Human Rights Policy

“All human beings are born free and equal in dignity and rights. They are endowed with reason and conscience and should act towards one another in a spirit of brotherhood.”

Article 1 of the Universal Declaration of Human Rights, of the United Nations (UN).

Application of Policy

This policy applies to all employees, administrators, shareholders, customers, suppliers and partners as well as other entities or institutions that maintain business relationships with CTA-Continental. Everyone must have knowledge of this policy and be committed to it.

About the Stakeholders

Administrators: any member of CTA-Continental's Board of Directors, Advisory Committees and Executive Board, or individuals holding any other statutory or similar office, in accordance with applicable laws in the jurisdiction that CTA-Continental operates.

Customers: any of CTA-Continental's clients, including their agents.

Collaborators: any of CTA-Continental's employees, seasonal or permanent, interns and/or trainees.

Suppliers: any suppliers of goods, products and/or services to CTA-Continental, including Integrated Producers (farmers).

Partners: any entities (associations, institutions, organizations, etc.) with which CTA-Continental has any type of commercial, technical, social, or institutional partnership, among others, that do not qualify as Customer or Supplier.

Human Rights Policy

CTA-Continental is committed to respecting human rights in all forms and areas of activity, through practices that promote diversity, dignity and equality. We believe that honest, fair and respectful relationships between people are the most basic and essential prerequisite for any business.

We work continuously to prevent and mitigate potential risks and adverse impacts identified in our operations, as well as to remedy any human rights violations to which we may have contributed or caused. CTA-Continental complies with applicable legislation, as well as international treaties and guidelines from global organizations on Human, social and labor rights. We observe the Universal Declaration of Human Rights Principles and references of the International Labor Organization's Declaration on Fundamental Principles and Rights at Work, the United Nations Guiding Principles on Business and Human Rights and, to complement Human Rights, other guidelines that promote Civil, Political, Economic, Social, Cultural, and Labor Rights.

With this Policy, CTA-Continental acknowledges its role as a leading company in the production chain for what it represents to the sustainability of the sector and for pioneering relationships between the company, integrated growers and other value chain links.

It is thus CTA-Continental's desire to continuously contribute to Human Rights promotion in the tobacco and agribusiness value chain, as well to ensure all actions implemented by the company or business partners respect and follow the guidelines contained herein.

CTA-Continental is committed to ethical relationships that encourage the advancement of Human Rights and fair, sustainable, and responsible social / environmental initiatives, through clear Corporate Policies and implementation of transparent, effective Governance mechanisms. Corporate policies and practices are continuously improved and evolve in line with ESG (Environmental, Social, Governance) principles, whose purpose of creating value for society is part of CTA-Continental's way of doing business.

CTA-Continental's actions are based on the following:

Respect for Human Rights

of all individuals involved in the company's value chain;

Implementation of a governance model

that is robust and effective, with defined strategies and actions that guarantee the Human Rights of those involved in the company's value chain;

Promoting a due diligence mechanism

that is continuous and comprehensive, in order to identify and manage potential risks so they can be mitigated or prevented or, still, to remedy any unfavorable impacts that the company may have caused or contributed through its operations, in a participative, transparent manner;

Providing a grievance mechanism

for proper treatment and remediation of reported violations;

Forming strategic partnerships to promote human rights,

to join forces and bring about more positive impacts to the value chain.

Respect for Human Rights

We believe that all individuals must have their Human Rights unconditionally respected and secured. CTA-Continental's commitment, covering the entire value chain, is evidenced through Policies, Codes, Programs, and corporate practices.

The Human Rights Policy was prepared with the participation of subject matter experts. It has been approved by the highest Company management levels, reflecting the Company's commitment to promoting and developing this very important issue. The provisions of this Policy are continuously monitored through a governance model that ensures human rights risk analysis, proposes the definition of strategies and actions for prevention, mitigation or remediation. The effectiveness of these measures is then evaluated.

CTA-Continental's commitments to respect and ensure Human Rights are mirrored on the following principles:

Forced or compulsory labor of any form shall not be tolerated.

CTA-Continental rejects any form of forced or involuntary labor in the value chain, whether on an integrated grower's farm, in an employee's home, in a supplier's company, at the company's headquarters or at its subsidiaries, or anywhere else in the company's value chain. Workers have the right to leave the premises at the end of the working day, documents cannot be withheld and there can be no debt bondage. If workers are provided with housing, it must be safe, clean and comfortable.

Exploitation of any form of child labor shall not be tolerated.

Underage labor in the tobacco industry is considered one of the worst forms of child labor and is therefore unacceptable, as is any hazardous work performed by persons under the age of 18, even if not in the tobacco industry. It is also unacceptable in the industry or among partners and suppliers involved in CTA-Continental's value chain. Brazilian legislation is clear: entry into the labor market is at the age of 16, if the work is not dangerous, or at the age of 14 as an apprentice, which requires a special contract authorized by law.

Promote fair treatment and repudiate any type of discrimination, harassment, threat or prejudice.

Whether by gender, race or ethnic origin, nationality, sexual orientation, religion or difference of opinion.

