1. Introduction
both® is committed to respecting and promoting internationally recognized human rights in every aspect of our business. This Policy formalizes our obligations under the UN Guiding Principles on Business and Human Rights and applicable national laws.

 

2. Scope
This Policy applies to all both® entities worldwide—including employees (full-time, part-time, temporary), contractors, suppliers, business partners and any third parties acting on our behalf.

 

3. Core Principles

• Respect for Dignity: We treat everyone with fairness, courtesy and respect.

• Non-Discrimination: We prohibit discrimination or harassment on grounds of race, color, gender, sexual orientation, religion, age, disability, nationality or any other protected characteristic.

• Prohibition of Forced & Child Labor: We do not tolerate forced, bonded or under-age labor in our operations or supply chains.

• Freedom of Association: We recognize the right of workers to join or form trade unions or other representative organizations.

• Safe & Healthy Work Environment: We maintain workplaces free from violence, intimidation and harassment.

• Privacy & Data Protection: We safeguard personal data in accordance with our Privacy Policy and applicable law.

4. Human Rights Due Diligence
We perform a structured human-rights risk assessment annually covering:

• Our operations: all offices, studios and digital platforms

• Our supply chains: from procurement of goods and services through delivery

Findings trigger corrective action plans; progress is tracked by our Compliance team.

5. Grievance & Reporting Mechanism
both® provides secure channels for reporting concerns or violations without fear of retaliation:

• Email hotline: hr@both.works (monitored 24/7)

• Anonymous email: whistleblower@both.works

All reports are investigated promptly, and outcomes are communicated to the reporter where feasible.

6. Accountability & Review

• The Chief Compliance Officer oversees implementation and reports human-rights performance to Executive Leadership annually.

• This Policy is reviewed and updated at least once per year to reflect evolving best practices and stakeholder feedback.

7. Legal Compliance
both® has never been subject to investigation or penalty for human-rights violations. We adhere to all applicable international standards, including the UN Guiding Principles on Business and Human Rights, and local legislation in every jurisdiction where we operate.

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Effective Date: 1 January 2025
Next Review: 1 January 2026

Policy Owner: both FZ LLC (Bosky Cherin & M. Thomas George)