September 2021
Human Rights
Policy
Amended by the Board of Directors on February 2024 1
Human Rights Policy
February 2024
About this Policy
Reference -
Name Human Rights Policy
Overview This Policy addresses the engagement of the Inditex Group with
respecting the internationally recognized Human Rights and
outlines the values and principles that guide its business activities
in all its spheres of action.
Theme Sustainability, Human Rights
Scope Global
Type Policy
Owner Sustainability
Date of approval 12 December 2016
Last amended on 6 February 2024
Versions 2.0: Human Rights Policy, dated 6 February 2024
1.0: Policy on Human Rights, dated 12 December 2016
2
Human Rights Policy
February 2024
Table of contents
1. Purpose. Laws and construction ........................................................................................................................................................................4
2. Definitions ......................................................................................................................................................................................................................4
3. Scope of application.................................................................................................................................................................................................5
4. Engagements...............................................................................................................................................................................................................5
5. Principles of engagement regarding respect for Human Rights ........................................................................................................ 6
6. Principles on Human Rights applicable to Stakeholders ....................................................................................................................... 9
7. Operational-level grievance mechanisms: Ethics Committee and Ethics Line ..........................................................................10
8. Roles and responsibilities .....................................................................................................................................................................................11
9. Oversight and monitoring .................................................................................................................................................................................... 12
10. Disclosure and circulation ................................................................................................................................................................................... 12
11. Update and review .................................................................................................................................................................................................. 12
3
Human Rights Policy
February 2024
1. Purpose. Laws and construction
Purpose
The Human Rights Policy (the “Policy”), approved in 2016 by the Board of Directors, following a favourable report from
the Audit and Compliance Committee and the Social Advisory Board, builds on the Codes of Conduct of the Inditex
Group addresses its engagement with respecting the internationally recognized Human Rights and outlines the values
and principles that guide its business activities in all its spheres of action.
This Policy considers both the interests of the Inditex Group and the expectations and needs of its Stakeholders.
Laws and construction
The enforcement of this Policy should not entail a violation of any applicable laws in the market where the Group
operates.
Where necessary, local internal rules may be approved to ensure that the Policy is aligned with local requirements. In
such case, local Policies should adjust as much as possible to the structure and provisions hereunder laid down, only
adjusting or supplementing what is strictly necessary to meet statutory and/or local requirements. In the event of any
discrepancy between the provisions of any local policy and this Policy, the former shall prevail. Where local policies do
not make provisions for a particular matter, this Policy shall apply on a supplementary basis.
2. Definitions
For the purposes of this Policy, the following terms are defined below:
Inditex Group’s Codes of Conduct
The Code of Conduct and the Code of Conduct for Manufacturers and Suppliers.
Inditex Group’s Stakeholders
Anyone at the Inditex Group, its customers, shareholders, manufacturers, suppliers, business partners, non-
governmental organizations, local communities and the society at large.
Inditex Group or Grupo
Group made up of Industria de Diseño Textil, S.A. (Inditex, S.A.) and the companies where Inditex holds, directly
or indirectly, at least 50% of the share capital or the voting rights.
Inditex (also the “Company”)
Industria de Diseño Textil, S.A. (Inditex, S.A.), parent company of the Inditex Group (as defined above).
Team leader
The leader of a group or team within the Group.
4
Human Rights Policy
February 2024
3. Scope of application
The Policy applies to every Group company and is binding for anyone at the Inditex Group, irrespective of their job title,
position, department or geographic whereabouts.
The Policy also applies to anyone rendering services or collaborating with Inditex on any terms other than an
employment relationship, such as board members or directors in any company of the Inditex Group, unpaid interns and
anyone engaged or about to be engaged in a professional relationship with the Inditex Group.
4. Engagements
To meet the Agenda for Sustainable Development set by the United Nations, the Inditex Group has assumed as its own
the Sustainable Development Goals (SDGs). Moreover, the Group acknowledges that respect for Human Rights, in the
framework of the United Nations Guiding Principles on Business and Human Rights, is key to sustainable development.
In this context, the Inditex Group undertakes to play an active role in the promotion of Human Rights, and to work
proactively to respect them. This engagement entails preventing or, if appropriate, reducing the negative consequences
of its own proceedings on Human Rights. Likewise, it shall do its utmost to prevent or reduce the negative consequences
on Human Rights directly related to the proceedings of third parties with whom the Group is engaged in a business
relationship.
