Human Rights Policy

BRIGHT Products Human Rights Policy

1. Purpose

At BRIGHT Products AS, we understand our responsibility to respect internationally recognized human rights. BRIGHT aims not only to be a sustainability leader in the solar energy field, but to also set an example in our human rights practices. This policy outlines BRIGHT’s commitment to human rights, our key human rights priority areas, our expectations for business partners and other key stakeholders, and how we will implement our commitments.

This Policy complements BRIGHT’s Code of Conduct. BRIGHT’s commitment to human rights is not static, and we are dedicated to adapting this policy to meet evolving needs as they are identified – we are in a continuous improving journey.

2. Our Human Rights Commitment

BRIGHT is committed to respect internationally recognized human rights standards in alignment with the International Bill of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the United Nations Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises. BRIGHT is also an active member of the United Nations Global Compact.

BRIGHT is committed to complying with all applicable laws, rules, and regulations in the countries where we operate. Where we might face conflicts between internationally recognised human rights and national laws, BRIGHT will seek to respect the principles of international human rights.

In line with international standards and the Norwegian Transparency Act (Åpenhetsloven), BRIGHT will implement human rights due diligence in order to identify, prevent, mitigate and account for how we address our human rights impacts. We recognize that human rights risks in our activities and supply chain can change over time and that our commitment and this process should be ongoing.

BRIGHT is committed to the humanitarian principle of “doing no harm” and the 2030 Agenda goal of “Leaving No One Behind.” As such, BRIGHT will seek to support human rights there where can make a positive impact.

3. BRIGHT’S Human Rights Priority Areas

BRIGHT will pay particular focus to those areas more critically affected by our activities, where human rights risks might be more salient. We acknowledge that these areas might change over time, and we will conduct regularly human rights assessments to update our priority areas. BRIGHT’s current key priority human rights areas include:

A) Labour Rights in our Supply Chain

We oppose all forms of slavery, human trafficking, forced labour and illicit forms of child labour in our operations and value chain. BRIGHT recognizes and respects the right to freedom of association and the right to collective bargaining. BRIGHT is committed to ensure that the rights of the employees engaged in our supply chain work in safe and fair conditions, and opposes all forms of discrimination, harsh or degrading treatment or harassment.

B) Employee Rights

All employees of BRIGHT shall be treated with dignity and respect. Discrimination on the basis of race, colour, religion, creed, sex, age, social status, family origin, physical or mental disability or sexual orientation will not be tolerated. We are committed to a work environment free of all forms of harassment.

C) Community Impact

We are committed to respecting the rights of the communities in which we operate. As a usercentric company, we seek to maximize the positive impact of our products for the end user. It is of vital importance for us to also understand how our activities might negatively impact the communities in which we operate, and we strive to maintain an open and transparent channel of dialogue with local stakeholders and community representatives to better understand and understand these impacts.

4. BRIGHT’S Expectations

All BRIGHT employees, Board of Directors, suppliers, business partners and other parties linked to the company’s operations, products or services are expected to comply with this Policy. We aim to establish business relationships with business partners that share the same principles and commitment to internationally recognized human rights. BRIGHT expects its business partners and others whose impacts might be directly linked to our operations to respect and not infringe upon human rights.

5. Implementation

It is the responsibility of the members of the Board of Directors to reflect the human rights commitments of this Policy into the company’s strategy and ensuring that any breaches are investigated. Upper management has the responsibility to reflect this Policy in the operational procedures and systems.

BRIGHT will seek to identify and any actual or potential risks to human rights related to our activities or those of our business partners. In the event adverse impacts are identified, BRIGHT will seek to respond and remediate said impacts, and track the implementation of corrective measures in the event these were necessary. We will communicate how human rights impacts are addressed and collaborate with relevant stakeholders throughout this process. We are committed to report on our human right’s due diligence progress yearly in accordance with Norway’s Transparency Act (Åpenhetsloven).

6. Communication and Transparency

If any employee believes that someone is violating this human rights policy or the law, they are asked to report it immediately to their manager. If this option was not available, the employee shall report to CEO or chairman of the board.

Any affected individual or stakeholder can raise concerns about how they are or might be negatively impacted by our activities through our website.

BRIGHT will not tolerate any breaches of this Policy or laws and regulations involving human rights.

Potential misconduct shall be investigated. Any such violations might result in disciplinary actions, up to and including termination of employment or business relationship, reporting to relevant authorities, and/or any other suitable actions.

7. Review and Continual Improvement

This Human Rights Policy will be reviewed periodically to ensure its relevance and alignment with our organization’s goals, legislation and human rights priority areas.

8. Contact information

This Policy will be publicly available and accessible at BRIGHT Products website. The published electronic version will always represent the most recent edition.

Questions regarding this Policy can be directed to: lorena@bright-products.com.

9. Approval and review

This Human Rights Policy was approved by Vidar Eskelund, CEO on 21.01.24