S3 – Affected Communities

We implement an ongoing process of human rights due diligence that extends across our operations, supply chains, and communities. Our Human Rights Principle outlines our approach to respecting the rights of affected communities.

We continue to use human rights criteria and assessments to inform decision-making on strategic business development, investments and innovation projects. For example, in 2024, we completed a human rights impact assessment for the potential construction and operation of a new unit at Neste's Porvoo refinery. The assessment identified and evaluated potential human rights risks to local communities.

Policies related to affected communities

Human Rights Commitment Statement

Our Human Rights Commitment Statement establishes our foundational commitment to the International Bill of Human Rights, the International Labour Organization's core labor conventions and the United Nations Guiding Principles on Business and Human Rights (UNGPs).

Code of Ethics

In our Code of Ethics, we commit to "conduct our business in a manner that respects the rights and dignity of all people."

Environmental policies

We set minimum, mandatory requirements for the management of water, waste, wastewater and pharmaceuticals in the environment. Each part of the organization is required to protect the environment by reducing risk; to ensure individuals are appropriately skilled, competent and fit for performing their tasks properly; and to comply with environmental regulation.

Community health considerations

We regularly measure water and air quality to make sure we remain within limits permitted by applicable local regulation. Sites with established regulatory limits, conditions or specific limitations on discharges are responsible for collecting data on a periodic basis.

Stakeholder engagement commitment

We engage across industries, listen to stakeholder concerns, and take individual or collective action. We also engage in collaborative efforts with stakeholders from civil society, investor communities and international institutions on our approach to human rights.

Prevention initiatives

Our pioneering urban health programme, Cities for Better Health (CBH), sits at the forefront of our prevention efforts. Now with a broadened scope that aligns with our expansion into new therapy areas, this public-private partnership drives action to prevent serious chronic diseases across a global network of 51 large cities.

The Childhood Obesity Prevention Initiative (COPI) is the latest initiative to come out of CBH. Taking aim at childhood overweight and obesity, it seeks to deliver measurable, community-driven interventions promoting healthy eating and physical activity among children living in underprivileged urban communities.

Community policies would be contained in the Sustainability Statement (pages 64-172). However, the company is a member of UN Global Compact supporting UN SDGs with focus on education, health and medical care, and environment.

As a responsible employer, we commit to advancing social progress for our employees and communities.

Furthering Ernest Solvay's pioneering social vision, we are committed to enhancing their well-being through various initiatives, while developing their skills and capabilities.

Ubisoft is committed to creating gaming experiences that enhance players' lives and environments in which they can fully enjoy the gaming experience with their friends in complete safety. This includes the development of a safe player environment through constant investment in efficient solutions for protection of player privacy and data and prevention of toxic behavior online.

Processes for engaging with affected communities about impacts

Local community involvement in station improvements We involve local communities in and around the station improvements.

Civil engineering and construction projects In connection with our major civil engineering and construction projects, we minimise the risks of nature and biodiversity impacts through engagement of local communities in the form of public meetings and collaboration with the authorities on EIA processes and local development plans.

Local projects and partnerships DSB has launched a number of local projects to get more people in Denmark to take the train and reduce road congestion.

Example: Køge Municipality collaboration One of these projects is in Køge, where DSB and Køge Municipality in 2023 joined forces to make it more attractive to travel on public transport at work and in people's leisure time. The collaboration has helped us gain knowledge and data about the local conditions, enabling us to develop more relevant local marketing efforts.

The collaboration has contributed to overall passenger growth on the line between Køge and Copenhagen, and more local initiatives are on the way in Køge Municipality. These include an expansion of parking facilities at Køge Nord Station, which will make it more attractive for commuters on Zealand to take the train the last stretch towards Copenhagen.

Community feedback and response Also north of Copenhagen, a local project has made a difference for our customers. In the summer of 2024, it became free of charge to take bicycles on Kystbanen and on the regional trains between Elsinore, Copenhagen Central Station and Næstved. This project built on the positive experience gained from S-trains and required reconstruction of a number of coaches on the regional trains to increase their bicycle capacity from 4 to 16.