This commitment, which is expressed in the Codes of Conduct and in the entire set of internal regulations, is based on
a corporate culture firmly rooted on the sustainability of its business model, and it covers all the transactions across the
Group’s entire value chain.
In particular, this Policy builds upon the ethical values of the Group, outlined in the Code of Conduct and the Code of
Conduct for Manufacturers and Suppliers of the Inditex Group. The Policy is also related to the following internal
regulations:
/ Sustainability Policy
/ Community Investment Policy
/ Enterprise Risk Management Policy
/ Criminal Risk Prevention Policy
/ Compliance Policy
/ Integrity Policies (Policy on Dealings with Public Officials, Policy on Gifts & Invitations and the Policy on
Donations & Sponsorship)
/ Conflicts of Interest Policy
/ Due Diligence Policy
/ D&I Policy
/ Compliance Policy regarding Personal Data Protection and Privacy
/ Health & Safety Policy
/ Anti-harassment Policy
5
Human Rights Policy
February 2024
/ Policy on the Internal Reporting Channels
/ The Ethics Line Procedure
5. Principles of engagement regarding respect for Human Rights
Under this Policy, the Inditex Group builds on its commitment to respecting and promoting Human Rights as set forth in
the United Nations Guiding Principles on Business and Human Rights and fostering them in the communities where it
operates.
This Policy is inspired by the following international declarations:
/ The Universal Declaration of Human Rights, that includes:
a) The Universal Declaration of Human Rights.
b) The International Covenant on Civil and Political Rights.
c) The International Covenant on Economic, Social and Cultural Rights.
/ The International Labour Organization (“ILO”) Fundamental Conventions numbers: 29, 87, 98, 100, 105, 111, 138,
155 and 182 as well as the ILO Declaration on Fundamental Principles and Rights at Work.
/ The Ten Principles of the UN Global Compact.
/ The United Nations Guiding Principles on Business and Human Rights.
/ The Guidelines of the Organization for Economic Cooperation and Development (OECD) for Multinational
Enterprises.
Additionally, the Inditex Group reinforces its responsibility to sustainability and protection of Human Rights, contributing
to the United Nations’ 17 Goals for Sustainable Development, in the framework of the 2030 Agenda for Sustainable
Development.
Based upon a review of its business model and the expectations of its stakeholders, the Inditex Group has identified
such Human Rights, both non-labour and labour, more directly related to its value chain.
Notwithstanding the foregoing, the Inditex Group represents its commitment towards respecting and promoting all
internationally recognized Human Rights.
Non-labour Human Rights
Respect for minorities and communities’ rights
The Inditex Group undertakes to respect the rights of local communities in such areas where it conducts its
business activity, and to respect the local laws, culture and uses, undertaking to maintain an open dialogue with
its stakeholders and paying special attention to the more vulnerable groups.
Right to intimacy, data protection and privacy
The Inditex Group respects the rights of all the persons with whom it interacts, to their intimacy, data protection
and privacy, and it shall make an appropriate use of the personal data and information gathered in all the countries
where it operates, paying special attention to the data of its employees and customers.
6
Human Rights Policy
February 2024
Right to health
The Inditex Group undertakes to take the required courses of action to ensure that its products do not represent
a hazard to the health and safety of its customers.
Right to freedom of opinion, information and expression
The Inditex Group undertakes to respect and promote, within its scope of application, the right to freedom of
opinion, information and expression, respecting diversity of opinion and fostering two-way communication with
its stakeholders.
Right to the security of the person
The Inditex Group undertakes to ensure the security of all the persons with whom it interacts in all its scopes.
Private law enforcements agencies with which it is related shall act in accordance with the applicable laws and
regulations and respecting Human Rights.
Contribution to the fight against corruption
The Inditex Group undertakes to fight corruption in all its forms, both directly and indirectly, including extortion
and bribery, pursuant to Principle 10 of UN Global Compact.
The Group relies on a Global Model of Compliance which comprises a criminal risk prevention model, to prevent
incurring in any wrongful or unlawful conduct related to corruption in any form or shape.
