integrating due diligence outcomes into its management system, policies, and processes, adopting a preventive approach to avoid or mitigate any human rights impacts.
For human rights impacts and risks considered priorities, based on severity and likelihood assessments, action plans are established by type of impact related to the company’s activities (cause, contribution, or direct linkage), including deadlines and responsible parties.
Monitoring of actions is carried out through appropriate qualitative and quantitative indicators (KPIs), as well as internal and/or external audits to assess and complement due diligence.
The results of the indicators are published in the ESG Report in a specific Human Rights section, with independent external verification.
7.3 Awareness and Training
All AMAGGI employees are trained on this Human Rights Policy upon its publication and whenever it is revised.
Through AMAGGI University, the company also provides all employees with mandatory training on Human Rights, covering the main concepts of this Policy and how each employee contributes to its implementation and maintenance.
The Human Rights Policy is made available to AMAGGI stakeholders on the company’s website, and information on its implementation and maintenance is disclosed annually through the company’s ESG Report.
7.4 Suppliers
The ethical conduct that guides AMAGGI’s activities extends throughout its supply chain. Accordingly, all suppliers registered in the management system are required to comply with the provisions set forth in the Ethical Conduct Agreement for Suppliers, as well as those contained in this Corporate Human Rights Policy.
AMAGGI promotes respect for human rights throughout the value chain, including the adoption of contractual clauses and requirements for documentation evidencing legal compliance.
For suppliers considered socially and/or environmentally critical, AMAGGI follows PO-0395 – SOCIOENVIRONMENTAL ASSESSMENT OF CRITICAL SUPPLIERS, and for grain and fiber procurement, AMAGGI follows IT-0533 – SOCIOENVIRONMENTAL ASSESSMENT OF GRAIN AND FIBER SUPPLIERS, applying the following criteria:
The company does not trade grains sourced from productive areas subject to:
• IBAMA embargoes or embargoes issued by state environmental authorities
• Demarcated/regularized Indigenous lands and strict protection conservation units
• Areas deforested after January 1, 2025, in accordance with the company’s commitment Towards a Deforestation- and Conversion-Free Grain Supply Chain
• Brazil’s Slave Labor Dirty
AMAGGI fosters productive and, above all, ethical relationships. Accordingly, it conducts compliance due diligence prior to entering into effective relationships or contracts with business partners, in accordance with eligible categories.
The DE-0146 – INTEGRITY ASSESSMENT POLICY FOR BUSINESS PARTNERS forms part of AMAGGI’s Compliance Program and seeks to assess integrity risks to which the company may be exposed in its relationships with business partners, in accordance with Decree No. 11,129/22 and aligned with international best practices.
All company contracts with suppliers and service providers include a standard contractual clause requiring respect for Human Rights and compliance with the ILO Declaration on Fundamental Principles and Rights at Work.
In cases of potential non-compliance with human rights, AMAGGI may notify partners, conduct on-site visits, provide training, require action plans, or engage partners to ensure immediate corrective measures. If a violation is confirmed, the company will enforce the applicable contractual provisions.
8. GRIEVANCE MECHANISM
AMAGGI provides all stakeholders with a specific channel for receiving, registering, handling, and responding to reports (such as complaints, grievances, and denunciations), aiming to promptly address and remedy adverse impacts that its activities may cause.
AMAGGI’S confidential channel can be accessed via the link available on the AMAGGI intranet, through the website https://www.canalconfidencial.com.br/amaggi/or via a toll-free call to 0800 647 0004, available 24 hours a day, seven days a week. Reports are received and analyzed by an independent third-party company specializing in confidential reporting channels and then forwarded for internal handling by AMAGGI in accordance with the reporting management flow.
In cases of sexual harassment, discrimination, or any act of violence against women, AMAGGI provides an exclusive reporting channel through https://canalconfidencial.com.br/canalmulheramaggi/, also accessible via the AMAGGI confidential channel website or by calling 0800 647 0004. Reports of this nature are handled exclusively by women. All service staff are trained and qualified to provide appropriate support for such reports.
Additionally, AMAGGI commits to widely disclosing public and specific channels for reporting human rights violations to key stakeholders, such as disque 100 and/or 180.
