Labour and human rights policy

Compliance with applicable laws and regulations is a mandatory requirement for all WYDE activities. In every employment contract, applicable legislation, the relevant collective bargaining agreement (where applicable), and any supplementary provisions established by company agreements must be strictly applied, ensuring compliance with both the letter and the spirit of the law. Every employee must have free access to a written employment contract in their own language, clearly setting out all terms and conditions.

Employment relationships must be voluntary and freely entered into. No fees or payments of any kind may be required as a condition of employment. At the time of hiring and throughout the employment relationship, employees must never be required to sign undated resignation letters or any other documents that could be detrimental to their interests or that do not reflect their free and informed consent.

WYDE offers its employees smart working arrangements under the Italian Agile Working framework.

1.2. Working hours, breaks, annual leave, and public holidays

WYDE recognizes every employee’s right to established working hours, weekly rest periods, paid annual leave, and public holidays. The company promotes a healthy work life balance, supporting employees’ physical and mental wellbeing.

Where it is not possible to take a public holiday on the scheduled date, employees must be granted a compensatory day off before the end of the calendar year or receive payment for the unused public holiday.

With regard to weekly working hours and overtime, WYDE complies with the provisions of ILO Conventions Nos. 001, 014, 106, and 030, as well as applicable collective bargaining agreements, ensuring measures that provide enhanced protection for employees.

WYDE does not permit:

• Working hours exceeding 48 hours of ordinary work plus 12 hours of overtime per week, in accordance with applicable local legislation.
• Working hours exceeding 40 hours per week or 8 hours per day for workers between the minimum legal working age and eighteen years of age.

To safeguard employees’ health and safety, WYDE provides:

• A minimum uninterrupted rest period of 11 hours between two working shifts, unless otherwise expressly provided by law or collective agreement.
• A minimum of 24 consecutive hours of rest within every seven day period, unless otherwise expressly provided by law or collective agreement.

Overtime must be agreed upon voluntarily and compensated at a higher rate than ordinary working hours, in accordance with applicable legislation and collective agreements.

WYDE recognizes the right to paid annual leave as established by collective bargaining agreements and, in any case, not less than the minimum provided by ILO Convention No. 132.

Employees who have worked for less than one year but have completed at least six months of service are entitled to a proportional period of paid annual leave.

1.3. Maternity rights and parental leave

WYDE’s workforce is predominantly female. For this reason, the company places particular emphasis on its parental leave policy to promote a better work life balance.

WYDE considers the protection of maternity to be essential, recognizing it as a fundamental right safeguarding the health and wellbeing of both employees and their children. In accordance with applicable legislation, maternity leave must be guaranteed to protect mothers during the period before childbirth and throughout the first months of the child’s life.

Maternity leave must be guaranteed for a mandatory minimum period of twelve weeks, without prejudice to:

• Leave during the two months preceding the expected date of childbirth as stated in the medical certificate of pregnancy.
• Leave covering the period between the expected date of childbirth and the actual birth, together with the following three months after childbirth.
• The right to continue working until the ninth month of pregnancy, provided that both the specialist physician of the National Health Service and the occupational health physician certify that this does not pose a risk to the health of the mother or the unborn child. In such cases, the entire five month maternity leave entitlement may be taken after childbirth.

WYDE guarantees the right to additional parental leave for a total period of ten months, which may be taken consecutively or in separate periods by either parent and shared between them during the first twelve years of the child’s life.

WYDE guarantees employees the right to return to their previous role following maternity leave, unless this is incompatible with the care needs of the child during the initial period after returning to work.

WYDE continuously works to reduce the risk of employment interruption resulting from the challenges of balancing work and family responsibilities. To support this objective, the company allows both female and male employees to reduce their working hours through part time arrangements in accordance with the applicable national collective agreement.

1.4. Fair remuneration

For WYDE, acting in full compliance with both the letter and the spirit of the law is essential. The company promotes decent work for all, believing that every employee should receive fair remuneration and a clear payslip, in accordance with collective bargaining agreements and applicable local legislation.