Respect freedom of association and collective bargaining.

People are free to negotiate their working conditions, wages and benefits in accordance with current legislation. Workers are free to choose representatives to negotiate on their behalf.

Comply with local legislation on income, working hours and benefits.

CTA-Continental abides by collective agreements with unions and offers its employees attractive benefits that extend to their families and go beyond what is required by law.

Promote a safe and healthy working environment,

that balances the personal and professional lives of employees so that they are happy, satisfied and safe within local and international occupational safety standards and requirements.

Value inclusion and promote diversity.

Diversity enriches, and it is these differences that make CTA-Continental the successful company it is today. Promoting and integrating diversity in everyday life is the best way to combat existing social inequalities.

Combat corruption and illicit practices.

Always value the truth, business ethics and transparency in relationships. CTA-Continental does not tolerate illicit practices, bribery, fraud, corruption or facilitation payments of any type.

Promote privacy and personal data security.

Personal data security is paramount. Data must be stored securely and must never be shared improperly or without the owner's consent.

CTA-Continental encourages its administrators, customers, employees, suppliers and partners to respect and continuously disseminate these public commitments in a comprehensive and nonexclusive manner throughout their respective value chains.

Human Rights Governance Model

To ensure full effective and transparent implementation of this Human Rights Policy, CTA-Continental establishes principles across its operations, based on constant promotion, awareness and respect for Human Rights throughout the company's value chain, with strategies and actions continuously monitored through a Governance Model.

This Governance Model aims to guarantee smooth functioning of the initiatives implemented through a set of good corporate practices, such as:

Set of Corporate Policies or Codes

Corporate Policies or Codes outline operational, management and business guidelines in an ethical manner. They communicate CTA-Continental's position to stakeholders on specific issues and must refer to or cite this Human Rights Policy in a complementary and transversal manner, regardless of the area, subject or scope. The key ones are:

CTA-Continental's Commissions

They discuss strategies and encourage specific actions, concentrated on fostering and raising Human Rights awareness.

  • Human Rights Commission: Contributes to guaranteeing the fundamental rights warranted to each and every human being to be treated decently at work, to express opinions and beliefs without fear of reprehension, to have privacy and to be free from harassment, abuse or discrimination. These rights also include the right to a standard of living adequate for health and well-being. There is a specific internal procedure for this Commission which, among other things, addresses the objectives, defines the scope of action, proposes indicators and the participating members.
  • Diversity & Inclusion Commission: Commission that works to develop and disseminate actions for inclusion, respect and Diversity promotion within the company and across the value chain.
  • Internal Accident Prevention Commission: albeit a legal requirement, this commission supports safety and quality of life to CTA-Continental's internal employees, also encouraging them to disseminate and multiply such practices with their family members.

Corporate Programs and Practices

These are initiatives toward CTA-Continental's integrity and sustainability, and which demonstrate, in a practical manner, the corporate commitment to supporting and respecting Human Rights, in issues of great relevance that generate value to society. The main programs are:

  • Diversity Management Program: to respect, promote and value diversity in the workplace, enabling fairer, healthier and more inclusive relationships.
  • CapaCiTAr Program: promotes inclusion of Persons with Disabilities (PWD) at CTA-Continental, to provide them access to productive work activities, in a positive working atmosphere, while raising coworker awareness. This is very beneficial to minimize prejudices, overcome barriers and expand the understanding of PWD's capacity to produce and to socialize, thus supporting the company's social responsibility principle.
  • CulTivAr Program: for training integrated growers on Safety and Health while also increasing and updating their knowledge of new tobacco production technologies.
  • Agricultural Labor Practices Program (ALP): is a communication & continuous monitoring program of our integrated producers' labor practices to encourage working conditions improvements on rural estates. The program is based on the Declaration on Fundamental Principles and Rights at work, as well as other relevant ILO conventions, covering child labor, workers' rights and occupational health and safety. ALP is also a mechanism that contemplates the ongoing steps of due diligence.
  • Sustainable Tobacco Program (STP): is a due diligence mechanism adopted by CTA-Continental as a sustainable platform suggested for the tobacco production chain, concentrating on eight topics related to agriculture: Human and Labor Rights, Water, Crop, Soil Health, Climate Change, Natural Habitat & Livelihood, and Governance (of the Program).
  • Health & Safety Program: Employee health and safety programs and activities that are broad-based and targeted to specific audiences.
  • CTA-Continental Supplier Integrity & Development Program: with a specific approach for this audience, the program covers topics related to Human Rights through training, meetings and other actions.
  • Mary Lebus Vaughan Nursery & Preschool: CTA-Continental's onsite facility that serves employees' children under 6 years of age for a full shift, fully subsidized by the company, promoting children's education, well-being and development while helping to balance employees' personal and professional lives.

Senior Management's Commitment

It is of fundamental importance that Senior Management is committed to the Human Rights Policy and its definitions, strategies, initiatives and all other corporate actions that promote and respect Human Rights, and that the necessary human and financial resources are guaranteed for the effective functioning of this Human Rights Governance model.

