Human Rights Policy

INTRODUCTION

Netdata, in fulfillment of its corporate social responsibility and in accordance with the highest international standards, adopts this Corporate Policy as an integral part of its governance system. This regulatory instrument reflects the company's commitment to respecting, promoting, and protecting human rights in the development of its business activities, in accordance with what is established in International Human Rights Law, the United Nations Guiding Principles on Business and Human Rights, and applicable legal regulations.

OBJECTIVE

To guarantee and promote the protection of human rights, the prevention of gender-based violence, sexual violence, victim support, and inclusion where individual differences are recognized and celebrated. This includes, but is not limited to, race, ethnicity, gender, sexual orientation, gender identity, religion, disability, age, and socioeconomic background.

SCOPE

This policy is applicable to all stakeholders related to Netdata, including employees, remote workers, suppliers, strategic partners, clients, communities, authorities, investors, and civil society organizations. Netdata will promote the respect, protection, and promotion of human rights in all its commercial and social interactions, without distinction of geographical location.

This policy establishes the guidelines associated with:

Human rights
Prevention of gender-based violence in the workplace
Prevention of sexual violence and victim support
Diversity, equity, inclusion, and belonging (DEIB)

HUMAN RIGHTS

Netdata is committed to the respect, protection, and promotion of human rights as a fundamental pillar of its business management and all its operational and commercial activities. This commitment is materialized through the adoption of this Policy, which is based on the Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social and Cultural Rights (ICESCR) and other human rights treaties, the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, ILO conventions, the United Nations Guiding Principles on Business and Human Rights, and the OECD Guidelines for Responsible Business Conduct.

In coherence with this normative and ethical framework, Netdata reaffirms its commitment to the respect and promotion of fundamental human rights, including the prohibition of any form of forced labor, child labor, and discrimination in all its operations and commercial relationships. This policy establishes the principles and commitments that guide our actions to guarantee fair, dignified, inclusive, and human rights-respecting working conditions.

Our principles:

Prohibition of forced labor: We do not tolerate any form of forced or compulsory labor, defined by the ILO as any work or service exacted under the threat of any penalty and for which the person has not offered himself or herself voluntarily. This includes debt bondage, coerced labor, or any form of modern slavery.
Prohibition of child labor: We are committed to protecting the rights of children and adolescents and are firmly opposed to the hiring of minors, except in cases where they are in a formal education process carrying out their internships, apprenticeships, and other inherent and/or professional development modalities. In these situations, they will be under an apprenticeship contract. We will not employ people younger than the minimum legal working age established by the current legislation in the country, nor will we use child labor at any stage of our operations.
Respect for Universal Human Rights: We fully recognize and respect Human Rights in all our commercial activities. In this commitment, we ensure the promotion and protection of fundamental rights such as freedom of association and collective bargaining, fair, safe, and healthy working conditions, adequate and timely remuneration, life and personal integrity, a healthy environment, as well as participation and access to information depending on the associated process. To make this commitment a reality, we implement policies, processes, and monitoring mechanisms that guarantee its effective compliance in all our operations and commercial relationships.
Prevention of discrimination: We promote an inclusive and diverse work environment, where all individual identities and characteristics are respected and valued. We do not tolerate discrimination based on race, skin color, gender, sexual orientation, age, religion, disability, or other characteristics protected by law.
Fair remuneration: We are committed to ensuring fair and transparent remuneration for employees. To fulfill this commitment, we implement the ES-POL-08 Salary Increase Policy, which defines clear criteria and transparent procedures for managing salary increases in the company.