The project has been well received by our customers, who especially take advantage of the opportunity to bring their bikes free of charge on weekends. The Danish Cyclists' Federation is also pleased with the pilot project, which they would like to become a permanent arrangement.

Stakeholder engagement is a key component of Neste's human rights due diligence, extending across our operations, supply chains, and communities. We actively seek opportunities to collaborate with our stakeholders to advance positive systemic change.

In 2024, we completed a human rights impact assessment for the potential construction and operation of a new unit at Neste's Porvoo refinery, which included engagement with local communities to understand potential impacts and develop appropriate mitigation measures.

Processes for engaging with affected communities about impacts

Stakeholder engagement approach

We engage across industries, listen to stakeholder concerns, and take individual or collective action. We also engage in collaborative efforts with stakeholders from civil society, investor communities and international institutions (e.g., PSCI and Business for Social Responsibility's Human Rights Working Group) on our approach to human rights.

External grievance mechanism

Our SpeakUp grievance mechanism is also open to external parties, including community members. Grievances can be filed via webform or telephone with an independent external service, which is available 24/7.

Nature assessment process

In 2024, we conducted a nature assessment for own operations and upstream supply chain, aligned with the TNFD LEAP approach. In 2025, we will conduct further analysis to understand the impact on Novartis, the environment and society, including an assessment of downstream value chain impacts.

Local community monitoring

We regularly measure water and air quality to make sure we remain within limits permitted by applicable local regulation, which helps protect community health and environment.

Industry collaboration

We participate in policy discussions with partners through various stakeholder dialogues and industry platforms, which includes engagement with community representatives and civil society organizations.

Community engagement processes include local engagement at operational level, employee volunteering programme with six non-profit organisations. Further details in Sustainability Statement (pages 64-172).

The Group engages with affected communities, particularly player communities, through direct relationships enabled by digital transformation. Player communities are at the very heart of the games and the Group has established mechanisms for ongoing engagement.

We have established various channels for communities to raise concerns about our operations. These include local engagement processes and grievance mechanisms appropriate to the communities where we operate.

Our human rights impact assessments include the identification of appropriate channels for affected communities to raise concerns about potential impacts from our operations and projects.

Processes to remediate negative impacts and channels for affected communities

External grievance mechanism access

Our SpeakUp grievance mechanism is open to external parties, including affected community members. Grievances can be filed via webform or telephone with an independent external service, which is available 24/7.

Environmental compliance and remediation

Sites perform an annual self-assessment of their controls, and the assessments of a representative sample of sites are tested by an independent governance team each year. Conformance reviews and legal compliance audits are conducted at least every five years.

Community impact assessment

We conduct ongoing human rights due diligence across our business and ensure that we have policies and management systems in place to support our commitments, which includes consideration of community impacts.

Stakeholder collaboration on remediation

We engage in collaborative efforts with stakeholders from civil society, investor communities and international institutions (e.g., PSCI and Business for Social Responsibility's Human Rights Working Group) on our approach to human rights and community impact remediation.

Environmental monitoring for community protection

We regularly measure water and air quality to make sure we remain within limits permitted by applicable local regulation, with results that help protect community health and environment.

See page 145 for processes to remediate negative impacts and channels for affected communities to raise concerns.

Reporting systems are systematically integrated into Ubisoft's online games to enable players to report toxic behaviors so that they can be addressed as quickly as possible. The Group has implemented processes to address negative impacts and provide channels for affected communities to raise concerns.

Community Impact Management

Local value creation: The creation of shared value for the communities in the vicinity of production sites has also been strengthened thanks to the activities organised with Plastic Free and the collaboration with the Banco Alimentare ETS Foundation, for the collection of surplus food from canteens.

