The group has a firm commitment to the defence of human rights, and has a set of tools that ensure and promote the protection of and respect for people, in order to prevent, mitigate and repair any possible impact on human rights. The Company’s practices are thus in line with the principles underlying the United Nations Global Compact, the Guiding Principles on Business and Human Rights: Implementing the United Nations ‘Protect, Respect and Remedy’ Framework (hereinafter, the UNGP), the OECD Guidelines for Multinational Enterprises, the Tripartite Declaration of Principles Concerning Multinational Enterprises and the Social Policy of the International Labour Organization.

• Since 2015, Iberdrola has had a Policy of Respect for Human Rights drawn up in accordance with the highest standards (last amended in April 2021), the principles of which must be followed by all professionals of the group. Among other principles, it commits to:
• To respect the human and labour rights recognised in domestic and international legislation, as well as compliance with international standards in those countries in which human rights legislation has not reached an adequate level of development
• To reject child labour and forced or compulsory labour or any other form of modern slavery and to respect freedom of association and collective bargaining, as well as non-discrimination, the right to freely circulate within each country, and the rights of ethnic minorities and of indigenous peoples in the places in which it carries out its activities.
• To advance a culture of respect for human rights and promote awareness-raising in this field among its professionals at all companies within the group, and especially at those where there may be a higher risk of violation of such rights.
• With this policy, apart from publicly formalising its commitment, Iberdrola wants to transmit to all of its Stakeholders the importance of respecting the human and labour rights.
• In addition, as a basis for the policy, Iberdrola has defined a general human rights due diligence framework to guide responsible business management, developing mechanisms to prevent and mitigate the risk of human rights violations, with the involvement of Stakeholders.
• Among the Stakeholders, Iberdrola's Suppliers:
• They are a key ally in compliance with the Policy of Respect for Human Rights, and therefore assume a shared responsibility. Thus, in the performance of their activities, they must show strict respect for the human and labour rights recognised in national and international law.
• They must comply with the Supplier's Code of Ethics: a guide for action that obliges them to promote actions and adopt the necessary measures in their organisation to eliminate all forms of forced or compulsory labour and to expressly reject the use of child labour. Code of Ethics (iberdrola.com)
• All our contracts include our Supplier’s Code of Ethics and all relevant suppliers are measured in terms of their ESG performance, including a section on human rights. As indicated below, for situations in which a higher risk level has been identified, specific clauses are added to the contracts to increase the level of commitment from those suppliers involved.
• Iberdrola continues to make progress in this regard, and has reacted actively to the recent controversies in Xinjiang:
• The Iberdrola Group has reacted by requiring its suppliers to scrupulously comply with the commitments signed, requesting extraordinary measures to guarantee the non-use of forced labour in the supply chain.
• The final objective would be to identify the origin of the materials and components of the modules and, in particular, the origin of the disputed material, polysilicon. Therefore, Iberdrola is working hard to trace and audit the origin of polysilicon.
• In particular, Iberdrola is working on implementing the following measures:
  
  • • • Express statements by our suppliers rejecting forced labour (in addition to acceptance of Iberdrola's Code of Ethics).
      • Confirmations that they do not use polysilicon or other components from Xinjiang province.
      • Traceability mechanisms for the materials incorporated in the modules.
      • Request for the codes of conduct and ethics applicable to your company and its suppliers.
        
• Avangrid (Iberdrola subsidiary, listed in US) has signed the SEIA (Solar Energy Industries Association) pledge on the firm opposition to the use of forced labour within the solar supply chain, committing to help ensure this and to raise awareness in the industry on this issue. To this end, it supports the development of an industry-led "Traceability Protocol" for the solar supply chain as a tool to identify the source of primary raw materials.
• The rest of the Iberdrola group companies are open to joining any initiative similar to that of SEIA whenever is developed in their countries of origin. In that sense, Ibedrola has joined an active working group in SolarPower Europe about Supply Chain Transparency with the aim to develop traceability and audit mechanisms for all SolarPower Europe’s members.
• And to confirm that our suppliers do not have exposure to the region, Iberdrola is currently negotiating to include, in the PV panel contracts, customer rights to perform, by means of an independent third-party, inspections to audit the traceability of the supply chain and the origins of the materials.