Commitments and responsibilities:

Netdata's senior management is committed to leading, supporting, and supervising the effective implementation of this policy, ensuring that the principles and commitments established here are integrated at all levels of the organization and in its commercial relationships.
The team of employees, remote workers, and other stakeholders must comply with this policy, actively promoting its application and preventing any form of forced labor, child labor, discrimination, or other violation of human rights.
Netdata will require its suppliers, strategic partners, and investors to comply with this policy, establishing evaluation and monitoring mechanisms and, if necessary, corrective actions or the termination of commercial relationships with those who fail to meet human rights standards.
We are committed to establishing monitoring mechanisms to regularly evaluate compliance with this policy in our operations and in our relationships with suppliers and contractors.
As part of its commitment to continuous improvement, Netdata will annually update the human rights due diligence process, with the support of internal or external auditors, as required.
Human rights monitoring indicators will be established in the sustainability report, where their performance will be communicated for the knowledge of the different stakeholder groups.

Implementation, monitoring, and auditing: Monitoring and auditing mechanisms are in place to regularly evaluate compliance with this policy in our operations and commercial relationships.

Internal and external audits: Internal audits are currently carried out annually to evaluate compliance with the established policies and procedures at Netdata. In addition, these are carried out by a third party currently linked to Netdata in a provider role, in order to avoid a conflict of interest in the final result.
Review of documentation and records: Annually examine documentation related to hiring, working conditions, and reported incident reports to identify possible human rights violations, child labor, discrimination, or forced labor.
Application of the due diligence approach: A human rights due diligence process will be developed to identify, prevent, mitigate, and, when necessary, remedy the adverse real or potential impacts that may arise within the framework of Netdata's operations, commercial relationships, and projects. This process will be reviewed annually and articulated with existing management and auditing mechanisms.
Awareness and sensitization: Training will be provided to the team of employees, remote workers, stakeholders, and those responsible for implementing the policy on Human Rights, the prevention of child labor, the elimination of discrimination, and the eradication of forced labor. This is done to create an organizational culture that values and respects human rights in all their forms. Information based on possible scenarios and practical cases that reflect relevant work situations will be shared. This helps participants apply the learned concepts in concrete contexts.
With our Cyberpact Social Responsibility program, the team of employees, remote workers, stakeholders, and those responsible for implementing this policy will be actively involved in various community initiatives and projects. They will participate in activities such as volunteering in charitable organizations, developing knowledge transfer programs, and awareness campaigns, fostering a genuine purpose and commitment to the cause. These actions will not only benefit the community but also strengthen teamwork and a sense of social responsibility among the participants.
Reporting and disclosure: Reports on compliance with the policy regarding Human Rights, child labor, discrimination, and forced labor will be prepared annually and this information will be disclosed both internally and externally. Transparency and accountability are fundamental to maintaining commitment to this policy.
Collaboration with stakeholders: We are committed to collaborating with suppliers, clients, and other stakeholders to promote ethical and human rights-respecting labor practices in our operations and commercial relationships.
Reviews and continuous improvement: This policy will be reviewed periodically to guarantee its relevance and effectiveness. We are committed to continuously improving our labor practices and our performance in Human Rights.

PREVENTION OF GENDER-BASED VIOLENCE IN THE WORKPLACE

Netdata, aware that gender-based violence in the workplace constitutes conduct contrary to human dignity, which deteriorates the interpersonal relationships on which the development of company activities depends and which may be punishable in accordance with the Internal Work Regulations, criminal law, and the applicable legal framework , is committed to ensuring that gender equality is a primary objective in all areas of the company. For this reason, it focuses its efforts not only on the prevention of gender-based violence, but also on promoting respect and inclusion of gender equity, women, and people belonging to LGBTIQ+ social groups, by addressing the following principles:

