Human rights

“Protect, Respect and Remedy” are the three pillars of Harvard Professor John Ruggie’s framework which was approved by the UN Human Rights Council and adopted in the UN Guiding Principles on Business and Human Rights (UNGPs) in 2011.

Roche fully supports and implements the UNGPs, and is equally committed to supporting the following:

• The UN Sustainable Development Goals (SDGs)

• The 10 UN Global Compact Principles

• The Universal Declaration of Human Rights

• The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work

This commitment is embodied in our, the, theand in ourand

To fulfill its corporate social responsibility, Roche is committed to delivering continuous improvement and maintaining best practice at a policy and process level, as well as in its management approaches.

Roche fosters human rights globally, both in our own operations and across our value chain. We are evolving our holistic approach in the value chain towards a proactive approach in improving human rights by committing to doing no harm and making an impactful positive contribution to society.

By applying the principle of ‘knowing and showing’, Roche is committed to avoiding adverse impacts on Human Rights by focusing on the perspective of the rights holder.

We have a risk management approach designed to systematically identify, assess, mitigate and adequately manage the risk of human rights violations, including the assessment of whether there are reasonable grounds to suspect child labour. The Group human rights risk assessment covers our own operations and third-party operations. Its purpose is to identify and assess the potential negative human rights impacts of our activities and business relationships with a focus on own operations and the upstream supply chain.

The following focus areas based on impact were identified in our own operations:

We embed Human Rights in our existing operations and daily business by multiple means:

All Roche departments and functions contribute to respecting and protecting Human Rights. For example, every site has a Human Resource contact supporting compliance with related principles such as discrimination and harassment, as outlined in the

Roche holds its suppliers to high performance expectations concerning human rights that are aligned with our own values and principles. These are detailed in the Roche Supplier Code of Conduct that is referenced in every Roche contract. In order to enhance transparency within our sphere of influence, we also expect suppliers and business partners to actively assess and manage Human Rights risks in their own business partners.

Our human rights commitment for business partners is based on the Pharmaceutical Supply Chain Initiative (PSCI) Principles, which we are committed to. The Principles are referenced in all Roche contracts and embedded in the provisions of the Roche Supplier Code of Conduct, which all our suppliers commit to.

We conduct risk-based due diligence on potential and existing suppliers and business partners. Human Rights aspects are an integral part of the due diligence undertaken at the Group and Affiliate level, this includes by way of example:

1.& Checklists

Thesets forth the framework and principles to ensure the protection of human rights across the Roche value chain.& Checklists on the Roche due diligence process, including instruction on how to develop and implement appropriate due diligence for local markets. Region specific toolkits are provided.

2. IT Tools

IT Tools support a consistent end-to-end process which allows for recurring and systematic due diligence activities and risk assessments.

3. Robust third party risk management

As part of Group human rights risk assessment the following focus areas based on impact were identified in our supply chain.

* Pharmaceutical Supply Chain Initiative (PSCI:go.roche.com/pscinitiative)

Roche has a formal process and methodology for assessing our suppliers to identify those at higher risk for Human Rights violations due to:

• Being associated with an industry that is likely to employ vulnerable populations

• Being located in a region at higher risk for Human Rights violations, per respected Human Rights indices

• Being associated with government, media or internal reports of alleged behavior or operations that indicate real or potential noncompliance with the Roche Supplier Code of Conduct

Roche selects its counterparties for acquisitions and divestments carefully from a general compliance and reputational perspective which includes but is not limited to Human Rights. Roche applies industry standard due diligence questionnaires to address health, safety & environment and employment related questions among a wide array of further matters which may relate to Human Rights. Depending on the counterparties, further risk based due diligence actions may be undertaken to ensure that issues such as human right violations, are detected and addressed.

Inputs to our automated human rights risk assessment methodology that allows for traceability in the supply chain include an external perspective with risk assessment depending on four main externally available and recognised indexes: KidsRights Index, Global Slavery Index, OECD Index and Global Rights Index, using the following data:

• Nature of product or service procurement category code identifying the supplier’s exact industry and the nature of its product or service – to assess associated human rights risk. We are looking for activities typically associated with vulnerable populations such as children, underage workers, migrants, local underprivileged communities and people with low levels of education.

• Exact location of the business partner’s operations to assess if that area or region is associated with higher levels of human rights violations (i.e. limited regulation or enforcement).

• History or new information on potential risk data input on external reports or concerns raised about a particular business partner, region or industry

Business partners identified as being at higher risk for human rights violations are included in a list of business partner auditable entities. These are scheduled for PSCI-based audits as part of our SSAV programme.

Roche selects its counterparties for acquisitions and divestments carefully from a general compliance and reputational perspective which includes but is not limited to Human Rights. Roche applies industry standard due diligence questionnaires to address health, safety & environment and employment related questions among a wide array of further matters which may relate to Human Rights. Depending on the counterparties, further risk based due diligence actions may be undertaken to ensure that issues such as human right violations, are detected and addressed.

4. Grievance mechanism

Employees as well as business partners are encouraged to speak up in good faith if they believe that a human rights violation has occurred. This also covers any reasonable concerns about the existence of a potential or actual adverse impact related to child labour.

Theare available for everyone internally and externally to report compliance concerns. Our local and regional Compliance Officers also serve as contacts for allegations, which are then reported to thevia the Business Ethics Incident Management System (). Human rights violations, especially by our suppliers, can also be identified by the Procurement department.

All allegations are taken seriously and are objectively investigated. If the allegation is substantiated, we take appropriate remedial measures.

In 2024, 20 substantiated incidents related to human rights violations triggered terminations of contracts. All the incidents were related to discrimination and harassment, 18 involving Roche employees and 2 a contractor.None of the incidents involved a business partner.

In addition, we assess supplier compliance with our Human Rights standards through our Supplier Sustainability Assurance Visit (SSAV) audit program. In 2024:

• We conducted 118 sustainability audits (SSAVs) at supplier sites (41 in EMEA, 62 in APAC, 6 in North America and 9 in LATAM). 

• We had 284 Human Rights related observations for issues such as excessive overtime and incorrect overtime compensation (16%), improper maintenance of HR and payroll documentation (12%), delayed, improper payment and calculation of wages (8%). 

• Each of the suppliers were findings were identified, was required to establish and make progress on a formal corrective action plan.

• Each of the 69 suppliers were required to establish and make progress on a formal corrective action plan.