WYDE believes that fair remuneration can only exist where there are no structural pay differences between men and women. Accordingly, no salary discrimination based on gender is permitted for employees performing the same role with the same level of seniority.

All employees must receive at least the minimum wage established by national legislation or by any applicable collective bargaining agreement where it provides more favourable conditions.

Where an authoritative standard exists for determining a minimum wage aligned with the cost of living (a living wage) that exceeds the minimum levels described above, WYDE undertakes to adopt that standard as its minimum compensation threshold. The company also ensures that salaries remain aligned with market conditions.

1.5. Freedom of association, the right to organize, and collective bargaining

WYDE recognizes the value of collective bargaining as the primary instrument for determining employees’ contractual conditions and regulating relations between company management and trade unions.

WYDE believes that one of the key responsibilities of a responsible employer is to foster constructive dialogue based on communication, trust, and mutual respect. The exchange of ideas and information creates positive working conditions that benefit both employees and the company.

The company adheres to the principles of freedom of association and employees’ right to collective bargaining, in accordance with applicable laws and local practices. Where these rights are restricted, WYDE is committed to ensuring that its employees are nevertheless able to exercise them.

WYDE condemns all forms of discrimination against individuals who exercise these rights and respects the freedom of opinion and expression of all parties involved.

1.6. Corporate welfare plan

To support the protection and wellbeing of everyone working at WYDE, the company provides a corporate welfare plan that complements the benefits established by law and by the applicable collective bargaining agreement.

In addition to statutory leave, permits, and parental leave, employee benefits include:

Health and wellbeing

• Supplementary healthcare fund.
• Complementary pension plan for severance pay contributions (TFR).
• Health insurance.
• On site medical facilities.
• Paid sick leave.
• Smoke free workplace.

Social services

• Company catering service with 70% of the cost covered by the company.
• Take away dinner service.
• Discounts through partner companies for health and wellbeing, culture, and leisure activities.
• Shopping and gym discounts.
• Tax assistance services.

1.7. Notice period, probation, termination, and disciplinary measures

WYDE, in full compliance with applicable legal requirements and within an ethical and productive working environment, guarantees the following conditions:

NOTICE PERIOD

The notice period for part time employees is the same as that for full time employees and is calculated in calendar days, regardless of the employee’s working schedule. Notice periods commence on either the first or the sixteenth day of each month. WYDE applies the notice periods established by the applicable collective bargaining agreement.

PROBATIONARY PERIOD AND TERMINATION

The probationary period is established in accordance with the applicable collective bargaining agreement. For executive employees and first level employees, it is calculated in calendar days. For all other employee categories, it is calculated in working days.

During the probationary period, the employee’s remuneration may not be lower than the contractual minimum established for the assigned role. During this period, either party may terminate the employment relationship at any time without notice. Employees remain entitled to severance pay (TFR), accrued additional monthly payments, and payment for any unused annual leave.

In the event of dismissal or resignation, employees are entitled to annual leave accrued in proportion to the months actually worked during the relevant year.

DISCIPLINARY MEASURES

WYDE reserves the right to apply the following disciplinary measures in the event of employees failing to fulfil their duties, according to the seriousness of the misconduct:

• Verbal warning for minor infringements.
• Written warning in the event of repeated violations of the above.
• Fine not exceeding the equivalent of four hours of ordinary pay.
• Suspension from work and pay for a maximum of ten days.
• Summary dismissal without notice, together with any other consequences provided for by law or company regulations.

WYDE is required to inform all employees of the disciplinary provisions contained in company rules or agreements by displaying them in a location that is accessible to everyone.

2.1. Diversity, discrimination, and inclusion

WYDE values diversity, recognizing its growing importance in light of the company’s ongoing international expansion.

WYDE recognizes the value of every individual and is committed to providing equal employment opportunities without discrimination of any kind based on ethnicity, religion, beliefs, nationality, gender, physical condition, age, or social status.

