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Human Rights Management

Human Rights Management System

Human Rights Management Organization

HL D&I Halla has established a human rights management governance system together with other HL Group affiliates. Under this system, the Company plans and implements human rights management activities centered on common Group-wide tasks and operates a Group-level framework for preventing human rights risks. The Group-wide human rights management governance system is designed to complement the response capabilities of individual affiliates and ensure consistent human rights management based on common standards and implementation principles. A council comprising the human rights management working-level organizations of each Group company performs both regular and ad hoc duties, including deliberation on grievance-handling processes and human rights impact assessments. Key agenda items are submitted to the Human Rights Management Committee for deliberation and resolution. Material matters approved by the Committee are regularly reported to the Sustainability Management Committee under the Board of Directors, the highest decision-making body for human rights management, thereby strengthening implementation capabilities and accountability.

Human Rights Management Organization and Roles

Human Rights Management Policy

HL D&I Halla recognizes respecting and protecting stakeholder human rights as a core responsibility throughout all business activities. Based on the labor laws of each country and region, the Universal Declaration of Human Rights,1) and the UN Guiding Principles on Business and Human Rights,²⁾ the Company has established and operates principles for human rights management. These principles are shared internally following approval by top management and apply to all stakeholders, including customers, employees, shareholders and investors, partner companies, and local communities.

The Company promotes systematic management activities to create a discrimination-free workplace, expand diversity and inclusion, and prevent human rights violations. To effectively manage human rights risks across its operations, HL D&I Halla conducts regular human rights impact assessments covering headquarters, worksites, and partner companies. It also performs on-site human rights due diligence at high-risk worksites to identify potential risks and advance its management system. In addition, the Company responds promptly and fairly to human rights issues through grievance-handling channels and strengthens the internalization of human rights management through employee education and awareness-building activities.

1) Universal Declaration of Human Rights: A declaration adopted by the United Nations General Assembly in 1948 that serves as a foundational international human rights instrument, affirming the equal rights and freedoms of all people without distinction based on race, gender, language, religion, or other status

2) UN Guiding Principles on Business and Human Rights: International standards unanimously endorsed by the UN Human Rights Council in 2011, covering the state duty to protect human rights, the corporate responsibility to respect human rights, and access to remedy for victims

Human Rights Management Declaration Human Rights Management Guidelines

Human Rights Management Goals and Strategies

HL D&I Halla has established the vision of “Realizing the Value of Respect for Human Rights for a Better Life” and formulated mid- to long-term strategies to advance its human rights management system. Through a phased approach encompassing the establishment of a human rights management framework, expansion of awareness, and strengthened leadership, the Company is creating a management environment in which the human rights of all stakeholders, including employees and partner companies, are respected.

Human Rights Management Strategy

Mid- to Long-term Roadmap for Human Rights Management1)

HL D&I Halla is gradually expanding the scope of human rights impact assessments for partner companies in accordance with its mid- to long-term human rights management roadmap. The Company aims to expand the assessment scope from 10% of partner companies in the short term to 30% in the medium term and ultimately to all partner companies in the long term. It also continues to maintain a 100% completion rate for employee human rights education, thereby strengthening the establishment and internalization of human rights management throughout the organization.

Category Short Term Medium Term Long Term
Scope of Human Rights Impact Assessments Expand to 10% of partner companies Expand to 30% of partner companies Expand to 100% of partner companies
Ratio of Employees Receiving Human Rights Education 100% 100% 100%

1) Short term, medium term, and long term refer to 2025, 2026–2030, and 2031–2050, respectively.

Human Rights Risk Management

Human Rights Impact Assessments

HL D&I Halla conducts annual human rights impact assessments across the value chain, including headquarters, worksites, and partner companies, to protect stakeholders who may be vulnerable to human rights risks. The assessment covers key stakeholders who may be directly or indirectly affected by human rights issues, including employees of the Company and workers employed by partner companies. During the assessment process, the Company identifies stakeholders associated with each assessment item and analyzes the potential negative impacts that the level of implementation may have on those stakeholders. The findings are reflected in the development of improvement action plans. In addition, HL D&I Halla conducts annual on-site human rights due diligence at major worksites. Through this process, the Company systematically manages the entire cycle of human rights risk identification, prevention, response, monitoring, and disclosure, thereby continuously enhancing the effectiveness of its human rights management.

