ILEP S.A. is committed to demonstrating zero tolerance regarding violations of labor and human rights, as well as to upholding human dignity, promoting ethical practices, and safeguarding the rights of all employees and stakeholders.

The Policy has been developed taking into account the interests of ILEP’s key stakeholders.

The Policy applies to all employees (staff, executives, and management) and is implemented across all operations and business activities.

This Policy is developed to address material adverse impacts related to labor and human rights, such as potential violations of human rights and labor legislation.

The Policy also incorporates related risks, such as legal disputes and reputational damage to ILEP S.A. ILEP S.A. is committed to adhering to the fundamental principles of human rights as set out in the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, as well as the UN Declaration on the Rights of Indigenous Peoples and ILO Convention No. 169 on Indigenous and Tribal Peoples. These commitments extend throughout the value chain, ensuring that all employees, suppliers, and partners comply with these standards. This Policy establishes a strict stance against workplace discrimination based on gender identity. ILEP S.A. will comply with the provisions of this Labor and Human Rights Policy, as well as with national laws and regulations. ILEP S.A. must assess the implementation of the Labor and Human Rights Policy during the planning and design of new business activities. In the event of discrepancies between the content of this Policy and national laws or other applicable standards, the stricter requirements shall prevail.

To achieve the above, ILEP S.A. must adhere to the following commitments:

Non-discrimination and inclusion

  • ILEP S.A. ensures that there is no discrimination based on gender, race, color, ethnic group, nationality, religion, beliefs, age, marital status, disability, sex, sexual orientation, gender identity, political views, participation in trade unions, or social and educational background. Recruitment, evaluation, compensation, and promotion processes must be fair, transparent, and free from bias, supporting diversity and inclusion at all levels of the workforce. This Policy emphasizes the protection of women’s rights, as well as the rights of groups at particular risk of vulnerability, and a commitment to non-discriminatory practices in every aspect of the business. Qualifications, skills, and experience serve as the basis for recruitment, appointments, training programs, and promotions at all levels, while also taking into account that some individuals may face greater challenges than others in acquiring these qualifications, skills, and experience. ILEP S.A. has programs that promote access to skills development.

 

Equality and equal opportunities

  • ILEP S.A. ensures equal treatment in all employment-related decisions, from hiring to promotion. Corporate processes emphasize evaluating employees based on performance, skills, qualifications, experience, and conduct. Any discriminatory practices are prohibited and will be reported transparently.

 

Freedom of association and collective bargaining

  • ILEP S.A. supports the right to freedom of association and the effective recognition of the right to collective bargaining. ILEP S.A. will maintain an open and constructive dialogue with its employees and will respect their rights to association, organization, and collective bargaining in accordance with applicable laws and regulations, for their mutual benefit.
  • These commitments are regularly monitored, and any violations are addressed through corrective actions. The company adheres to ILO conventions and standards governing trade union rights.

 

Forced labor

  • ILEP S.A. strictly prohibits all forms of forced or compulsory labor. All work performed must be voluntary, and practices such as forced labor, debt bondage, or involuntary labor are not tolerated within ILEP S.A. or its supply chains. The company is committed to implementing due diligence processes to identify and mitigate risks related to forced labor and to transparently report any violations.

 

Child labor

  • ILEP S.A. ensures compliance with ILO requirements regarding the minimum age of employees, set at 18 years, except in cases of legally regulated vocational training. ILEP S.A. is committed to preventing child exploitation and ensuring that no child labor exists within the company or along its supply chain. Compliance with these standards will be ensured through regular audits and assessments.

 

Harassment and workplace conduct

  • ILEP S.A. is committed to maintaining a workplace characterized by respect and free from harassment, prohibiting all forms of harassment, bullying, human trafficking, or violence. This includes sexual harassment and any behavior based on protected characteristics. The company will actively investigate and address all reported incidents of harassment, ensuring corrective measures are taken and results are reported transparently.

 

Working conditions

  • ILEP S.A. is committed to providing fair wages and benefits that meet or exceed legal requirements, and to ensuring that employment contracts clearly describe all agreed terms and conditions in a transparent manner. Working hours will comply with national laws and relevant industry standards, while overtime will be voluntary and fairly compensated.

 

Health and safety in the workplace

  • ILEP S.A. ensures health and safety in the work environment. Continuous improvement of health and safety performance is a key objective, and health and safety issues are integrated into all operational processes. Regular health and safety audits are conducted, along with transparent incident reporting. The company is committed to ensuring that private security services respect human rights in all its operations. Through its relevant “Health and Safety at Work” Policy, ILEP S.A. is committed to achieving the ultimate goal of “Zero accidents, zero occupational diseases.”

 

Incident reporting mechanism (whistleblowing mechanism)

  • ILEP S.A. encourages employees to report concerns regarding violations related to the implementation of this Policy and the Code of Business Conduct, including harassment, bullying, or discrimination against employees, serious risks that may threaten the health and safety of employees, as well as the general public or customers. ILEP S.A. will accurately assess reported incidents and, where necessary, take corrective actions to remedy all valid reported cases. ILEP S.A. will publish any confirmed human rights violations transparently.

 

Risk assessments and due diligence

  • ILEP S.A. is committed to implementing risk assessments and due diligence regarding human rights across all its activities and supply chains, in order to identify, prevent, and mitigate potential risks. These assessments will guide the development and implementation of programs to address exposure to human rights issues in specific sectors. The company will also communicate this Policy to all staff and external stakeholders to ensure full understanding and compliance.

 

Monitoring and remediation

  • ILEP S.A. is committed to monitoring human rights impacts on an annual basis, including potential impacts within each sector. In the event of adverse impacts, the company will ensure appropriate corrective measures are taken to remedy them. A robust review mechanism has been established to ensure that the Policy is regularly evaluated and updated as needed.

 

Stakeholder engagement

  • ILEP S.A. is committed to engaging stakeholders in the development and implementation of the Labor and Human Rights Policy. This includes the participation of employees, suppliers, customers, business partners, local communities, and other stakeholders, ensuring that human rights concerns are effectively addressed.

Training and awareness on labor and human rights

  • ILEP S.A. will ensure that employees receive adequate training and guidance on good human rights practices, tailored to their roles and areas of influence.

 

Governance and accountability

ILEP S.A. will establish governance mechanisms to monitor, assess, and manage impacts and risks arising from violations of labor and human rights.

Responsibility for implementing this Policy lies with the senior management of ILEP S.A. These executives will ensure that labor and human rights policy aspects are fully integrated into the company’s strategy and operations, with regular oversight by the Board of Directors and the establishment of clear internal governance structures, including performance monitoring.

Communication and distribution

It is the responsibility of ILEP S.A. management to communicate the content and spirit of this document to all staff, both direct and affiliated, and to stakeholders. This Policy is published and posted on the company’s website. To enhance awareness, ILEP S.A. will ensure that employees receive adequate training and guidance on labor and human rights practices, tailored to their roles and areas of influence.

The Policy will be reviewed annually to ensure compliance with applicable laws and regulations, legal requirements, and any other relevant updates.