In addition to condemning and taking action against conduct that violates these principles, WYDE is committed to creating and maintaining an inclusive working environment where respect for human rights is a priority and where there is no place for discrimination.

In line with these principles, WYDE is committed to fostering an inclusive environment that meets the needs of everyone, where each individual can fully express their potential. We recognize different perspectives and each person’s individual contribution as a source of enrichment and growth.

• Recruitment and selection: During recruitment and selection processes, WYDE guarantees equal treatment of all applications in accordance with this Policy.
• Performance evaluation: In evaluating performance, every WYDE manager acts objectively and excludes from the assessment any factors relating to family responsibilities, gender, sexual orientation, race, color, age, pregnancy, marital status, religion, political opinion, nationality, ethnicity, caste, illness, or disability, focusing exclusively on job performance. All WYDE managers are expected to consider the needs and individual strengths of their employees, encouraging personal development and implementing targeted training plans where improvement is needed.
• Internal promotions and remuneration policies: When defining the annual remuneration policy, WYDE managers ensure appropriate gender representation in incentive plans and stock option programs.
• Internal organization: The establishment of committees and working groups for governance or project purposes must reflect diversity in terms of gender, skills, and experience. WYDE is committed to ensuring equal opportunities at all times.

WYDE’s workforce reflects the social context in which the company operates, helping to ensure employment opportunities for all social groups in proportions that are as close as possible to their representation within the local community.

WYDE considers it a priority to promote equal opportunities for women throughout its extended supply chain, particularly in regions where discriminatory practices remain widespread. WYDE’s mission is to promote growth and development in the communities where it operates, with particular attention to women, supporting them in realizing their full potential through training and professional development opportunities equal to those available to men.

2.2. Harassment and violence

For WYDE, acting in full compliance with both the letter and the spirit of the law is essential, together with strict adherence to internal policies and procedures.

In line with ILO Convention 190, WYDE recognizes that all forms of harassment and violence in the workplace constitute a serious violation of human rights and a threat to equal opportunities. The company therefore condemns every form of abuse or violence within its sphere of influence.

At WYDE, everyone is expected to treat colleagues and everyone they work with respectfully, avoiding any threatening, intimidating, or harassing behavior.

To respond decisively to all forms of gender based violence, WYDE provides women working within the company with free legal advice and support in cases of violence or harassment.

2.3. Child labour

WYDE condemns all forms of child labour. Only workers who have reached the minimum legal working age established by applicable local legislation, in accordance with ILO Conventions Nos. 138 and 142, may be employed in activities carried out directly or indirectly by WYDE.

WYDE is committed to ensuring that all young workers, between the minimum legal working age and the age of 18:

• are identified in a dedicated register;
• are not assigned to hazardous work, overtime, or night shifts;
• do not suffer adverse effects on their education, health, or physical, mental, spiritual, moral, or social development as a result of their employment;
• can be easily identified.

WYDE ensures that all necessary measures are adopted by its suppliers to prevent the employment of individuals below the legal minimum working age. Business partners are required to maintain systems capable of ensuring that child labour is excluded from the supply chain.

Where these principles are violated, WYDE believes that action must always be taken in the best interests of the child, involving the family and or specialized organizations where appropriate. In such cases, WYDE is committed to working with all stakeholders to remove the child from employment while ensuring continuity of financial support for the family and implementing educational programs that enable the child to continue their education until reaching the legal minimum working age.

2.4. Forced, bonded, prison, and undeclared labour

WYDE does not accept any form of forced or bonded labour, nor the use of prison labour outside officially recognized rehabilitation programs, whether directly or through project contracts, supply agreements, or any other form of cooperation.

WYDE’s approach is based on ILO Conventions Nos. 138 and 142, ILO Recommendations Nos. 146 and 190, and the United Nations Convention on the Rights of the Child. WYDE defines a child as “every human being below the age of 18 years unless, under the law applicable to the child, majority is attained earlier.”