Key Human Rights Impact Assessment Items

Category Subcategory Human Rights Risk Stakeholders
Establishment of a Human Rights Management System Institutionalization of human rights management and grievance remediation procedures Employees of HL D&I Halla
Non-discrimination in Employment Non-discrimination in employment, including non-discrimination against non-regular workers and foreign workers Employees of HL D&I Halla
Guarantee of Freedom of Association and Collective Bargaining Guarantee of freedom of association and collective bargaining Employees of HL D&I Halla
Protection of Workers’ Human Rights Prevention of human rights violations against workers and protection of workers’ rights Employees of HL D&I Halla
Prohibition of Forced Labor Prohibition of forced labor and prevention of forced labor at partner companies Workers employed by partner companies
Prohibition of Child Labor Prohibition of child labor and prevention of child labor at partner companies Workers employed by partner companies
Guarantee of Occupational Safety Workplace safety, establishment of emergency response plans, protection of pregnant employees and employees with disabilities, provision of safety-related training and information, support for workers affected by industrial accidents, and protection of foreign workers Employees of HL D&I Halla and workers employed by partner companies
Responsible Supply Chain Management Management and monitoring of partner companies Workers employed by partner companies
Protection of Stakeholder Human Rights Protection of local residents’ human rights and intellectual property rights Local communities
Guarantee of Environmental Rights Establishment of an environmental management system, internal and external disclosure, prevention of environmental issues, and response to climate change Local communities
Consumer Protection Compliance with consumer protection laws, product defects, product management, and protection of consumer privacy Consumers

Human Rights Due Diligence Process

Step 1

Identify human rights issues and define the assessment scope

Step 2

Conduct human rights impact assessments

Step 3

Establish risk mitigation and improvement plans

Step 4

Implement and monitor corrective actions

2025 Human Rights Impact Assessment Results

Potential Human Rights Risks Definitions Vulnerable Stakeholders Action Plans
Establishment of a Human Rights Management System Insufficient dissemination and internalization of human rights management among subsidiaries and partner companies Employees of subsidiaries and partner companies Regularly distribute human rights management training materials and relevant content to subsidiaries and partner companies Include human rights-related content in training provided to employees of subsidiaries and partner companies
Protection of Workers’ Human Rights Insufficient education, policies, and programs for gender equality Employees of HL D&I Halla Conduct relevant education, policies, and programs at least once a year Include a human rights education module in the 2026 training curriculum
Prohibition of Child Labor Employment of persons aged 15 or older but under 18 without the consent of a person with parental authority or a guardian Children Revise relevant policies, including the enactment of the Human Rights Management Regulations
Responsible Supply Chain Management Insufficient fulfillment of human rights protection and occupational safety and health obligations by suppliers, subcontractors, subsidiaries, and other key partner companies Employees of subsidiaries and partner companies Attach HL D&I Halla’s Partner Code of Conduct when entering into contracts and recommend compliance
Require written provisions on human rights protection and respect when entering into contracts with partner companies Employees of partner companies

Mitigation Measures and Effectiveness Assessment

HL D&I Halla systematically implements and manages improvement measures based on human rights risks identified through human rights impact assessments. The Company identifies the actual likelihood and potential severity of human rights risks and derives improvement tasks according to their level of materiality, thereby minimizing the possibility of human rights violations. In addition, the Company establishes response plans to systematically address identified risks and regularly evaluates the effectiveness of response activities to advance its action strategies. In 2025, HL D&I Halla completed measures including the enactment of Employment Regulations and Human Rights Management Regulations and implemented its improvement plans accordingly.

Priority Risk Response and Improvement

Category Details Action Plan 2025 Action and Effectiveness Assessment
Compensation The wage calculation method for daily workers requires the separation of incidental cost items from wage items. Clarify the classification system by wage item. Corrective action completed at the relevant worksite.
Recruitment and Contracts Multilingual employment contracts need to be provided to foreign workers. Develop and distribute multilingual employment contracts. Chinese-language employment contracts provided.
Prohibition of Child Labor Employment regulations need to be supplemented with provisions prohibiting child labor. Enact and disclose Human Rights Management Regulations. Human Rights Management Regulations enacted and disclosed.

