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Respect for human rights 

The principles of METRO include respect of all human rights, as set out in the United Nations’ Universal Declaration of Human Rights, the International Bill of Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and the Declaration on Fundamental Principles and Rights at Work of the International Labour Organization (ILO). This is manifested in our Declaration of Values on Human Rights and Environmental Concerns, which applies to our own employees and to our business partners within our supply chain. An attitude with similar values is also important to us on the part of our business partners. Our goal is to identify and prevent violations of human rights in our own business operations and in our supply chain. We also strive to systematically improve working conditions in our supply chain. In the reporting period, we implemented, in accordance with our management approach with regard to respecting human rights, the requirements of the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG), which entered into force in Germany in January 2023, for the METRO companies that are directly affected by the LkSG. As a result, METRO AG, METRO Deutschland GmbH and METRO Logistik GmbH each published its human rights strategy in the form of a policy statement for compliance with human rights and protection of the environment and appointed designated human rights officers. METRO AG has created matching responsibility structures in the national subsidiaries and trained the local human rights ambassadors. In addition, METRO AG issued a group guideline as an operational instruction for implementing the Declaration of Values on Human Rights and Environmental Concerns and rolled out an e-training course on the protection of human rights and environmental aspects, which is mandatory for all employees worldwide. METRO Deutschland had already revised the content of its code of conduct in the previous reporting period and made it a part of the contractual relationship with relevant suppliers. Furthermore, all framework agreements for own-brand and brand suppliers and the international standard logistics contracts contain a clause on the social standards. As a responsible company, we have implemented corresponding processes and measures that help us to enforce our requirements accordingly. In the reporting period, the companies subject to the requirements of the LkSG introduced an IT-based social compliance risk management system for supplier relationships with a differentiated risk analysis. Here, we determine, weight and prioritise the risks to human rights and environmental protection on a regular and case-by-case basis. For relevant contracting parties, abstract and, where necessary, specific risk factors are used to classify and prioritise the risks in correlation with our options to exert influence. In relation to our own business operations, a risk analysis was carried out by interviewing the human rights ambassadors appointed for the respective group companies using a defined set of questions, as well as by analysing reports from our whistle-blower system and on the basis of our own research conducted by the human rights officers. In turn, the operational and strategic human rights officer classify and prioritise the risk factors on the basis of the criteria of ability to influence, seriousness, probability and reversibility of a potential violation as well as on the basis of the nature of our contribution to the cause. METRO AG’s function as a group holding and management entity results in a specific structure of contracting parties, the vast majority of which are traditional service providers such as business consultancies, law firms or similar that have their registered office in Germany rather than traditional goods suppliers. No fundamental risks relevant to human rights and environmental matters were identified for these specific contracting partners and for the company’s own business operations in the reporting period. Regular analyses are nevertheless conducted to verify whether this investigation is up to date in order to exclude potential risks or to identify and address them accordingly on an ongoing basis.

In case of violations of our basic human rights principles, our employees can contact their supervisors or the company’s compliance officers. Using a tool that is publicly accessible via the METRO compliance page, internal and external individuals, including stakeholders of our suppliers, can report incidents and violations. It is important for us that our suppliers also are familiar with the METRO complaint mechanism and provide information about it along the rest of the supply chain. Corresponding measures to ensure that this is also implemented by our suppliers have not been established. Reported incidents affecting our company will be promptly investigated and processed by our experts to take appropriate action, if necessary. We are also committed to working with our suppliers and within the group to remedy the effects of the grievances, utilising joint initiatives and collaborating with stakeholders, and not obstructing access to other legal remedies. To this end, we are working with a catalogue of preventive measures and remedies aligned with the requirements of the LkSG. Depending on the particular case, it is posted and tracked during risk classification of a supplier or, at the latest, when a confirmed incident is reported. As part of the effectiveness analysis of our risk management system, including measures and complaints procedures, we were able to determine the effectiveness of the measures used and of our business processes. Particular tools used to further this process were the way our organisation is structured, contract adjustments, the use of supplier questionnaires, bilateral supplier dialogues for a more detailed risk analysis, e-training for employees and relevant suppliers, requests for audit documents and investigative interviews on existing complaints, including with third parties.

Global labour and social standards in the supply chain

In order to contribute to ensuring socially acceptable working conditions within our procurement channels and to prevent potential infringements, the application of social-standard systems in our own-brand supply chain is a key part of the purchasing process. We pursue the approach of requiring own-brand producers to be audited by a third party, for example in accordance with the supply chain management set out by the amfori BSCI, the Sedex audit according to SMETA or equivalent social-standard systems. These audits may be initiated by us, or we access audits initiated by other companies that are released to us for our evaluation. This applies to all producers of certain typically human-rights-critical food categories and industries, and to all producers in defined risk countries (based on the amfori BSCI assessment) in which METRO SOURCING International Ltd. Hongkong (MSI) have imported goods manufactured. It also applies to all above-referenced risky producers who manufacture own brands or own imports for METRO. This risk assessment did not have to be adjusted in connection with the Russian war in Ukraine, as it is universally applicable. Under normal circumstances, we have audits regularly carried out on-site by external auditors in accordance with the audit cycles of the social standards accepted by METRO. For many years now, we have been working on the basis of a corresponding process for our non-food producers1. We are gradually establishing this process analogously for all food and near-food producers in the own-brand sector. To date, the process has been implemented entirely via MSI’s food and near-food producers and the national subsidiaries METRO Deutschland and METRO France. The national subsidiaries METRO Turkey, MAKRO Spain and METRO Pakistan are continuously expanding their producer portfolios in the food and near-food process. Other purchasing companies and national subsidiaries are preparing for implementation. Our goal is to include our entire own-brand supply chain in this process by 2030, insofar as it is considered risky in terms of potential human rights violations. The national subsidiaries are trained and gradually integrated into the programme. During the reporting period, 12 national subsidiaries refreshed their proficiency of the programme and/or trained new colleagues via online training sessions.

