Policies

[ESRS S1-1; GRI 2-23, 2-25, 3-3c]

The policies and guidelines listed in the Management approach “Human rights and fair labor practices” apply to the entire Lenzing Group. The policies and guidelines are accessible to all employees via the intranet and are also sent by e-mail.

The policies that explicitly come from Human Resources are described in more detail below.

The others are described in different chapters: For more information on the Policy for Safety, Health and Environment, please see the “Pollution” chapter. For the Global Code of Business Conduct and for the Global Supplier Code of Conduct, please refer to the “Business conduct” chapter. The Clean & Hygiene Guideline can be found in the “Consumers and end-users” chapter.

Policy on Human Rights and Labor Standards

This policy confirms the company’s commitment towards fulfilling, and wherever possible, exceeding all applicable social and ethical obligations. Lenzing fully supports all internationally recognized human rights and the principles proclaimed in the Universal Declaration of Human Rights (UDHR), United Nations Global Compact (UNGC), OECD Guidelines, and the Rights at Work of the International Labour Organization (ILO). Lenzing believes in employee satisfaction and wellbeing as well as fostering compliance with standards. The Vice President Corporate Human Resources is responsible for the implementation of this policy.

Global Recruitment Guideline

This guideline clarifies the position approval process as well as key rules and roles for the collaboration required to recruit or transfer talent using sound hiring decisions through a fair and unbiased process including for full-time, part-time and temporary roles as well as apprentices and for special projects. The guideline covers approval to recruit, sourcing, selection, decision, documentation standards, offer and onboarding stages and clarifies the responsibilities of local HR, the Line Manager, Corporate HR, HR Directors and HR Business Partners. The Director Corporate Recruitment/HR Employee Branding is responsible for the implementation of this guideline.

Lenzing Group Reward Guideline

This guideline sets out the guiding principles and reward philosophies of the Lenzing Group with the aim of attracting and retaining staff, be the employer of choice, while also maintaining internal and external equity for its employees. This is based on a Hay job evaluation approach. The guideline covers base salary, local elements, short term variable pay, benefits, annual salary reviews, off-cycle increases and short term variable pay. All Group business units and legal entities are required to structure reward in accordance with this guideline. The Lenzing Group Reward Guideline has been designed to:

• Support and drive the business strategy
• Attract, retain and motivate the best people by providing competitive pay within local markets
• Recognize and reward individual performance
• Link variable pay to business performance
• Link shareholder, management and employee interests

The Senior Director Corporate Compensation & Benefits is responsible for the implementation of this guideline.

Global Guideline for Creating a Job Description

This guideline provides a global process for creating a job description to ensure standardization and comparability of jobs and is intended to prevent duplication of responsibilities and competencies as well as ensuring that the job and its functionality are described and not the job holder. The Senior Director Corporate Compensation & Benefits is responsible for the implementation of this guideline.

Global Job Evaluation Guideline

This guideline has been created to ensure a globally consistent approach is taken towards job evaluation using the Korn Ferry Hay grading methodology. It covers those involved, the approval levels, a summary of the process as well as an appeal stage.

The Senior Director Corporate Compensation & Benefits is responsible for the implementation of this guideline.

Lenzing Group Short-Term Incentive Plan

This plan confirms the structure and targets of the annual bonus set by the Board. It covers eligibility, the short term incentive plan, the targets, the payment levels, the payment date, eligibility for payment and exceptions.

The Vice President Corporate Human Resources is responsible for the implementation of this plan.

Global Salary Administration Guidelines

These guidelines have been compiled to define the administrative standards required to ensure that an individual employee’s base salary is set at a level that is market-competitive, internally equitable, and performance driven. These procedures apply to all graded jobs globally for as far as this is compliant with local labor laws and regulations. The guideline includes aspects such as equity analysis, compensation administration principles, salary increase types, a decision tree, promotion, transfer and demotion.

The Senior Director Corporate Compensation & Benefits is responsible for the implementation of this guideline.

Global Learning & Development Guideline

This guideline provides an overview of learning and development processes to ensure the Lenzing Group is prepared for further growth by having key employee competencies and skills developed. The guideline describes Lenzing’s People Development Approach as being the way it identifies the knowledge that is core to the business’s sustainable competitiveness and defines how competencies are built and developed in defined areas of strategic relevance. This approach is targeted towards all Lenzing employees. The guideline includes topics such as performance and development talks, competency framework, competency assessment, individual development plan and the training budget process.

The Senior Director Corporate People Development is responsible for the implementation of this guideline.

Global Performance Management Guideline

This guideline is part of the People Development Approach and provides an overview of how talent management processes operate to enable its employees to support the growth plans of Lenzing. It includes the definition of performance, the performance management process, Lenzing’s corporate values and behaviors, how goals are defined and describes how to conduct performance and development talks.

