Human Rights Diligence at Covestro

Covestro is committed to respecting and safeguarding human rights in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs). This commitment extends throughout the Covestro Group, our subsidiaries, and our global supply and value chains. We comply with applicable local laws and regulations while actively working to prevent human rights violations. We have integrated human rights aspects into the various management systems within our company. Our cross-departmental Human Rights Office drives our due diligence approach in line with both the UNGPs and national legislation, such as the German Supply Chain Act. Our Human Rights Office works under the leadership of the corporate function Group Innovation & Sustainability and has permanent members from the following corporate functions: Group Health, Safety, Environment & Reliability, Group Procurement, Human Resources, Law, Intellectual Property & Compliance.

At Covestro, respecting human rights is a fundamental part of our license to operate. Across our global operations in over 30 countries and throughout our supply chains, we take clear responsibility for preventing and addressing human rights impacts. Our human rights management system integrates due diligence into daily operations through six core elements that guide our approach:

• We outline our human rights principles in various Corporate Commitments, corporate regulations, and in our Supplier Code of Conduct.
• These documents reference key international conventions and principles as the basis of our conduct. We expect the conduct of our employees and business partners worldwide to comply with these basic principles.
• Our zero-tolerance policy covers child labor, forced labor and human trafficking. This commitment is reinforced through our public statements on modern slavery (UK Modern Slavery Act Statement) and forced labor reporting (Canadian Supply Chains Report).
• Further information on our Corporate Commitments and Policies can be found here.

• Our human rights due diligence begins with comprehensive risk analysis that identifies and assesses actual or potential negative impacts on human rights that Covestro could cause as a result of its business activities.
• Our ongoing risk analysis covers all of the production and distribution sites of Covestro, the supply chain, as well as the use phase and end-of-life of our products.
• We prioritize addressing the most severe potential human rights violations first. Covestro performs ad hoc risk analyses in an event-based manner. Also, internal and external findings may trigger a reassessment of our human rights risks.

• We follow the risk-based approach recommended by the UN, assessing the suitability of our existing measures for the prioritized areas where Covestro may cause, contribute to, or is directly linked to negative impacts on human rights.
• Many measures in the areas of health and safety, product stewardship, compliance, human resources, and sustainable supplier management have long been integrated at Covestro and aim to prevent or mitigate negative human rights impacts.
• We continuously assess and enhance these measures to close any potential gaps and strengthen our human rights management system.

• We continuously monitor the effectiveness of our human rights measures using qualitative and quantitative assessments from both internal and external sources.
• The corporate functions within our Human Rights Office provide regular updates on measure implementation and effectiveness, ensuring we can quickly identify and address any potential gaps.

• We actively encourage the reporting of potential human rights violations in the Group as well as at suppliers’ companies. We use a whistleblower tool for reporting violations, which consists of a worldwide hotline and an online tool.
• We follow a defined process to investigate suspected violations, ensuring involvement of potentially affected stakeholders. Further information on our Corporate Grievance Mechanism can be found here.

• We communicate our human rights activities publicly in our annual report.
• Our Human Rights Office reports regularly (no less than once a year) to the Board of Management on the performance of its human rights due diligence and the systematic integration of these requirements into the management systems at Covestro.