The AMAGGI confidential channel meets the effectiveness criteria established by the United Nations guiding principles on business and human rights, being legitimate, accessible, predictable, equitable, transparent, rights-compatible, a source of continuous learning, and based on engagement and dialogue.
9. PROCESSES FOR THE INVESTIGATION AND REMEDIATION OF ADVERSE HUMAN RIGHTS
AMAGGI maintains processes for the identification, response, remediation, and reparation of adverse human rights impacts caused by, contributed to, or directly linked to AMAGGI’s operations or supply chain, in accordance with the operational procedure GUIDELINES FOR THE REMEDIATION OF ADVERSE HUMAN RIGHTS IMPACTS.
Accordingly, the company ensures alignment with the United Nations Guiding Principles on Business and Human Rights (UNGPs) and its responsibility to respect human rights, seeking to prevent and remedy any adverse human rights impacts.
10. ZERO TOLERANCE FOR VIOLENCE AGAINST HUMAN RIGHTS
AMAGGI does not tolerate any form of violence, threat, intimidation, or retaliation against environmental and human rights defenders, whether in its own operations or throughout its value chain. The company is committed to preventing, monitoring, responding to, and remedying reports related to retaliation against defenders, ensuring priority handling through the grievance mechanism. Measures are adopted to ensure prompt investigation, adequate protection, and cooperation with competent authorities and independent organizations.
11. STAKEHOLDER COMMUNICATION AND ENGAGEMENT
AMAGGI recognizes the importance of maintaining effective relationships with stakeholders, especially those potentially affected. Therefore, it maintains PO 0383 – STAKEHOLDER IDENTIFICATION AND ENGAGEMENT, which guides the process of identifying key stakeholders and the engagement plan to address their expectations.
AMAGGI will regularly report progress related to its Human Rights commitments, aligned with the UN Guiding Principles Reporting Framework, in its annual ESG Report.
12. SECTORAL INITIATIVES
To strengthen and accelerate this agenda, AMAGGI participates in several multi-stakeholder initiatives, including:
• UN Global Compact: AMAGGI has been a participant since 2009, engaging in the implementation and dissemination of the Ten Principles and the Sustainable Development Goals across its operations and value chain.
• National Pact for the Eradication of Slave Labor – INPACTO: AMAGGI has been a signatory since 2005, supporting the eradication of all forms of labor analogous to slavery in Brazil.
• Business Pact for Integrity and Against Corruption – Instituto Ethos: Initiative promoting an ethical and transparent business environment; AMAGGI has been a participant since 2009.
• Child-Friendly Company Program – ABRINQ Foundation: AMAGGI and the André and Lucia Maggi Foundation have participated since 2009, recognizing their commitment to protecting children and adolescents.
• Na Mão Certa Program – Business Pact Against the Sexual Exploitation of Children and Adolescents on Brazilian Highways: Supported by AMAGGI since 2014.
• Green Grain Protocol – Federal Prosecution Service, Government of Pará, Ministry of the Environment (MMA): Initiative to prevent the commercialization of products from illegally deforested areas, areas under environmental embargo, or associated with slave labor in Pará; AMAGGI has been a signatory since 2018.
13. RESPONSIBILITIES, EXCEPTIONS, AND GENERAL
All employees are individually responsible for ensuring compliance with this document, in conjunction with the Code of Ethics and Conduct and applicable laws and regulations.
Immediate supervisors must ensure that their subordinates receive the necessary guidance to meet the requirements of this document.
This document and its updates, whenever necessary, are the responsibility of the Socioenvironmental area, and any exceptions to its provisions must be submitted to Socioenvironmental Management.
14. REFERENCE
• DE-0090 – SOCIOENVIRONMENTAL POLICY
• DE-0093 – INCLUSION AND DIVERSITY POLICY
• DE-0057 – PRIVATE SOCIAL INVESTMENT POLICY
• DE-0146 – INTEGRITY ASSESSMENT POLICY FOR BUSINESS PARTNERS
• PG-0015 – ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
• PO 0383 – STAKEHOLDER IDENTIFICATION AND ENGAGEMENT
• PO-0395 – SOCIOENVIRONMENTAL ASSESSMENT OF CRITICAL SUPPLIERS
