1. Purpose.
The purpose of this policy is to formalize the commitment of the IMTO companies, hereinafter “the Group,” to the human rights recognized in national and international law. Furthermore, this commitment will help define the principles that will apply to the Group’s operations to ensure due diligence in the area of human rights.
2. Scope of Application.
This policy applies to all companies within the Group within the limits established by law.
In addition, this policy also applies, as appropriate, to joint ventures, temporary consortia, and other equivalent partnerships, when the entity assumes management responsibility for them.
3. Basic Principles of Conduct.
To achieve the established objective and fulfill the commitments outlined, the Group will adopt and promote the following basic principles, which shall serve as a guide for the conduct of all individuals and companies comprising the Group:
• Identification of the potential impacts that the Group’s operations and activities may have, directly or indirectly, on human rights.
• Monitoring compliance with respect for and commitment to human rights, particularly in areas where there is a higher risk of impact.
• Whistleblower channel for reporting situations and activities that pose a higher risk of human rights violations – comiteetico@imto.com
• Promotion of a corporate culture that respects human rights in accordance with our vision, mission, and corporate values.
• Assessment of measures to safeguard and protect human rights in the course of the Group’s activities.
4. Human Rights Regulatory Framework.
In addition to this policy, the following form part of the Group’s regulatory framework:
• Social policies: aimed at addressing the needs and expectations of stakeholders that impact IMTO, such as workplace safety, equal opportunity, work-life balance, and quality;
• Personal Data Protection Policy: the right to data protection for all individuals who interact with the Group’s companies, with respect for and protection of the right to honor and privacy being fundamental in the processing of personal data.
• Procurement Policy: Shared responsibility with suppliers regarding respect for human rights, with the aim of increasing the number of suppliers committed to sustainable development and a human rights strategy.
• Rejection of child labor, forced or compulsory labor, and any other form of modern slavery.
• Respect for freedom of association and collective bargaining.
• Respect for the right to free movement within the country, subject to applicable law.
• Non-discrimination based on status or characteristics, as established in Article 14 of the Spanish Constitution.
• Respect for the right to a clean, healthy, and sustainable environment, as set forth in Article 45 of the Spanish Constitution.
Mascaraque, January 28, 2025