Right to the environment and to water
The Inditex Group undertakes to incorporate environmental yardsticks, namely those related to the
consequences of climate change and water management, upon planning and implementing its activities and
those of its business partners, promoting responsible environmental conducts among its staff, its suppliers and
the society at large.
The Group relies on a Sustainability Policy and a global, sound and efficient environmental management standard.
The Inditex Group shall comply with the environmental laws and regulations that apply to its activities, as well as
with any other future obligations, and shall make special efforts to prevent pollution and reduce, as much as
possible, the potential environmental impact created across its supply chain, both at environmental level and in
terms of people. Likewise, the Group shall contribute to preserve the environment, by implementing continuous
improvement actions towards reducing direct and indirect greenhouse gas emissions. It shall also strive to reduce
resources, control and improve the quality of spills, minimize the use of potentially hazardous components to both
the environment and the people, and generally, in the whole system of environmental management of the Group.
In this respect, the Inditex Group acknowledges the relevance of the First Global Legally Binding Climate
Agreement signed by 195 countries in December 2015, in the framework of the Paris Climate Change Conference
(COP21). The Company also acknowledges the principles covered in the CEO Water Mandate initiative,
established by UN Global Compact, as the roadmap for an appropriate and sustainable management of water.
7
Human Rights Policy
February 2024
Labour Human Rights
Forced or compulsory 1 labour is rejected
The Inditex Group rejects any form of forced or compulsory labour, as defined in ILO Convention 29. This extends
both to its own employees and its entire supply chain, as well as to any natural and/or legal person related to the
Group.
Inditex joined UN Global Compact in 2001, and adhered to its principle 4, according to which, businesses should
uphold the elimination of all forms of forced and compulsory work or work done under coercion.
Child 2 labour is rejected
The Inditex Group respects children’s rights and rejects child labour, pursuant to the provisions of ILO Convention
138 and in accordance with the minimum working age under the relevant regulations of each country. No one
under the age of 16 will be hired by the Group, unless not doing so would constitute a violation of the applicable
local regulations. Likewise, pursuant to its Code of Conduct for Manufacturers and Suppliers, the Group forbids
its suppliers and/or manufacturers to hire anyone under the age of 16.
Moreover, Inditex advocates the children’s right to education, in line with the Children’s Rights and Business
Principles of the United Nations Children’s Fund (UNICEF).
Discrimination is rejected and diversity 3 is promoted
The Inditex Group rejects any form of discrimination, respecting its employees’ diversity and offering equal
opportunities for employment and professional promotion. No one employed at the Group will be subject to
discrimination on grounds of race, ethnicity, disability, illness, religion, marital status, sexual orientation, political
opinion, age, citizenship, gender, or on any other grounds whatsoever.
Moreover, manufacturers and suppliers shall refrain from engaging in any discriminatory practice with regards to
the recruitment, remuneration, access to training, promotion, termination of employment or retirement of their
workers.
Respect for freedom of association and collective bargaining 4
The Inditex Group acknowledges the right of its employees to set up, be involved or join trade unions and/or
organization that defend and promote their interests, irrespective of the environment where they work. It also
ensures its workers respect for collective bargaining, freedom of opinion and protection for the workers’
representatives.
In turn, the Code of Conduct for Manufacturers and Suppliers provides that the company’s manufacturers and
suppliers shall ensure that their employees have, without distinction, the right of association, union membership
and to collective bargaining. No retaliation may arise from the exercise of such rights and no remuneration or
payment whatsoever may be offered to the employees to hinder the exercise of such rights. Likewise, they shall
adopt an open attitude of collaboration towards the activities of trade unions. Workers’ representatives shall be
protected from any form of discrimination and shall be free to carry out their representative functions at their
1
Issues relating to forced labour will be implemented pursuant to ILO Conventions 29 & 105
2
Issues relating to prohibition of child labour are governed by ILO Conventions 138 & 182
3
Issues relating to prohibition of discrimination are governed by ILO Convention 111
4
Issues relating to freedom of association and collective bargaining practices are governed by ILO Conventions 87, 98 & 135
8
Human Rights Policy
February 2024
workplace.
Protecting workers’ 5 health and safety
Every employee of the Inditex Group works in a healthy and safe pace. The Company ensures that a healthy and
safe work environment is provide to its employees through different procedures and regulations in the field of
occupational health and safety, meeting all the requirements in this aera laid down in the applicable laws of the
countries where it operates.
