Human rights

Roche respects and proactively supports 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 our.

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.

For more than 125 years, both in our own operations and our value chain, Roche has in many ways fostered Human Rights globally. Within our sphere of influence, we proactively focus on improving global Human Rights by committing to doing no harm and making an impactful contribution.

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 implemented a risk management program designed to systematically identify, assess, mitigate and adequately manage the risk of Human Rights violations. The four identified top risks are:

Roche also expects of its suppliers and other business partners to comply with all laws and regulations relating to the above mentioned risks.

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.

We conduct risk-based due diligence on potential and existing suppliers and business partners. We hold our suppliers to high performance expectations 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.

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

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

3.

embedding risk identification, monitoring and management processes throughout the supplier lifecycle.

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.

Employees as well as business partners are encouraged to speak up if they believe in good faith that a human right violation has occurred.

The is available for everyone who is not a Roche employee or contractor.

Our local and regional Compliance Officers serve as contacts for allegations too, which are then reported via theSystem (BEIMS) to the. Human Rights violations, especially of 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 2021, there were 4 substantiated incidents related to Human Rights, all related to Discrimination and Harassment. All of those triggered a termination.

In addition, we assess supplier compliance with our Human Rights standards through remote and onsite audits, our Supplier Sustainability Assurance Visit (SAV) program. In 2021:

• We conducted 26 SSAVs at supplier sites (7 in Europe, 14 in APAC, 1 in North America and 4 in LATAM).

• We had 52 Human Rights related observations for issues such as excessive overtime, incorrect overtime compensation, delayed payment of wages, and inadequate maintenance of employee time records.

• Each of the 26 suppliers were required to establish and make progress on a formal corrective action plan (find an example).