Human Rights

Dear reader,

As a cargo carrier serving a vast international network, it is our responsibility to ensure our operations respect Human Rights and create value for society. Air cargo is a central component of the global supply chain and air freight operators are in the middle of a vast and complex logistics industry.

As a responsible corporate citizen, Cargolux has established a comprehensive compliance program encompassing Human Rights. The extensive Know Your Customer (KYC) process, for example, enables the airline to assess its customers’ engagements and ensure they are aligned with our company values, including Human Rights. We take our responsibility to conduct ethical and fair business seriously, and support others within the supply chain to follow suit.

The KYC process is supported by stringent Compliance monitoring to ensure that all shipments and transshipments are not in breach of any regulations including sanctioned items and countries, and that all required documentation for shipments has been received and vetted. In addition to applicable regulations, we also apply our own self-imposed restrictions on what we carry on board our aircraft. Any deviation is investigated and, when required, entities are verified from shipper to consignee to cover the full scope of the transport. Cargolux refuses any transport of weapons and dual-use goods linked to entities suspected of maltreatment of individuals or governments notorious for breaching Human Rights. This engagement is complemented by a growing list of embargoed goods and countries which is continually reviewed and updated.

From an employer perspective, Cargolux is intent on ensuring fair and ethical treatment for all employees. We have a solid Occupational Health & Safety (OHS) program in place that ensure the workplace is safe and risks of incidents and accidents are kept to a minimum. Most of our employees are covered by a Collective Work Agreement that goes beyond labor law in its guarantees towards personnel. We also regularly conduct employee satisfaction surveys throughout the network to identify areas of improvement for our team members. A company-wide Human Rights program is also under development to enhance our commitment.

Human Rights is a complex issue that is difficult to assess and monitor but Cargolux is committed to play its part in ensuring these fundamental rights are respected. Our industry may have a long way to go but we are increasingly taking steps in the right direction and raising awareness of this crucial topic.

Richard Forson,

President & CEO

PART A: Governance of Respect for Human Rights:

A1: What does the company say publicly about its commitment to respect human rights?

A1.1 How has the public commitment been developed?

Cargolux formalized its commitment to Human Rights in a declarative policy in 2021. The commitment aims to improve the visibility of this important topic within the company and to stress the importance of Human Rights for Cargolux.

The commitment was backed by the signing of Luxembourg’s pact for Business and Human Rights in 2022.

Cargolux has been a signatory of the UN Global Compact since 2008.

A1.2 Whose human rights does the public commitment address?

The company is committed to respect Human Rights as a whole, but it has defined two main areas of focus and action. On one hand, human rights related to employees, such as health & safety, ensuring diversity and equality while fighting all forms of discrimination and harassment. On the other hand, managing the impact that the company’s operations may have on global communities.

A dedicated framework for Human Rights is under development to include all company activities.

 A1.3 How is the public commitment disseminated?

Cargolux has included its commitment to human rights in its annual CSR report since 2021 and communicated the signature of the national pact for Business and Human Rights on social media. It will also be included in the Sustainability Report 2022 which is publicly available on the corporate website. A dedicated regularly updated web page detailing our commitment is also available on our website.

 A2: How does the company demonstrate the importance it attaches to the implementation of its human rights commitment?

A2.1 How is day-to-day responsibility for human rights performance organized within the company, and why?

In 2022, Cargolux introduced a Supplier Sustainability Charter, which outlines the fundamental principles that should govern Cargolux’s activities and its partners’ operations. All Cargolux suppliers will be requested to abide by this charter. The first group of suppliers have been contacted and asked to sign the commitment.

Human Rights are an important aspect of our compliance activities. In 2021, Cargolux introduced a KYC (Know Your Customer) / KYS (Know Your Supplier) policy, by which a due diligence is conducted on business partners.

As part of its export controls, Cargolux rejects shipments related to entities known for Human Rights violations or child labor. The airline also rejects shipments that contain military or repression material which are addressed to governments notorious for Human Rights violations or countries subject to internal conflict.

As regards Human Resources and employee welfare, the employees’ Collective Work Agreement covers a number of human rights particularly relevant to the workplace. In 2022, the airline rolled out a campaign for anti-harassment and discrimination.

A2.2 What kinds of human rights issues are discussed by senior management and by the Board, and why?

In case of severe findings, the report is addressed to Executive management.

A2.3 How are employees and contract workers made aware of the ways in which respect for human rights should inform their decisions and actions?

Employees undergo regular trainings that include Human Rights topics. The Human Rights Commitment document is accessible for all employees on the Intranet. Furthermore, it is referred to in the induction training for all new employees.

A2.4 How does the company make clear in its business relationships the importance it places on respect for human rights?

See A2.1

A2.5 What lessons has the company learned during the reporting period about achieving respect for human rights, and what has changed as a result?

The main lesson learned in the frame of these activities is that Cargolux takes responsibility when it comes to Human Rights. The airline strives to play its part both to ensure its activities fully respect Human Rights and to raise awareness and encourage its partners to do the same. With the implementation of the KYC process and the Supplier Sustainability Charter, Cargolux is taking considerable steps to establish itself as a benchmark for integrity in the industry.

PART B: Defining the focus of reporting

B1: Statement of salient issues: State the salient human rights issues associated with the company’s activities and business relationships during the reporting period.

Cargolux commitment to respect Human Rights lists the following topics:

• Diversity and prohibition of discrimination
• Anti- harassment and anti-bullying environment
• Fight against forced and child labor
• Freedom of association and collective bargaining
• Health & Safety
• Mutual respect
• Child labor, modern slavery
• Torture or to cruel, inhuman or degrading treatment or punishment
• Data protection: No one shall be subjected to arbitrary interference with his/her privacy, family, home or correspondence, nor to attacks upon his honor and reputation.

B2: Determination of salient issues: Describe how the salient human rights issues were determined, including any input from stakeholders.

The list of salient issues has been determined by the company over many years and is included in different documents, such as the Collective Work Agreement and company policies. In 2021, the airline published its Human Rights commitment.

Since 2017, the airline runs stakeholder surveys that enable to determine priority SDGs related to human rights, such as SDG 3, SDG 4, SDG 5, and SDG 10.

B3: Choice of focal geographies: If reporting on the salient human rights issues focuses on particular geographies, explain how that choice was made.

This will be part of the Human Rights framework that is under development.

B4: Additional severe impacts: Identify any severe impacts on human rights that occurred or were still being addressed during the reporting period, but which fall outside of the salient human rights issues, and explain how they have been addressed.

Nothing to report.