1. Introduction

Eleven Access International Services SRL recognises that respect for human rights is a fundamental responsibility of every organisation operating within the global economy.

The Company is committed to conducting its business activities with integrity, transparency and respect for the dignity and rights of all individuals affected by its operations.

As a provider of transportation services, recruitment solutions and integrated operational support across multiple jurisdictions, Eleven Access acknowledges that its activities may influence employees, subcontractors, local communities, and supply chain partners.

For this reason, the Company seeks to ensure that its operations are conducted in a manner that:

• respects internationally recognised human rights
  • protects the wellbeing and dignity of employees and partners
  • promotes ethical labour standards
  • prevents discrimination, exploitation and abuse
  • contributes positively to responsible and sustainable business practices.

This policy outlines the principles through which Eleven Access integrates respect for human rights into its governance framework, operational practices and business relationships.

2. Purpose of the Policy

The purpose of this Human Rights Policy is to establish a clear framework for protecting and promoting human rights across the Company’s operations.

This policy aims to:

• define the Company’s commitment to internationally recognised human rights standards
  • establish expectations for employees, subcontractors and business partners
  • identify potential areas of human rights risk related to the Company’s operations
  • provide mechanisms for reporting concerns and addressing potential violations
  • integrate responsible business practices within operational and contractual frameworks.

This policy forms part of the broader ethical governance structure of Eleven Access and should be read in conjunction with the Company’s:

• Code of Conduct
• Anti-Bribery and Anti-Corruption Policy
• Workplace Anti-Harassment and Anti-Discrimination Policy
• Modern Slavery and Human Trafficking Policy
• Health, Wellbeing and Work-Related Stress Policy
• Subcontractor Performance Monitoring Procedure.

3. International Standards and Reference Framework

Eleven Access aligns its human rights approach with internationally recognised principles and standards, including:

• The Universal Declaration of Human Rights (UDHR)
  • The International Covenant on Civil and Political Rights
  • The International Covenant on Economic, Social and Cultural Rights
  • The ILO Declaration on Fundamental Principles and Rights at Work
  • The UN Guiding Principles on Business and Human Rights.

These frameworks establish the global expectation that companies must respect human rights, avoid causing harm through their activities, and address potential negative impacts where they occur.

The Company recognises that respect for human rights is not only an ethical obligation but also an essential element of responsible corporate governance and sustainable business development.

4. Scope and Applicability

This policy applies to:

• all employees of the Company
  • temporary workers and deployed personnel
  • subcontractors and service providers
  • recruitment partners and agencies
  • suppliers and operational partners
  • any individuals acting on behalf of the Company.

All parties engaged in business activities with Eleven Access are expected to uphold the principles outlined in this policy.

5. Risk Awareness and Human Rights Due Diligence

The Company acknowledges that certain operational activities may present potential risks related to human rights.

Examples of such areas include:

• employment practices and recruitment processes
  • working conditions and occupational safety
  • subcontractor and supply chain operations
  • deployment of personnel across different jurisdictions
  • equality and non-discrimination in employment
  • protection of vulnerable workers.

To address these risks, Eleven Access aims to implement a structured due diligence approach that includes:

• identifying potential human rights risks
  • integrating preventive measures within operational procedures
  • monitoring supplier and subcontractor compliance
  • addressing potential impacts through appropriate corrective actions.

Human rights considerations are integrated into the Company’s operational risk management and governance processes.

6. Key Human Rights Commitments

Equality and Non-Discrimination

Eleven Access promotes equality of opportunity and prohibits discrimination in any form.

Employment decisions are based exclusively on professional qualifications, competence and operational needs.

The Company does not tolerate discrimination based on:

• gender
  • race or ethnicity
  • nationality
  • religion or belief
  • disability
  • age
  • sexual orientation
  • social background or any other protected characteristic.

Fair and Ethical Employment Practices

All employment relationships within the Company are based on lawful and voluntary agreements.

Employees are entitled to:

• written employment contracts
  • fair wages and lawful compensation
  • reasonable working hours and rest periods
  • access to safe and healthy working conditions.

The Company complies with applicable labour legislation in the jurisdictions where it operates.

Prohibition of Forced Labour and Human Trafficking

Eleven Access maintains a strict zero-tolerance policy regarding:

• forced labour
  • bonded labour
  • human trafficking
  • exploitation of vulnerable workers.

Employees and subcontractors must not be required to work through coercion, intimidation or unlawful pressure.

Child Labour

The Company strictly prohibits the employment of child labour.

Minimum working age requirements are respected in accordance with national legislation and international labour standards.

Freedom of Association

Eleven Access respects the right of employees to freedom of association and collective representation in accordance with applicable legislation.

Employees may communicate workplace concerns and participate in constructive dialogue without fear of retaliation.

Health, Safety and Wellbeing

The Company is committed to maintaining safe and healthy working conditions.

Operational activities are conducted with strong emphasis on:

• risk prevention
  • fatigue management
  • safe operational procedures
  • employee wellbeing.

The Company recognises that employee health and wellbeing directly contribute to operational safety and service quality.

7. Responsible Supply Chain and Business Partners

Eleven Access expects suppliers, subcontractors and business partners to operate in accordance with ethical labour standards and respect for human rights.

Partners must:

• comply with applicable labour legislation
  • provide safe working conditions
  • respect employee rights and dignity
  • avoid forced labour or exploitative practices
  • comply with contractual and ethical requirements.

The Company may monitor supplier compliance through documentation review, operational assessments and contractual obligations.

8. Speak-Up and Reporting Mechanism

Eleven Access encourages employees and partners to raise concerns regarding potential misconduct or human rights violations.

Concerns may include:

• discrimination or harassment
  • unethical business conduct
  • corruption or fraud
  • labour exploitation
  • workplace safety risks.

Reports may be submitted confidentially to:

hr@elevenaccess.com

All reports will be treated seriously and handled in a confidential and professional manner.

The Company strictly prohibits retaliation against individuals who raise concerns in good faith.

9. Implementation and Integration

This policy is integrated into the Company’s governance and operational framework through:

• internal policies and procedures
  • employee awareness and training
  • contractual requirements for suppliers and subcontractors
  • operational risk management processes.

Management is responsible for ensuring that the principles outlined in this policy are implemented and respected across all relevant business activities.

10. Monitoring and Continuous Improvement

Eleven SRL is committed to continuously improving its ethical governance and human rights practices.

The Company will periodically review this policy in order to:

• reflect regulatory developments
  address emerging operational risks
  • align with international best practices.

Updates may be implemented where necessary to ensure the policy remains effective and relevant to the Company’s activities.