The war in Ukraine has an impact on our supply chain. Taking the experience gained from testing the resilience of the supply chain into account, we particularly consider responsible procurement practices as the key to strengthening business relationships, ensuring business continuity and protecting human rights in global value chains.

As of 30 September 2024, 412 of 466 reported active risky own-brand non-food producers2 and 117 of 191 corresponding food/near-food producers3 had undergone the audit process4. Within this group, 100% (412) of non-food producers and 100% (117) of food/near-food producers have passed the audit successfully. Effective 1 January 2019, non-food producers who fail the audit can only be commissioned as METRO contracting parties if they achieve an acceptable audit result. In other words, they have to receive an A, B or C for the amfori BSCI assessment or successfully pass an audit that is acknowledged as equivalent. In exceptional cases, D audits may also be permitted, if it can be demonstrated that the items that led to the D result have been remedied, but no new audit has as yet been conducted. In addition, a D audit may be permitted by way of exception, if according to the audit provider’s calculation system an individual result in a non-critical performance area leads to an overall result of D, although the individual assessment reveals only minor shortcomings and the overall assessment of the performance is therefore acceptable. Until further notice, all food/near-food suppliers with amfori BSCI D (and in exceptional cases also E) audit results (and corresponding equivalents of other standards recognised by METRO) also qualify to be commissioned by METRO.

The verification of compliance with our requirements is performed via an internal IT-based process management database, which provides an overview of the portfolio management of the affected suppliers and the associated producers. The database is also used to monitor compliance with contractual agreements during the initiation and suspension of business relationships. Misconduct with regard to the so-called deal-breakers specified by METRO in the course of ongoing business relations will trigger suspension of the supplier. Deal-breakers include serious findings in the areas of child labour, forced labour, occupational safety hazards with regard to fire safety and ethical behaviour. If misconduct is discovered at suppliers and their producers concerning one of these areas, they are required by METRO to develop short-term and long-term solutions to remedy the deal-breaker issue. New orders or follow-up orders are suspended until the findings in the deal-breaker process have been resolved.

In order to contribute to the improvement of the social requirements in the production facilities of our own brands and thus to further increase the proportion of valid social audits, MSI, MFS and METRO Turkey work together with our local producers and support them with training courses that serve to teach understanding and compliance with the social standards. By training our own-brand suppliers on the implementation of fair labour conditions, we sensitise them to comply with conditions and to avoid violations.

Act on Corporate Due Diligence Obligations in Supply Chains
The law, which entered into force on 1 January 2023 in Germany, sets out clear due diligence requirements for companies based in Germany to comply with basic human rights and environmental standards (for example prohibition of child and forced labour).
Glossary
Food, non-food
Under the global term food, METRO summarises the following categories of goods: fresh foods, durable foods, nutrients, frozen foods and drinks of all kinds, as well as luxury foods, dietary supplements and pet food, but also detergents, cleansers and cleaning agents, which are sometimes also labelled as near-food. All other goods are considered non-food items.
Glossary
Own brands
Brand products with an attractive price/performance ratio developed by a retail company and protected by trademark law.
The own brand sales share is one of the core key figures that METRO uses to measure and verify the implementation status of the sCore strategy. It shows the share of own brand sales in total sales (based on the merchandise management system) excluding the segment Others.
Glossary
Sedex audit according to SMETA
Sedex, a data platform for transparency in the sustainability commitment of companies, provides SMETA (Sedex Members Ethical Trade Audit), one of the world’s most frequently used concepts for social audits. The audit is focused on working conditions, occupational safety, environmental management and business ethics as well as respect for human rights and temporary employment.
Glossary
Social compliance
The adherence to laws, guidelines, standards, codes and/or social conventions by which an organisation ensures socially responsible operations within its value and supply chains. The aim is to ensure the safety and health of employees and to protect their basic human and labour rights in their own company as well as among its suppliers.
Glossary
amfori Business Social Compliance Initiative (amfori BSCI)
A global business association founded in 2003 for open and sustainable trade whose aim is to ensure that production in all supplier countries complies with minimum social standards, including through verification by means of social audits. The association aligns its standards with the UN’s Universal Declaration of Human Rights and the conventions of the International Labour Organization (ILO).
Glossary

1 This includes producers of commercial goods (non-food own-brand products and own non-food imports) in high-risk countries that carry out the final value-creating production step, for example produce the final item of clothing.

2 High-risk non-food producers are assessed using the following criteria, among others: inherent risk (producers located in a high-risk country under amfori BSCI) as well as fact-based risk (critical incidents).

3 High-risk near-food producers are assessed using the following criteria, among others: inherent risk (producers located in a high-risk country under amfori BSCI) as well as fact-based risk (critical incidents). High-risk food producers are assessed using the following criteria, among others: I. inherent risk: a) producers located in a high-risk country, b) producers that make products from certain high-risk categories of goods and/or sectors/industries, regardless of the risk status of the production country or c) governance and organisational structures: staff made up primarily of women or migrant workers or seasonal/temporary workers, or workers without fixed or regular contracts or II. fact-based risk (critical incidents).

4 For the key figures in the chapter on social matters, there may be variances from the consolidation group in financial reporting for reasons such as data availability.

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