Spectrumlabs S.A. is committed to ensuring a working environment that respects human dignity, promotes equal treatment and equal opportunities, and is free from all forms of violence and harassment. The Company applies zero tolerance to violence, intimidation, threats, psychological or physical abuse and harassment, including sexual and gender-based harassment. This Policy is based on the following principles:

• Whether at the workplace, during business travel, work-related training or social activities, or through work-related communications and information and communication technologies.
• Systematic identification and assessment of risks related to violence and harassment and implementation of appropriate measures for prevention, control, mitigation and response, in accordance with applicable legislation and the Company’s internal procedures.
• Continuous information, awareness and, where appropriate, training of personnel regarding the prevention and handling of violence and harassment, employees’ rights and obligations, and the available reporting channels.
• Maintenance of safe and easily accessible communication channels for reports or complaints and provision of appropriate guidance to persons seeking information or support.
• Prompt, impartial and confidential handling of every report or complaint, with respect for the dignity and rights of all persons involved and protection of relevant information to the extent required for the proper investigation of the matter.
• Strict prohibition of any form of retaliation or adverse treatment against any person who reports an incident, submits a complaint, provides information or participates in good faith in the relevant process.
• Adoption of necessary, appropriate and proportionate measures where a violation is established, with the aim of protecting affected persons, preventing recurrence and maintaining a safe and respectful working environment.
• Support, to the extent possible, for employees affected by violence or harassment and provision of appropriate measures or reasonable adjustments for employees who are victims of domestic violence, in accordance with the applicable corporate framework.

Implementation of this Policy is supported by Procedure Δ-30 for the prevention and handling of violence and harassment at work, the Occupational Health & Safety Policy, the Employee Manual and other relevant Spectrumlabs S.A. procedures. All employees are expected to contribute to a workplace of mutual respect and to comply with this Policy and the related internal procedures.