The Group’s manufacturers and suppliers shall also provide their employees with a safe and healthy workplace.
Just, fair and favourable 6 working conditions
The Inditex Group treats its employees with respect in a just and fair manner and pays their remuneration in
accordance with the applicable statutory provisions, including minimum wages, overtime and benefits. The
weekly working hours and overtime shall not exceed the statutory limit set forth in the laws and regulations of
each country. Overtime shall always be voluntary and paid according to law.
The Inditex Group shall establish all required conditions to ensure that its employees enjoy such rights, pursuant
to ILO Conventions or the applicable laws and regulations. Inditex shall strive for its employees to enjoy a work
environment free from any form of harassment, intimidation or violation. Thus, any form of harassment or abuse
to its employees is prohibited, whether sexual, psychological or verbal, as well as any other behaviour which might
lead to an intimidating, offensive or hostile work environment.
The Group’s manufacturers and suppliers shall meet the provisions of the Code of Conduct for Manufactures and
Suppliers to ensure just, fair and favourable working conditions to all their employees.
6. Principles on Human Rights applicable to Stakeholders
To fulfill the engagements set out above, the following principles shall apply to the relations between the Inditex Group
and its Stakeholders:
Employees
The Inditex Group undertakes to respect all its employees’ Human and Labour Rights, in particular those set forth
as fundamental, as defined in ILO Conventions. In turn, Inditex demands from all the employees of the Group
strict respect for Human Rights and boosts the promotion thereof.
The Inditex Group’s engagements to its employees are outlined in the Code of Conduct and implemented in
internal regulations and procedures. Additionally, Inditex has a Global Framework Agreement with UNI Global
Union to respect and promote fair work and labour rights; such Framework Agreement fosters the implementation
of best practices in industrial relations.
Suppliers
All manufacturers and suppliers that work with Inditex shall undertake to respect their employees’ Human and
Labour Rights, and to involve their business partners and convey to them such principles.
5
Issues relating to working conditions in the occupational safety and health ara are governed by ILO Convention 155
6
Issues relating to working conditions are governed by ILO Conventions 1, 14, 26, 111 & 131
9
Human Rights Policy
February 2024
The Codes of Conduct and in particular, the Code of Conduct for Manufacturers and Suppliers lay down the
minimum standards for an ethical and responsible behaviour that must be respected by all its manufacturers and
suppliers. These latter are bound to comply with labour laws and regulations of such countries where the Group
operates, as well as with ILO Conventions and other international standards, especially underscoring respect for
Human Rights in the framework of the United Nations Guiding Principles on Business and Human Rights.
These Codes are implemented by means of internal regulations and a permanent dialogue with the stakeholders,
which materialize, among others, in the Global Framework between Inditex and IndustriALL Global Union regarding
compliance with international labour regulations across Inditex’s production and distribution lines.
Business partners
The Inditex Group’s business partners shall respect and promote the internationally recognized Human Rights in
the performance of their activities. In this regard, Inditex shall do its utmost to promote the observance of this
obligation. For such purposes, business partners shall be deemed to be any company engaged in business with
Inditex by means of any manner of joint venture or franchise.
Customers
The Inditex Group respects the Human Rights of its customers and undertakes to communicate with them in a
clear and transparent manner and to provide safe products and services. Inditex undertakes to offer its customers
products that meet high standards for excellence, quality and health & safety, and that are manufactured in an
ethical and responsible manner pursuant to the Group’s health & safety standards: Clear to Wear, Safe to Wear
and IPLUS.
The Group rejects any form of discrimination against its customers, and it will respect at all times their right to
privacy, protecting and making an appropriate use of their persona data.
Community
The Inditex Group promotes and boosts the promotion of Human Rights in any local, national or international
community where it operates. As a supplement to the impact of its own business activities, Inditex implements its model
of social investments driven by its commitment towards global welfare and the reinforcement of the communities with
which it is related. This way of understanding investing in social and environmental programmes entails that Inditex
takes part, in a voluntary manner, in practices which build value in the community and in the company, as provided in
the Policy on Community Investment.
7. Operational-level grievance mechanisms: Ethics Committee and Ethics Line
The Inditex Group has a permanent dialogue with its stakeholders, allowing these latter to raise their concerns and
expectations about respect and promotion of Human Rights by the Group.