Educational initiatives: Training and engagement activities were strengthened on sustainability and DE&I issues, as well as were activities aimed at promoting STEM subjects in support of the educational system and the local area. These include the Leonardo Constellation project, carried out in collaboration with Il Cielo Itinerante and 10 other associations that work on social change by sharing Leonardo knowledge and hosting children at the Italian sites.

Community solutions: Leonardo has identified the issue as a priority both for the business and in terms of the materiality of its impacts, risks, and opportunities. The benefit of the solutions offered by the Group in the area of protecting territories, infrastructure and citizens, as well as in the area of emergency management, is recognised, even by stakeholders, as the most relevant impact generated by Leonardo on society, consistent with purposes and strategy.

In 2024, we completed a human rights impact assessment for the potential construction and operation of a new unit at Neste's Porvoo refinery. The assessment identified and evaluated potential human rights risks to local communities, construction workers, and future employees at the facility, providing recommended mitigation measures to ensure human rights are respected throughout the project.

We continue to work proactively with local communities where we operate to understand and address potential impacts from our operations and projects.

Affected Communities - Actions and Performance

Hydro aims to improve lives and livelihoods wherever it operates by contributing to the protection of human rights and access to equal opportunities, resilient local communities in a changing world, and development of skills and jobs for the future low-carbon economy.

Community Investment and Support

In 2024, Hydro spent NOK 300 million in its local communities including community investments, TerPaz (local community centers), donations and sponsorships, and launched its program to increase funding to projects aligned with Hydro's Just Transition priorities in the communities where it operates.

In addition to this, Hydro made a provision in December 2024 of NOK 300 million to support communities along the pipeline between the Paragominas mine and Alunorte refinery in Brazil. The provisioned funds will support infrastructure, local production facilities, and skills development.

Skills Development Program

Hydro has a target to equip 500,000 people with new skills and education by 2030. Hydro progressed towards this target by reaching more than 44,000 people in 2024. In total, 241,000 people have benefitted from Hydro's education and skills initiatives since 2018.

Social Programs

100,000 people have been assisted by social programs since 2018 at Bauxite & Alumina operations.

Taking action on material impacts on affected communities

Human rights risk assessment

In early 2024, we completed our company-wide annual human rights risk saliency assessment. This reaffirmed our focus on four previously identified priority areas, which include considerations of community impacts.

Nature and biodiversity assessment

We are conducting nature assessments at priority sites close to nature-sensitive areas. Where material, we will establish site-specific nature management plans.

In 2024, we conducted a nature assessment for own operations and upstream supply chain, aligned with the TNFD LEAP approach. In 2025, we will conduct further analysis to understand the impact on Novartis, the environment and society, including an assessment of downstream value chain impacts.

Environmental protection measures

We have mitigated physical risks to our sites by putting in place infrastructure (e.g., shelters, flood defenses), supported by administrative procedures (e.g., business continuity plans). These measures also help protect surrounding communities.

Water and environmental quality

We seek to minimize discharge of active pharmaceutical ingredients (APIs) into water systems, and do not dispose of waste containing APIs in landfill, which protects community water resources.

As of the end of 2024, 97% of Novartis manufacturing sites can demonstrate that they meet internal water quality standards, helping protect community water resources.

Community health considerations

Shifts in temperature and air pollution affect disease patterns. This is likely to influence the prevalence and severity of certain health conditions, in particular cardiovascular diseases, respiratory conditions, kidney diseases, lung cancer, and communicable diseases such as malaria and dengue. We consider these broader community health impacts in our climate adaptation strategies.

See page 145 for taking action on material impacts on affected communities. Training a local offshore wind workforce: In the US, we developed a workforce development programme that has provided 335 union workers with the necessary credentials for working offshore. Delivering additional value with renewable energy: In connection with the construction of Hornsea 3 in the UK, we have launched a community benefit fund that will distribute up to GBP 7 million over ten years to invest in the region's future. In 2024, 21 social and environmental groups were selected.