WYDE also follows the principles established by ILO Conventions Nos. 29 and 105 and ILO Recommendation No. 135.

The use of coercive practices based on threats, the confiscation of personal documents, or practices equivalent to forced labour, such as the Sumangali scheme, is strictly prohibited. Subject to the applicable legal provisions governing the employment relationship, employees must be free to leave both the workplace and the company without any form of coercion.

WYDE does not accept the use of unlawful fines or disciplinary measures that undermine the dignity of its employees.

WYDE does not tolerate any form of human rights violation within its global organization or throughout its supply chain.

3.1. Occupational health and safety

WYDE is committed to ensuring that all applicable local health and safety legislation is strictly observed.

As required by law and in accordance with Article 17, letter b, paragraph 4 of the Italian Consolidated Health and Safety Act (T.U.S.), WYDE has established a Prevention and Protection Service and appointed a Prevention and Protection Service Manager (RSPP) with the professional qualifications, experience, and training required for the role. Appointed by and reporting directly to the employer, the RSPP is responsible for coordinating the prevention and protection service against workplace risks, with the following specific duties:

• identifying risk factors, assessing risks, and determining the measures necessary to ensure health and safety in the workplace, in compliance with applicable legislation and based on a thorough understanding of the company’s organization;
• developing, within the scope of their responsibilities, the preventive and protective measures arising from the Risk Assessment Document (DVR) and the related monitoring systems;
• preparing safety procedures for the various company activities;
• proposing employee information and training programs;
• participating in consultations concerning occupational health and safety and in the annual safety review meetings;
• providing employees with the necessary health and safety information.

3.2. Occupational health and safety management system

In line with the provisions of the Italian Consolidated Health and Safety Act (Legislative Decree 81/2008), the Prevention and Protection Service, understood as the system of people, resources, and procedures dedicated to protecting employees from occupational risks, whether internal or external to the company, has implemented and continuously improved an Occupational Health and Safety Management System.

In addition to ensuring compliance with applicable legal requirements, the system includes a structured program of activities, coordination meetings, and inspections to ensure that workplace health and safety conditions are regularly monitored.

In accordance with Legislative Decree 81/2008, WYDE has developed its Occupational Health and Safety Management System in line with the UNI INAIL Guidelines.

3.3. Risk assessment and identification of health and safety protection measures

Employers, in cooperation with the Prevention and Protection Service Manager (RSPP) and the Occupational Physician, and after consulting the Workers’ Safety Representative (RLS), carry out risk assessments and prepare the Risk Assessment Documents (DVR) in accordance with applicable legislation and the company’s health and safety policy.

These documents are prepared for all company locations and are stored within the company’s document management system.

The Risk Assessment Document includes:

• a report on the assessment of occupational health and safety risks;
• the preventive and protective measures adopted as a result of the assessment, including any personal protective equipment used;
• the program of measures considered necessary to continuously improve health and safety performance;
• the procedures for implementing these measures and the organizational roles responsible for their implementation;
• the names of the Prevention and Protection Service Manager (RSPP), the Workers’ Safety Representative (RLS), and the Occupational Physician who participated in the risk assessment;
• the identification of job roles that may expose employees to specific risks requiring recognized professional competence, specific experience, appropriate training, and adequate instruction.

Risk Assessment Documents are updated whenever significant changes occur in work activities or job responsibilities.

WYDE periodically assesses the risks associated with its activities, documenting the analyses performed, identifying relevant risks, and defining the actions required to eliminate or reduce them.

3.4. Emergency management and first aid

Given that WYDE operates in a low fire risk environment with limited manual activities, emergency procedures have been established primarily as preventive measures to ensure the prompt involvement of the competent authorities, such as the Fire Brigade, to define roles and responsibilities during emergencies, and to enable the rapid evacuation of the premises when necessary.