The Ethics Line is the preferred confidential channel to receive, investigate and handle through to completion any
concerns on topics that fall within the scope of the Policy. As an exception where a local or specific line exists, concerns
should be sent via this latter.
The Company will go through every concern or report received within the scope of the Policy.
You can access the Ethics Line on INET or on the company’s website ([Link]), as well as via the
communication channels that may be set out in the Ethics Line Procedure or, as the case may be, in the procedures of
10
Human Rights Policy
February 2024
local or specific ethics lines or via any other communication channel set out in the Ethics Line procedure, or, as the case
may be, in the procedures for local or specific lines.
In addition, anyone can send a report or concern that falls within the scope of this Policy to their Line Manager or the HR
Department.
Ethics Line management. Procedure
The Ethics Line is managed by the Ethics Committee, responsible for handling through to completion the concerns that
fall within the scope of this Policy, except where, pursuant to applicable law, a local committee has been appointed to
handle them.
Concerns shall be handled in accordance with the Group’s internal regulations, in particular, the Global Policy on the
Internal Reporting Channels of the Inditex Group and the Ethics Line Procedure, both of which are available on INET and
on [Link].
8. Roles and responsibilities
8.1. Anyone at the Inditex Group
Anyone at Inditex must observe this Policy and take the training they are called to attend.
Anyone at Inditex shall take the required action to ensure that the Policy is implemented, in accordance with their
position and responsibilities.
8.2. Board of Directors and board Committees
The Board of Directors is responsible for approving or amending this Policy, following a report from the pertaining
board committee.
8.3. Ethics Committee
The duties of the Ethics Committee include, without limitation:
/ Regularly apprising the Audit and Compliance Committee of the enforcement and compliance with this
Policy in particular, of any serious breach thereof reported via the Ethics Line.
/ Handling through to completion the cases concerning a breach of this Policy reported via the Ethics.
Line.
8.4. Sustainability Committee
The duties of the Sustainability Committee include, without limitation:
/ Effectively implementing the Policy by taking the appropriate action.
/ Planning and managing training and awareness-raising regarding the Policy.
/ Training the different areas in the Company and assist them in implementing the Policy.
/ Assisting the Ethics Committee, together with the General Counsel’s Office - Compliance, in the
investigation of allegations or reports of breach of the Policy and to issue the reports form the relevant
11
Human Rights Policy
February 2024
investigations and to implement the action to be taken including, as the case may be, disciplinary
measures against anyone at the Inditex Group, the termination of trade relations with third parties and/or
the reporting to the relevant authorities.
/ Regularly reviewing the Policy to ensure its alignment with applicable laws.
8.5. General Counsel’s Office-Compliance Office
The General Counsel’s Office – Compliance will, together with the Sustainability Department, coordinate the
reviews and updates of the Policy.
Likewise, in collaboration with in-house areas or with external assets, the General Counsel’s Office – Compliance
Office will provide the Ethics Committee with the technical assistance required to handle through to completion
any concerns, queries or reports about the Policy.
8.6. Internal Audit
Pursuant to the Internal Audit Charter and its Annual Activities Plan, Internal Audit may carry out audits to establish
compliance with the Policy.
9. Oversight and monitoring
The Inditex Group undertakes to allocate specific assets to ensure the effective implementation of the Human Rights
Policy. The Inditex Group shall carry out appropriate due diligence processes, regularly identifying actual and potential
impacts in the field of Human Rights and taking the appropriate action to prevent and mitigate any potential negative
consequences that may result, promoting positive impacts across its entire value chain.
The Inditex Group will collaborate with its relevant Stakeholders to implement the Policy and will respect and promote
the work of those who advocate for Human Rights.
10. Disclosure and circulation
This Policy is available on the Group’s intranet (INET) and on the corporate website ([Link]).
The Sustainability Department will liaise with the Communication and Institutional Relations Department, the General
Counsel’s Office – Compliance and local teams at the subsidiaries to implement the appropriate communication and
awareness-raising actions to ensure that the Policy is duly understood and implemented.
11. Update and review
The Policy will be reviewed and updated on the proposal of the Sustainability Department where this is deemed
necessary to encompass any statutory or organisational changes or to embrace best practices.
12