Affected communities and noise

Schiphol Group is and remains committed to reducing noise disturbance in the surrounding area. Noise disturbance from air traffic remained a key issue in our discussions with local communities in 2024. Direct community engagement and communication is crucial in navigating the delicate balance between aviation and the well-being of people who live near Schiphol Group's airports. This balance influences the future development of our airports and is therefore important for our license to operate.

Schiphol Group is committed to reducing noise disturbance for the communities surrounding its airports. We have been working with Luchtverkeersleiding Nederland ('Air Traffic Control the Netherlands'; LVNL) and with the support of airlines on the Minder Hinder noise reduction programme. This involves developing and implementing concrete measures that reduce noise disturbance in the area surrounding Schiphol.

The ambition to reduce noise disturbance in the surrounding area is also reflected in the new airport charges published at the end of October. Once the new airport charges come into effect, newer, quieter aircraft will pay lower fees while older, noisier aircraft will pay higher fees for landing at Schiphol.

Environmental Fund

Schiphol Group contributes to the mitigation of noise disturbance. In 2008, the Schiphol Living Environment Foundation was established in collaboration with the Province North Holland. The Environmental Fund, successor to the Stichting Leefomgeving Schiphol ('Schiphol Quality of Life Foundation'), now has a definite form and will start work in early 2025. The Environmental Fund has 10 million euros per year to spend on measures to improve the quality of life in the local environment until 2031.

Local residents reputation score

TPI Local Residents – Reputation Score: 6.6 Target 2024: 7; result 2023: 6.7

The TPI Local Residents is based on the results of the reputation score as surveyed quarterly by the research agency Motivaction among local residents. The average score obtained from these surveys in 2024 was 6.6 (6.7 in 2023). This means that the target of 7 has not been achieved. Over the past year, significant efforts have been made to streamline operations, improve the quality of work and foster a better balance with our surrounding environment. While progress has been made, local residents indicate that there are still opportunities for improvement, particularly in strengthening corporate responsibility such as sustainability, noise mitigation, improving living conditions and transparent communication.

Number of severely annoyed people

The number of severely annoyed people (48Lden) in the Schiphol area increased in 2024. Main reason is the rise in air traffic movements. The number of severely annoyed people per flight has not changed compared to 2023.

People that experienced noise disturbance at night: 12,835 (2023: 11,775)

The Group takes action to address material impacts on affected communities through various initiatives including the 'Fair Play' awareness program, player Code of Conduct, and collaboration with 'Safe In Our World' association to promote better mental health online through the 'Good Game Playbook' launched in November 2023.

Affected Communities Targets

Persons empowered with skills and education: Provide quality education and capacity building for 500,000 people by 2030

2024 Performance

Hydro progressed towards its target to equip 500,000 people with skills and education for the future low-carbon economy by 2030, reaching more than 44,000 people in 2024. In total, 241,000 people have benefitted from Hydro's education and skills initiatives since 2018.

Targets related to managing material impacts on affected communities

Environmental targets supporting community protection

Water quality targets

• 2025 target: No water quality impacts from manufacturing effluents by 2025

  • Manufacturing sites meeting water quality standards: 97% (2024)
  • Progress: On track

• 2030 target: No water quality impacts from manufacturing effluents by 2030

  • Own sites meeting water quality standards: 100% target (including all manufacturing sites and labs)
  • All suppliers meeting water quality standards: 100% target

Water consumption targets

• Reduce water consumption in operations by half by 2025 (vs. 2016 baseline)
• Progress: 57% reduction achieved - target met

Waste reduction targets

• Reduce waste sent for disposal by 50% by 2025 (vs. 2016 baseline)
• Progress: 72% reduction achieved - target met
• New target: Reduce waste sent for disposal by 30% by 2030 (vs. 2022 baseline)

Nature and biodiversity targets

• Implement water use reduction for own and supplier sites based in water stressed basins
• Site-specific targets to be set for material sites affecting local communities

Climate adaptation measures

We assess and plan for climate-related impacts on communities, including changes in disease patterns and extreme weather events, as part of our climate adaptation strategy.

See page 145 for targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities.