Social & Human Rights Policy

BICO’s social and human rights due diligence process takes a risk-based approach and is carried out in the below three steps to identify, assess and address actual or potential material adverse social and human rights impacts:

Identify – Screen to identify adverse impact

• Screening against specific expectations in Human Rights risk sectors
• Screening against certain markets/geographies

Assess – Assess the findings in the screening

• Reach an opinion on the risk of an actual or potential adverse social and human rights impact

Act (cease, prevent or mitigate) – Act on the assessment
• Set expectations on the BICO subsidiaries and partners in the value chain

5.1. Identifying adverse social and Human Rights impacts (screening)

The purpose of the screening is to identify risk for potential or actual adverse human rights impacts. This is done through a combination of screening against policies and processes in risk sectors, general controversy screening and transaction specific screening for transactions involving high human rights risk countries.

5.1.1. Screening against specific expectations in human rights risk sectors

Clients and portfolio companies that operate in human rights risk sectors are covered by specific expectations as described in BICO’s respective sector policies. The following sector policies include specific social and human rights expectations:

(i) Animal welfare
(ii) Clinical trials
(iii) Mining and metals
(iv) Shipping

5.1.2. Screening against certain markets/geographies

When BICO in its value chain is involving cross border trade, there are specific expectations depending on what country the partner’s trading counterpart is based in. If a country is defined as a high human rights risk country, BICO expects the partner, in relation to its size and risk exposure, to have implemented the following:

• Human rights and labour rights policy commitment;

• Human rights due diligence process. The trading counterpart should also be screened for controversies – see controversy screening below.

5.1.3. Controversy screening against BICO’s statements on social and human rights

The BICO subsidiaries and partners in the value chain are subject to a controversy screening, to identify any activities with adverse human rights impact. BICO’s statements on Social and Human Rights, as set out in chapter 6, is used to define BICO’s position on any adverse human rights impact that was identified in the screening.

5.2. Assessment of findings in the screening processes

The findings in the screenings are assessed in order to reach an opinion of the risk of an actual or potential adverse social and human rights impact. The opinion of the risk will lay the ground for how to address the impact, see items 5.3 and 5.4 below. The assessment is defined and performed in the BICO Group and implemented to all subsidiaries.

The following considerations can be used as a guidance when assessing the risk of the identified potential adverse impact in the screening process:

• Clear indications of adverse impact or risk of adverse impact because of the value chain partner or BICO subsidiary;

• The value chain partner or BICO subsidiary lacks systems to manage social and human rights risks:

• The time that has elapsed since a relevant controversy took place and any actions taken to prevent continued adverse impact;

• Potentially vulnerable groups or affected communities are subject to the actual or potential risk that was identified in the screening. Examples of such groups, which can be present in all contexts, are indigenous peoples, women, national or ethnic, religious and linguistic minorities, children, persons with disabilities migrant workers and their families and human rights and environmental defenders;

• The use of the customer or BICO subsidiary product or service has a potential adverse social or human right impact;

• The value chain partner or BICO subsidiary operates in a human rights risk environment such as countries with weak institutions, fragile states, conflict areas, repressive states;

• The upstream value chain partners, to which there is a strong link, was identified in the screening process as having adverse human rights impact.

5.3. Measures to address actual and potential adverse impacts

BICO will address the findings in its screening and assessment by engaging for example through dialogue with value chain partners or BICO subsidiaries, or through other type of engagement, including building leverage. The purpose is that over time the adverse, or potentially adverse impact, will cease, be prevented or mitigated. Depending on the outcome of the assessment in 5.2, the value chain partners or BICO subsidiaries are subject to certain expectations, e.g. to implement a plan or have systems in place that address the risk that was identified in the screening. The following expectations apply in the event of actual adverse impacts:

• BICO expects involved value chain partners or BICO subsidiaries to address the adverse impacts, to engage in meaningful and good-faith dialogue with stakeholders affected by the adverse impacts and to enable remediation, where relevant.

• If a value chain partner or BICO subsidiary, over an extended period of time, does not comply with BICO’s expectations and agreed timeline to improve, and this has material adverse social and/or human rights impact, BICO shall take an active decision on the future of the relationship.