INTRODUCTION AND PURPOSE

DEFY’s employees are of great value and the key to our success. DEFY must strive to provide a workplace where employees can fulfil their potential in an open and inspirational working environment. We must maintain a strong commitment to high standards that deliver a fair, respectable and safe workplace for all employees in DEFY.

The purpose of this policy is to define the labour and human rights standards to which all employees in DEFY are entitled, irrespective of the country in which they work.

SCOPE

This policy applies globally to the management, employees and contract workers of all entities in DEFY.

Where DEFY participates in existing joint ventures as a non- controlling shareholder, the other shareholder(s) shall be made specifically aware about the significance to DEFY of the policy and shall be encouraged to apply the same policy or a similar standard to the joint venture. For contemplated new minority joint venture cooperations, DEFY shall strive to commit the other shareholder(s) to adopt the policy or a similar standard for the joint venture.

REQUIREMENTS

1. NON-DISCRIMINATION

1.1. DEFY does not tolerate any form of discrimination against our employees based on race, colour, gender, language, religion, political or other opinion, caste, national or social origin, property, birth, union affiliation, sexual orientation, age, disability, or other distinguishing characteristics.

1.2. Any employment-related decisions, from hiring to termination and retirement, must be based solely on lawful, non-discriminatory criteria.

2. FORCED LABOUR

2.1. DEFY does not tolerate any form of forced labour including bonded labour, indentured labour and slave labour, or human trafficking. Workers must be allowed to move around freely and leave their place of work when their working hours end.

3. CHILD LABOUR

3.1. DEFY does not tolerate the hiring of child labour under any circumstances. The minimum age for full-time employment must be 15 or the legal minimum age for employment under Applicable Law, whichever is higher . Where the applicable local minimum working age is 14 in accord- ance with exceptions for developing countries, this lower age will apply. DEFY must not hire employees under the age of 18 for positions requiring hazardous work that could jeopardise health, safety or morals.

4. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

4.1. DEFY must respect employees’ rights to form, join or not join a labour union, or other organisation of their choice, and to bargain collectively in support of their mutual interests without fear of punitive actions such as intimidation, harassment or termination of employment.

5. HARASSMENT

5.1. DEFY must protect workers from any acts of physical, verbal, sexual or psychological harassment, bullying, abuse or threats in the workplace by either their fellow employees or managers.

6. WORKING HOURS, BENEFITS AND WAGES

6.1. DEFY must adhere to the stricter of Applicable laws or industry standards, relating to minimum wages, working hours, overtime and benefits.

6.2. Employees must not be required to work more than 60 hours a week, including overtime, on a regular basis (or more than the limits on regular hours and overtime allowed by local laws and regulations).

6.3. Wages for overtime must be paid in legal tender on a regular basis. Wage deductions as a disciplinary measure must not be permitted unless provided for by national law. Employees must be entitled to at least one day off in seven, and must be given reasonable breaks while working and sufficient rest periods between shifts.

6.4. DEFY must be committed to continuously developing employee skills and capabilities, and to providing opportunities for career advancement.

6.5. In the event of major layoffs, DEFY must, as a minimum, satisfy applicable laws and industry standards.

7. LEAVE

7.1. DEFY must ensure that all employees have the right to sick leave and annual holiday, as well as parental leave for employees who have to care for a new-born or newly adopted child as provided by national legislation. Employees who take such leave must not, as a result, face dismissal or threat of dismissal.

8. EMPLOYEE CONTRACTS/LETTERS

8.1. All employees must be provided with a written, understandable and legally binding employment contract/letter.