Statement of the Human Rights policy

The scope of human rights for Spuerkeess includes non-discrimination, transparency, respect for privacy, fair working conditions, diversity and inclusion, and responsible investment. By respecting these principles, we hope to contribute to the respectful and inclusive development of the local economy, while protecting the rights of our staff and counterparties (business relations, investors, business partners). This scope applies to all of our activities, operations, products and services.

The limits mainly consist of:

• risk management requirements or other legal and/or regulatory requirements;
• due to the depth and complexity of the value chain of certain companies as well as;
• the maturity of certain SMEs in terms of sustainable development.

Depending on the means and access to the information of its clients and service providers, the Bank will carry out a due diligence exercise of the human rights situation. With regard to service providers, subcontractors and external staff, the commitments are limited to a contractual obligation accepted by the latter and the controls and verifications of the Bank are limited to due diligence.

CSRD requires organizations to be more transparent regarding their sustainable development policies. Spuerkeess complies with this requirement by developing its sustainability report according to the Global Reporting Initiative (GRI) reporting standards, revised in 2021 to align with European regulations such as the CSRD. These reports include information on responsible business conduct and due diligence policies, and demonstrate their implementation across the organization by monitoring and controlling the progress made on the commitments undertaken. In addition, Spuerkeess voluntarily undertakes to apply the principles established by the United Nations Global Compact, in particular Principles 1 and 2, which promote respect for and protection of human rights internationally and prohibit complicity in violations of these rights.

Spuerkeess has chosen a federated approach to its human rights governance. Thus, standards and guidelines are defined centrally and implemented locally, within the departments and branches of Spuerkeess. The ultimate responsibility for Spuerkeess’ commitment to its human rights policy lies within the Executive Committee and under the control of the Board of Directors. The responsibility for implementing the policy lies within the operational and functional departments of Spuerkeess’ value chain.

At Spuerkeess, we are committed to:

• Integrating human rights throughout our value chain by raising awareness among our suppliers and their subcontractors to comply with human rights regulations;
• Ensuring that our banking activities and operations, products and services or employment opportunities are never discriminatory based on race, colour, religion, sex, political opinion, national or social origin, birth or any other status such as disability, age, marital and family status, sexual orientation and gender identity;
• Remaining transparent about our social and environmental impacts;
• Guaranteeing the transparency of our products and services, in particular by providing clear and understandable conditions;
• Implementing ethical practices and sustainable operations throughout our business activities, investments and value chain;
• Paying particular attention to respect the privacy and protection of the personal data of our stakeholders
• Ensuring fair working conditions for our staff - Raising awareness and educating our staff on the potential impact of our investments and lending activities on human rights and training them in the identification and mitigation of negative impacts;
• Striving for diversity and inclusion within the Bank, activities and operations and integrating these concepts into any product and service development
• Avoiding any risk of involvement by our partners or our products in companies, business relationships or products suspected of using forced child and adult labour;
• Promoting an inclusive working environment that values the diversity of its staff, where equal opportunities allow everyone to develop their individual potential on a daily basis, above and beyond the equal treatment linked to the Bank’s public law status.

The human rights policy, and thus the resulting statement, are reviewed at least annually or when required by relevant practices and/or regulatory aspects.