Prioritize the coexistence of people, by executing programs, campaigns, and training sessions that tend to strengthen the bonds and spaces for dialogue among our employees, framed in the prevention of gender-based violence.
Promote and encourage the participation of workers in the definition of intervention strategies, against risk factors that may generate gender-based violence in the workplace, where mechanisms for reporting or alerting situations that affect the coexistence of people will be provided. This emphasizes the Labor Coexistence Committee as an essential instance for improving employee relationships in the company.
Preferentially promote dialogue and the friendly resolution of conflicts, thus generating processes of continuous improvement in human talent management in the organization, always respecting the right to human dignity and non-discrimination of women and LGBTIQ+ people.
Comply with the current legal provisions, especially Law 1010 of 2006, Resolutions 652 and 1356 of 2012, Circular 0026 of 2023, and the PROTOCOL AGAINST SEXUAL HARASSMENT and ON THE BASIS OF SEX IN THE WORKPLACE of 2019 by the Ibero-American Social Security Organization (OISS), recognized as a regional standard on the matter. Additionally, we consider other relevant international instruments, such as the conventions and recommendations of the International Labour Organization (ILO) and the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) and other regulations on psychosocial risk prevention and the principles enshrined in the Constitution and jurisprudence.
Establish timely support mechanisms for reported cases of workplace and sexual harassment that threaten the dignity of women and the LGBTIQ+ population, providing accompaniment in the different cases or complaints processed.
The prevention of workplace harassment will be a function of the activities to be carried out by the company with the aim of creating an organizational culture with norms and values that foster positive social interaction and non-tolerance of conduct constituting workplace harassment.

PREVENTION OF SEXUAL VIOLENCE AND VICTIM SUPPORT

Prevention Strategy: Netdata will manage or promote activities with the Occupational Risk Administrator to strengthen support, protection, and prevention of sexual harassment in the workplace. Internal disclosure or socialization of existing sexual harassment policies will be carried out for the prevention, early detection, and support of gender-based violence and acts of sexual harassment, promoting respect and equality in the workplace.

Principles:

Zero tolerance: Sexual harassment, violence, or discrimination will not be tolerated.
Victim-centered approach: Case management will consider and validate the victim's perception, prioritizing their safety and well-being.
Confidentiality: Every person involved in the management and resolution of a case must maintain the confidentiality of the information.
Non-repetition: Mechanisms will be implemented to prevent the repetition of harassment behaviors.
No retaliation: Complainants will be protected against retaliatory actions.
Due process: All procedures will guarantee fair and equitable treatment for all parties involved.
Right to a defense: The right of people under investigation to present their statements and to an adequate defense will be respected throughout the process.

Approaches:

Gender-based: Decisions based on stereotypes will be avoided, promoting respect for gender identity.
Care-based: A safe and respectful work environment will be guaranteed.
Intersectional: The multiple identity variables that can increase vulnerability will be recognized and addressed.

Definition of sexual conduct in the workplace context: It will be understood that the interactions that employees and remote workers, contractors, interns, apprentices, and other people who participate in the work context have are part of the work context, regardless of the nature of the relationship. It will be presumed that the conduct was committed in the work context when it is carried out:

In the workplace or where the contractual relationship is carried out, regardless of the modality.
In the place where the remuneration is paid or where the tasks are delegated.
During travel, business trips, activities, events, and commutes between home and the workplace.
Through communication channels, whether digital or of another technological modality.
In the accommodation provided by the employer, as long as the sexual harassment comes from someone in the work environment.
Protection and support strategy: After receiving a complaint, the People area will establish appropriate protection measures, always acting with impartiality and guaranteeing respect for due process for all parties involved. Support for the victim will be managed or promoted with the Occupational Risk Administrator for activities for the support, protection, and prevention of sexual harassment in the workplace, and the protocol for filing a complaint with the Attorney General's Office will be indicated.

SOLUTION STRATEGY:

- Disciplinary Procedures: Follow the procedure described in Netdata's Internal Regulations.
- Alternative: Allow dialogue and a resolution in case the victim requests it.
- Legal: Refer cases that may constitute crimes to the relevant authorities, always with the victim's consent.

