Focus Topics – Respect for human rights

Upholding human rights

Impacts, risks, and opportunities

Impacts

Zehnder Group’s approach to human rights aims to prevent and mitigate any potential negative impacts on individuals within its own operations and across the supply chain. This includes risks related to unfair labour practices, unsafe working conditions, restrictions on freedom of association, and discriminatory treatment. By setting expectations regarding fair labour standards, workplace safety, freedom of association, and non-discrimination, the Group aims to minimise the risk of human rights violations and ensure decent working conditions.

With regard to its products, Zehnder Group considers the potential impact on consumers’ health and safety. The design and development of products aim to avoid adverse effects on indoor air quality and, where possible, to promote healthy indoor environments. While these measures primarily serve to mitigate potential negative impacts, any positive effects depend on appropriate product use and operating conditions.

Risks and opportunities

The global nature of our supply chain, particularly in high-risk regions, makes ensuring respect for human rights more complex. Failure to address issues such as forced labour, poor working conditions and environmental damage can result in legal challenges, reputational damage, and potential loss of business opportunities.

Strengthening human rights due diligence can improve responsible sourcing, strengthen supplier relationships, and increase overall resilience. Engaging with employees, suppliers, and local communities helps to identify root causes and supports the implementation of more effective corrective actions. Increased transparency, targeted audits, and improved supplier assessments drive higher standards across the value chain. Furthermore, sustainable product development and responsible procurement reinforce Zehnder Group’s position as a reliable and ethical business partner.

Management approach

We have systematically evaluated our performance across the six core elements of human rights due diligence, in line with the UNGPs, and with a focus on minimising the use of rare earths and conflict minerals. We have established clear objectives and metrics to reinforce our dedication to human rights.

The salient human rights issues for Zehnder Group across the value chain include child labour, modern slavery, and forced labour, as well as environmental impacts on people, particularly in logistics and end-of-life management. Actions are prioritised based on severity and likelihood, and focus on preventing workplace discrimination, ensuring living wages, eliminating modern slavery, and strengthening OHS.

Responsibility for human rights due diligence has been embedded within Zehnder Group’s corporate governance framework and is overseen by the Steering Committee, the CEO, and the Chair of the Board of Directors. To further ensure compliance with our sustainability goals, human rights considerations are incorporated into the company’s strategies, policies, and processes across all departments. The Group’s sustainability team coordinates these measures in consultation with the Group Executive Committee and in collaboration with departments such as Legal, Compliance, HR, Procurement, and Logistics.

Our approach aligns with international standards, including the ILO Conventions, the ILO-IOE Child Labour Guidance Tool¹, and the UNGPs.

Zehnder Group’s human rights due diligence framework

Our standalone Human Rights Directive defines clear goals and measures to strengthen our commitment to human rights. Through regular monitoring, public reporting, and effective grievance mechanisms, we ensure the highest ethical standards and transparency, and continuous improvement.

Furthermore, Zehnder Group has integrated human rights aspects into several existing policies, including those against harassment and for the promotion of diversity, equity, and inclusion, to encourage fair treatment and inclusion. Safe and secure working conditions are also guaranteed in our local OHS policies. In addition, the Zehnder Group Code of Conduct, the Supplier Code of Conduct and our Modern Slavery Statement (UK only) are integral to our commitment to upholding ethical business practices throughout the supply chain.

Child labour and conflict minerals

In line with Swiss regulations on due diligence obligations and transparency concerning minerals and metals from conflict areas,² and child labour, we address these issues within the broader framework of our human rights due diligence.

Zehnder Group categorically rejects child labour. We are following international standards, as explained above, and therefore comply with the equivalent provisions of Swiss law.³ Within the Group, the risk is considered very low due to the high production depth. In addition, our Supplier Code of Conduct ensures that our suppliers comply with ILO standards. According to the annual group-wide review, no cases of child labour were identified within Zehnder Group legal entities. There were likewise no such cases of child labour uncovered during the audits carried out at suppliers. Furthermore, the analysis of child labour at high-risk suppliers did not give rise to any reasonable suspicions.

With regard to minerals from conflict-affected regions, we have conducted assessments in accordance with the Ordinance on Due Diligence and Transparency relating to Minerals and Metals from Conflict-Affected Regions and Child Labour. Although our total imports are below the threshold values, we are committed to minimising our use of conflict minerals and ensuring that our materials are responsibly sourced, avoiding materials from conflict-affected regions wherever possible.

¹The ILO-IOE Child Labour Guidance Tool is a resource developed by the ILO and the International Organisation of Employers (IOE) to help companies identify, prevent, and address child labour in their operations and supply chains.

²Tantalum, tin, tungsten, gold (3TG), as defined by regulation (EU) 2017/821

³As defined in CO Art. 964j para. 4 and Ordinance on Due Diligence Obligations and Transparency Regarding Minerals and Metals from Conflict Areas and Child Labour Art. 9 para. 1

Implementation and outlook

Implementation of the above management approach and policies is structured around two focus areas with defined targets.

Targets

Ambition: Apply a human rights due diligence approach and respect the UN Guiding Principles on Human Rights

Target: Set up a human rights due diligence risk management process and implement a roadmap based on the UN Guiding Principles on Business and Human Rights

• Status: Progress continued in establishing a human rights due diligence (HRDD) risk management process aligned with the UNGPs. The Supplier Code of Conduct was revised to expand its scope and ensure alignment with other internal policies, strengthening coverage of key human rights topics. In addition, the Group Occupational Health and Safety Directive, approved in May 2025, provides clear guidance on OHS management system requirements supporting worker protection.
  
  Employee awareness was further enhanced through the Sustainability Snacks training series, which includes human rights topics alongside environmental and social issues. No additional human rights-specific trainings have yet been released beyond existing modules on SuccessFactors. The Zehnder Group Integrity Line was reviewed for outreach improvements, with implementation planned beyond 2025. The completion of the Job House roll-out across most EMEA and all North American branches also paved the way for continued progress on the Living Wage project in North America.
• Outlook: We plan to launch our Living Wage project in North America in 2026, which will entail a thorough gap analysis of actual wages compared to living wages and the formulation of a concrete action plan to close potential gaps, where applicable.

Ambition: Minimise the use of rare earth and conflict minerals in our products and production processes

Target: Assess our main direct high-risk material supply chains by country of origin

• Status: Efforts to assess high-risk material supply chains by country of origin continued through additional outreach and direct communication with suppliers’ sustainability teams. Despite these efforts, obtaining full transparency remains challenging, as many suppliers are either unwilling or unable to share detailed origin information, and the Group’s influence over upstream supply chains remains limited.
• Outlook: While the topic remains important, this specific target is considered closed. The focus will shift toward strengthening market intelligence and improving visibility in the steel supply chain to support future due diligence and responsible sourcing initiatives.