Emergency procedures have been established for the following situations:

• power outages;
• fire;
• smoke detector alarms;
• automatic fire suppression system (sprinkler) alarms;
• earthquakes;
• failures of the air conditioning or ventilation system.

Each year, the RSPP reviews the effectiveness of these procedures and submits a report on the inspections to the Supervisory Body.

The RSPP also verifies:

• the correct placement of fire safety signage, including emergency exits, fire extinguishers, and hydrants;
• the presence of emergency public address systems for evacuation announcements;
• the availability of first aid kits within the company’s offices.

3.5. Periodic safety meetings

Each year, a safety meeting is held involving the employers, the RSPP, the Occupational Physician, and the Workers’ Safety Representative (RLS). The Supervisory Body established pursuant to Legislative Decree 231/01 is invited to attend and, in any event, is informed of the outcomes.

During this meeting, the company reviews:

• the adequacy of the Risk Assessment Document;
• workplace accident statistics;
• health and safety training and information programs;
• possible actions to further improve workplace safety.

3.6. Health surveillance

Health surveillance is carried out by the Occupational Physician.

For every employee subject to medical examinations, the Occupational Physician maintains, under their own responsibility, a confidential medical and risk record containing the results of medical examinations and any related diagnostic tests.

Medical examinations are carried out:

• before employment, to verify the absence of medical conditions incompatible with the intended role and to assess fitness for the specific position;
• periodically throughout the employment relationship;
• at the employee’s request;
• when the employee changes role, where the new position involves occupational risks requiring a specific fitness assessment;
• upon termination of employment, where required by law.

Medical examinations, provided at the company’s expense, include clinical assessments, biological tests, and any diagnostic investigations deemed necessary by the Occupational Physician.

The Occupational Physician, together with the RSPP, must inspect the workplace at least twice each year.

3.7. Training and information activities

In accordance with the company’s Prevention and Protection System and the provisions of Articles 36 and 37 of the Italian Consolidated Health and Safety Act, WYDE implements appropriate health and safety training and information programs.

These programs place particular emphasis on:

• the importance of complying with the company’s health and safety policy;
• the consequences of employees’ actions and work activities;
• the consequences of failing to comply with health and safety requirements.

Training activities are managed by the Integrated Management System Manager (RSGI) and organized in cooperation with the RSPP and the Chief Executive Officer.

Training delivery is delegated to the managers responsible for each operational location, with the exception of training for the emergency response team, which is coordinated by the technical services department and may also be delivered by external consultants.

At the company’s headquarters, training is provided upon hiring and is managed by the Human Resources and Organization Manager.

3.8. Coordination and monitoring of activities entrusted to third parties

In accordance with Legislative Decree 81/2008, whenever work is entrusted to contractors or self employed workers within company premises or operational sites, company personnel, in consultation with WYDE managers:

• verify the technical and professional suitability of contractors or self employed workers through the relevant Chamber of Commerce registration, in relation to the activities assigned;
• provide detailed information regarding the specific risks present in the workplace and the preventive and emergency measures applicable to the activities to be performed;
• cooperate in implementing measures to prevent occupational accidents during the execution of contracted work;
• coordinate risk prevention and protection measures by exchanging information to eliminate risks arising from interference between the activities of different contractors involved in the overall project.

The Single Interference Risk Assessment Document (DUVRI) is attached to all relevant contracts or contract documentation.

Employees of contracting companies must carry an identification badge with a photograph, the employee’s personal details, and the name of the employer. The badge must be visibly displayed at all times.

WYDE does not permit any exceptions to workplace health and safety standards:

• the workplace must be safe and healthy;
• workplace temperature and ventilation must be appropriate throughout the year;
• lighting must be adequate for the activities performed and throughout all working hours;
• sanitary facilities must be clean, proportionate to the number of employees, and separated for men and women;
• employees must have access to healthcare services without unreasonable restrictions.

While WYDE directly manages its own services, it also works with independent suppliers to improve occupational health and safety standards, preferably through multi stakeholder initiatives, in accordance with the principles set out in this Policy.