The Senior Director Corporate People Development is responsible for the implementation of this guideline.

Modern Slavery Act Transparency Statement (UK only)

This statement is made in accordance with section 54 of the Modern Slavery Act 2025 and provides an annual update on the actions taken by the business in combating modern slavery. It refers to a number of internal Lenzing documents, including the Policy on Human Rights and Labor Standards, the Global Supplier Code of Conduct and the Global Code of Business Conduct. The statement confirms support for the principles proclaimed in the Universal Declaration of Human Rights (UDHR), the UN Global Compact, the OECD Guidelines for Multinational Enterprises and the fundamental labor principles that protect workers’ rights as defined by the Declaration on Fundamental Principles and Rights at Work of the International Labor Organization (ILO) including:

• The prohibition of child labor
• The prohibition of forced labor
• Freedom of association and the right to collective bargaining
• Fair compensation and working hours
• Safe and healthy workplaces
• Protection from discrimination, harassment and inhumane treatment

The statement describes both risk assessment and due diligence processes and confirms the use of the EcoVadis methodology that uses a CSR analysis criteria for assessing its suppliers and which has the following themes:

• Environment
• Labor & Human Rights
• Ethics
• Sustainable Procurement

The UK Human Resources Manager is responsible for updating this statement.

Global Equity, Diversity and Inclusion Policy

This policy confirms Lenzing’s desire to strive to inspire, empower, engage and develop its employees to enable them to participate in maintaining Lenzing’s competitive advantage. Lenzing aims to provide equal opportunities for all, regardless of gender, marital status, ethnicity, skin color, nationality, national origin, disability, sexual orientation, religion or belief, age or other characteristics. Lenzing strives to build a diverse and inclusive work environment where differences are respected and valued. So everyone feels appreciated, included and so they can be their true self and feel able to give their best contribution. The Lenzing Group aims to:

• Facilitate equity, fairness and respect for all existing employees and those applying to join the business
• Ensure an environment free from unlawful discrimination
• Oppose and prevent all forms of unlawful discrimination

Lenzing supports the UN Global Compact, endorses its principles and is committed to advancing a number of the UN Sustainable Development Goals by encouraging equity, diversity and inclusion among its workforce. Employees are encouraged to report breaches of this policy and a variety of options for doing so are provided, including the use of a confidential whistleblowing system.

The Vice President Corporate Human Resources is responsible for the implementation of this policy.

Global Child Labor Remediation Procedure

This procedure provides guidance for any instance of child labor found within Lenzing and includes remediation steps that can be followed by managers to ensure that child safety and rights are upheld, and the best interests of children are always served. Lenzing’s expectation is that child labor is not to be used in the production of its products. This procedures aims to ensure compliance with the United Nations International Labor Organization’s (ILO’s) Conventions on child labor. The procedure relates to permanent, temporary, informal and contract labor, whether directly, or indirectly employed by Lenzing as well as children who have been trafficked or sold into work. Lenzing requires all internal recruitment procedures to ensure that child labor is not used. Lenzing is also committed to protecting the rights of young workers. Lenzing facilities are expected to have effective procedures in place for age verification purposes and retain related records for all employees. This global procedure applies to all applicants, employees and interns associated with any Lenzing facilities worldwide. The application of this procedure will take into consideration relevant local and national laws. The procedure includes:

• Removing the child from the workplace
• Confirming the identity of the child’s parent(s)/guardian(s)
• Consulting the parent(s)/guardian(s)
• Advising relevant child-focused organizations/authorities
• Making a record of the incident
• Communication with relevant people
• Determining a resolution proposal
• Conducting a root cause analysis to ensure future avoidance
• Reporting the incident

Human rights

The Lenzing Group fosters a safety culture and a sustainable working environment for the benefit of all employees, all local communities in which the company operates and all business partners. It is imperative that the entire global network of the Lenzing Group fulfills, and wherever possible, exceeds all applicable social and ethical obligations. Suppliers are held to the same high standards.

The United Nations Global Compact (UNGC) is one of the world’s most important initiatives for responsible corporate governance. As a member, Lenzing is committed to upholding human rights, respecting the rights of employees and their representatives, protecting the environment, enabling fair competition and combating corruption. As part of the six-month UN Global Compact Business & Human Rights Accelerator Program, the company took a closer look at the topic of human rights in the reporting year and defined the human rights relevant to the company by means of an internal survey with around 30 people. The resulting heat map forms the basis for developing plans and actions for salient human rights in a next step. To fulfill the requirements of corporate due diligence, Lenzing monitors adherence to laws, human rights principles and applicable environmental standards not only internally, but also at its suppliers and within its supply chains. Compliance with human rights is essential and non-negotiable for the Lenzing Group. The company follows internationally accepted foundational principles and rights when it comes to work as per the International Labor Organization (ILO).