*Prepared based on the results of human rights impact assessments conducted at headquarters, partner companies, and worksites.

Status of Responses to Potential Risks1)

Category Value Chain Impact Response Activities
Establishment of a Human Rights Management System Employees and partner companies
  • Improve grievance-handling channels
  • Advance remediation procedures for human rights violations
Prohibition of Forced Labor Employees and partner companies
  • Strengthen due diligence on partner companies
    Strengthen the management of daily worker employment contracts
Protection of Stakeholder Human Rights Customers and local communities
  • Respond to grievances by worksite
  • Communicate with local communities
Guarantee of Environmental Rights Local communities
  • Reduce greenhouse gas emissions at worksites and promote the circular economy
  • Implement natural disaster preparedness measures and training

1) Issues that were not identified as risks in the current human rights impact assessment but require continued attention.

Human Rights Grievance Handling

HL D&I Halla operates grievance-handling channels to protect the human rights of all stakeholders, including employees, and to prevent unfair treatment and human rights violations within the organization. The identity and personal information of whistleblowers are protected under the Public Interest Whistleblower Protection Act, and any personnel or administrative disadvantages resulting from internal reporting are strictly prohibited. Reports are managed in accordance with the principle of confidentiality, and the Company’s internal whistleblower protection system ensures the anonymity and safety of reporters. No reports related to human rights violations were received in 2025. To continuously review the effectiveness and accessibility of its grievance-handling channels, HL D&I Halla applies the CSR Europe Assessment Checklist1), which reflects the eight effectiveness criteria set out in the UN Guiding Principles on Business and Human Rights.

1) CSR Europe Assessment Checklist: A checklist consisting of eight principles for evaluating the effectiveness of a company’s grievance-handling mechanism: legitimacy, accessibility, predictability, equitability, transparency, rights compatibility, continuous learning and improvement, and engagement and dialogue.

Human Rights Grievance Handling Process

Step 1

Report Human Rights Violations

  • Report via the Grievance Reporting Channel
Step 2

Confirm Human Rights Violations

  • Immediate Investigation of Reported Contents
  • Guarantee the Identity of the Victim/Informant
Step 3

Approval of Remedial Measures

  • Report to the Highest Decision-making Authority or Submit Agenda Items to the Decision-making Body
Step 4

Notification of Decisions and Further Actions

  • Immediately Notify the Victim of the Decision
  • Disciplinary or Judicial Action, if Necessary

Grievance Reporting Channels

HL Group Integrated Reporting Center

HR Team / Labor Union

  • Handling of human rights grievances through the HL D&I Halla Labor-Management Council
  • Human rights issues may be reported via e-mail, phone, in person, or in writing.

Human Rights Grievance Handling Status in 2025

(Unit: cases)
Number of grievances received Number of grievances handled Number of grievances subject to disciplinary action
2 2 1

Human Rights Training

HL D&I Halla provides regular human rights training to all employees to embed a culture of respect for human rights throughout the organization. Each year, the Company conducts training on the prevention of workplace harassment and sexual harassment, as well as disability awareness improvement, thereby strengthening employees’ basic human rights awareness and compliance consciousness. To respond to growing human rights risks, HL D&I Halla also operates an ESG training program entitled “Growing Human Rights Risks and HL D&I Halla’s Response.” In 2025, the Company expanded its job-specific training and provided training to 23 executives, 40 site managers, and 49 site directors. Training for executives focused on enhancing strategic response capabilities by providing an overview of human rights impact assessments, including their procedures and key results, based on an understanding of human rights management trends and the institutionalization of ESG. Training for site managers and site directors focused on improving on-site execution capabilities by covering human rights management trends and the Company’s current status, key human rights risks and response strategies in the construction industry, and the results of human rights impact assessments and related improvement tasks.

Key Human Rights Training Programs in 2025

Target Date Details
All Employees Ongoing
  • Workplace Harassment Prevention Training
  • Workplace Sexual Harassment Prevention Training
  • Disability Awareness Improvement Training
All Executives November 11, 2025
  • ESG Regulatory Trends and Response
  • Overview and Procedures of Human Rights Impact Assessments for Subcontractors
  • Human Rights Impact Assessment Results: Key Risks and Areas for Improvement
Site Managers November 20, 2025
  • 2025 Human Rights Impact Assessment Results and Improvement Tasks