It is Senior Management's responsibility to deliberate on changes to the Policy, disseminate and make stakeholders aware of the corporate commitments to respect and endorse Human Rights, as well as to ensure full compliance with this Policy or to prompt the correction of any Human Rights violations.

Control & Support Mechanisms

CTA-Continental requires that its partners comply with labor and Human Rights laws, encourage continuous engagement, and are in harmony with the principles established in this Policy.

Contracts signed between CTA-Continental and suppliers and business partners include mandatory clauses prohibiting child labor, work analogous to slavery, or any other violations established by this Policy. The contracts also require compliance with any public commitment assumed by the company or Global Organization Guidelines, as well as labor, health & safety and environmental legislation, and request for supporting documentation. CTA further requires that this Human Rights Policy be attached as part of the contract with the supplier or business partner.

Furthermore, CTA-Continental:

  • Raises awareness and disseminates the precepts of this Policy to respect and fulfill its social role in promoting Human Rights in the value chain, through events and specific training for suppliers and business partners;
  • Notifies customers, suppliers and partners when the principles of this Policy are violated, requests proof of corrective actions and adopts appropriate sanctions and applicable contractual measures;
  • Encourages suppliers to select business partners that comply with labor and environmental legislation. Suppliers should also adopt fair and inclusive practices that foster human rights;
  • Conducts announced and unannounced audits (in case of investigation of alleged human rights violations) to suppliers and partners, to ensure that their processes are in compliance with CTA-Continental's Human Rights Policy, the law, and global human rights guidelines;
  • Specifically for integrated Growers, ALP program principles and guidelines are communicated and monitored by Field Technicians during their technical assistance visits. Furthermore, such principles are included in contractual clauses that are strictly complied with. In case of non-compliance/violation of these clauses, the producer is formally notified, with official communication sent to the authorities, as per adopted protocols and commitments.

It is important to point out that CTA-Continental strives for mutually beneficial long-term relationships based on trust, transparency, and ethics. Raising awareness and dialogue are top priorities. The goal is to promote Human Rights and never just mere penalties to concerned parties.

Promoting a Due Diligence Mechanism

The United Nations Guiding Principles for Businesses and Human Rights recommend that companies implement ongoing due diligence mechanisms, following the steps to:

1 Assess potential risks and impacts to Human Rights caused by their activities, through identification, development and implementation of controls for prevention and mitigation of potential adverse risks.

2 Consolidate impact assessment results coming from the perspective of impacted stakeholders into the Company's processes. This includes Programs, reviews of policies and norms, procedures, and budget, among others.

3 Continuously monitor the process to ensure the effectiveness of CTA-Continental's actions toward its suppliers and value chain. Indicators must be clear and specific.

4 Report, in a transparent manner, risk management performance and any impacts to which the company contributes or causes, as well as Human Rights remedial actions promoted by the company. At this stage, sustainability reports or specific Human Rights reports must be prepared. An accreditation report is desirable and recommended.

Providing Grievance Mechanisms

Whenever deviations, violations or adverse impacts to the Human Rights Policy are identified, CTA-Continental takes actions involving its value chain stakeholders, in preparation for, and implementation of, remedial actions.

All matters directed through CTA's Grievance office are treated with the utmost confidentiality. The individual who reported the concern should not fear retaliation.

Contact information for complaint channels are widely disclosed to all concerned parties. There are various means and channels, both internal and external. Other official government reporting channels are also divulged by CTA-Continental to its employees, suppliers and partners.

CTA-Continental also encourages its business partners to make Complaint Channel contact information readily available to all concerned parties, to encourage its use in the event of human rights violations. Cases of violations must be treated with strict confidentiality and respect, and negative impacts must be corrected.

Forming Strategic Partnerships to Promote Human Rights

  • Mutli-stakeholder platforms: CTA-Continental believes in the potential of joint efforts to multiply actions and enhance positive impacts. The company's protagonist participation in Programs and Platforms occurs through active working group discussions. Support for specific initiatives and adopted commitments are aimed at respecting and promoting Human Rights through evolution and continuous learning. Best practices and corporate references (benchmarking) are guided by dialogue. Some examples are:
    • Crescer Legal (“Growing Up Nice”) Institute: an initiative of the Interstate Tobacco Industry Union (SindiTabaco) and its associated companies. Crescer Legal was formed under the support and devotion of individuals and entities involved in education and fighting child labor, especially in tobacco growing areas in the southern region of the country. This initiative provides opportunities for generating income and developing skills and potentials, respecting gender differences, so that boys and girls can have access to learning and professionalization alternatives for young people, therefore helping to combat adolescent labor.
    • Ser Mais Feliz na Escola (Be Happier in School): Program implemented by CTA-Continental in partnership with a public school, which aims to contribute to child labor prevention and minimize classroom evasion in tobacco growing regions via extracurricular educational activities.

General Provisions

This policy is disclosed on the company's internal channels and website, for open access. It is reviewed annually and/or whenever there are legal updates or requirements arising from the assessment, monitoring and remediation channels. Changes must be approved by the company's Senior Management.

Violations of this policy are subject to penalties outlined in the company's Code of Conduct.