Roles and Responsibilities:

The employer: Approve the policy and promote its compliance by generating spaces for reflection.
Legal Advisor: Advise on specific cases and on updating the policy.
Employees and remote workers: Commitment to complying with the policy by fostering an environment of respect.
Suppliers and strategic partners: Comply with the standards and principles of this policy, implementing their own measures to prevent human rights risks and reporting any non-compliance.
Clients: Respect human rights in their interactions with Netdata and collaborate to ensure responsible practices throughout the value chain.
Investors: Support and demand compliance with this policy as part of their responsible investment criteria, promoting sustainability and respect for human rights.
Communities: Actively participate in dialogue and feedback spaces with Netdata to strengthen respect for and the promotion of human rights in the areas where the company operates.
Authorities and civil society organizations: Collaborate in the promotion, monitoring, and follow-up of compliance with this policy, contributing from their specific roles to the respect and defense of human rights.

DIVERSITY, EQUITY, INCLUSION, AND BELONGING (DEIB)

At Netdata, we believe that diversity, equity, inclusion, and belonging are essential for our continued success and growth. We are committed to ensuring a safe work environment, promoting diversity in all its forms, where Netdata's employees and remote workers feel valued, respected, and empowered to reach their maximum potential.

Our principles:

Respect and dignity: Netdata's employees and remote workers must be treated with respect and dignity. No form of discrimination, harassment, or intimidation will be tolerated.
Equal opportunities: We are committed to providing equal opportunities in all phases of employment, including hiring, promotion, training, and development.
Active inclusion: We promote the participation of all employees and remote workers in DEIB initiatives, ensuring that their voices are heard and valued.
Education and awareness: We will implement awareness programs to educate Netdata's employees and remote workers about the importance of diversity, equity, inclusion, and belonging.
Recruitment and retention: We strive to attract and retain a diverse workforce. This includes equitable recruitment practices and professional development programs that support the progression of all employees and remote workers.
Inclusive and accessible communication: We ensure that our internal and external communications reflect the principles of equity, inclusion, and social justice. We use respectful and empathetic language, and we adopt formats that ensure the information is understandable and accessible to our population, eliminating barriers that may limit anyone's participation.

Responsibilities:

Netdata's leadership team is responsible for promoting and supporting the DEIB culture, acting as role models.

The People team will supervise the implementation and monitoring of this policy, providing the necessary support and resources.

Netdata's employees and remote workers have the responsibility of contributing to an inclusive work environment, respecting and valuing the differences of others.

Review and continuous improvement: Netdata is committed to making continuous improvements to this policy, taking into account the information collected in a work climate survey, which will be reviewed annually to ensure its effectiveness and relevance. Adjustments will be made as necessary to adapt to changes in legislation and best practices. Training and awareness programs on topics related to DEIB will be offered. Constant feedback from employees and remote workers regarding the effectiveness of DEIB policies will be encouraged. Good practices in DEIB will be identified and shared both internally and externally.

Commitment to transparency: The company is committed to being transparent in its actions and decisions related to diversity, equity, inclusion, and belonging. Netdata considers that continuous improvement in its DEIB policy is fundamental for the company's sustainable growth and for the creation of a truly inclusive and welcoming work environment.

COMPLAINT MECHANISMS

We will establish secure and confidential channels for employees to file complaints, guaranteeing that these complaints will be handled fairly, quickly, confidentially, and with adequate follow-up of each case. For this, we have the following channels:

Direct complaint line:
- Through the SST-F-24 Report of cases of alleged harassment or human rights violations, people will be able to make the relevant complaints.
- It will be available 24 hours a day and will be managed in accordance with the current regulations of each country.
- If it is necessary to send evidence by email, use encryption tools to increase the security and confidentiality of your message. Consult with the IT process to get guidance on how to properly encrypt emails.
- This channel is dedicated and secure for receiving complaints, as it is an exclusive channel for this purpose and is protected by adequate security measures.
- If you file the complaint through the form, you will have the option of saving your complaint to have a record of its submission.
- After sending the complaint, avoid discussing the content with other people to protect your identity and the integrity of the complaint process.
- The response will be given within 15 business days after the complaint is filed, where the result of the investigation will be notified.
- If you have questions or need more information, communicate confidentially directly with julie.reina@netdatanetwork.com

Human Rights Policy, DEIB & Violence Prevention