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We believe that business can only flourish in societies where human rights are protected and respected. We recognise that business has the responsibility to respect human rights and the ability to contribute to positive human rights impacts. This is an area of growing importance to our employees, workers, shareholders, investors, customers, consumers, the communities where we operate and civil society groups. There is therefore both a business and a moral case for ensuring that human rights are upheld across our operations and our value chain. This Human Rights Statement contains over-arching principles which we embed into our policies and systems.

The company seeks to provide a work environment where employees are treated with respect, dignity and consideration. This commitment is built upon a framework of policies and procedures designed to ensure fairness in the recruitment, development and retention of all employees.

All employment must be in compliance with all applicable laws and regulations of local authority in Ireland. Where the applicable local laws and regulations require higher or additional levels of protection of human and employment rights than those set out in this Policy, the local laws and regulations will take precedence.

1. Human Rights

The company supports and complies with the United Nations’ Universal Declaration of Human Rights and seeks to honour the principles of internationally recognised human rights. Company employees shall be treated with dignity and shall not suffer harassment, physical or mental punishment or other forms of abuse. The company has effective grievance mechanisms which are transparent, equitable and predictable to enable the remediation of any adverse human rights impacts that may arise in its operations. The company promotes effective employee engagement throughout its operations and welcomes open feedback from employees on all matters of company business.

1.1 Addressing Human Rights Impacts

We recognise that we must take steps to identify and address any actual or potential adverse impacts with which we may be involved whether directly or indirectly through our own activities or our business relationships. We manage these risks by integrating the responses to our due diligence into our policies and internal systems, acting on the findings, tracking our actions, and communicating with our stakeholders about how we address impacts.

We understand that human rights due diligence is an ongoing process that requires particular attention at certain stages in our business activities, such as when we form new partnerships or our operating conditions change, as these changes may create new potential or actual impacts on human rights. In certain countries where we operate, there are particularly high, systemic risks of human rights abuses. We understand that this means that we must put in place additional due diligence to assess these risks and address them effectively, where appropriate, using our leverage to work either in one-to-one relationships or in broad-based partnerships. We recognise the importance of dialogue with our employees, workers and external stakeholders who are or could potentially be affected by our actions. We pay particular attention to individuals or groups who may be at greater risk of negative human rights impacts due to their vulnerability or marginalisation.

1.2 Remedy

We place importance on the provision of effective remedy wherever human rights impacts occur through company-based grievance mechanisms. We continue to build the awareness and knowledge of our employees and workers on human rights, including labour rights, encouraging them to speak up, without retribution, about any concerns they may have, including through our grievance channels. We are committed to continue increasing the capacity of our management to effectively identify and respond to concerns. We also promote the provision of effective grievance mechanisms by our suppliers.

1.3 Our Governance

Our work in this area is overseen by the Shellfish Chief Executive Officer, supported by the Shellfish Management Team including the Production Manager, Retail Manager, Quality Control Manager and Human Resource. This ensures that every part of our business is clear about the responsibility to respect human rights. Board-level oversight is provided by the Shellfish Ireland board of Directors.

2. Compulsory Labour and Human Trafficking

The company does not accept nor condone any form of modern slavery whether forced, compulsory or trafficked labour. Without limitation, the company does not engage sweatshop labour, convict labour or indentured labour under penal sanction.

All company employees shall provide their services to the Company on an entirely voluntary basis and no one shall be forced to remain in the employ of the company against their will.

The company has a zero-tolerance approach to modern slavery and encourages all employees, customers and suppliers to raise concerns about any issue or suspicion of modern slavery, in any part of the company’s business at the earliest opportunity.

3. Child Labour

The company adheres to and strictly complies with international child labour conventions and local child labour laws and regulations of Ireland.

The minimum age of a company Employee shall be in compliance with the Protection of Young Persons (Employment) Act, 1996, and in any event, shall not be less than 14 years.

The minimum age for admission to any type of work which by its nature or the circumstances in which it is carried out is likely to jeopardise the health, safety or morals of young persons shall not be less than 18 years.

If it is suspected that an underage worker is employed on site or in the supply chain then immediate steps will be taken to mitigate the risk to the child. Child Protection Services and local authorities will be contacted where appropriate.

4. Empowering Women through Rights, Skills and Opportunities

Around the world many women face discrimination and disadvantage, lack access to skills and training, and face roadblocks to their active participation in the economy. They often lack the protection of basic rights and laws. Poverty, discrimination and violence against women are major barriers to opportunity. Women are integral to our business model and growth ambitions. We seek to manage and grow socially responsible businesses where women participate on an equal basis. We believe that women’s rights and economic inclusion are priorities to win long-term. 3 Our approach starts with the respect of the rights of women and extends to their promotion as well as helping to develop skills and open up opportunities, both in our own operations and our value chain.

5. Going Forward

We continually evaluate and review how best to strengthen our approach to addressing human rights, including labour rights. We believe that working through external initiatives and partnerships, for example with other industry, NGO, trade union, supplier and other business partners, is often the best way to address shared challenges. This Human Rights Policy Statement consolidates our existing commitments and brings increased clarity on our processes and procedures. Its principles are implemented across our operations and value chain.

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