Human rights policy

Respect for Human Rights

Respect for human rights is a fundamental value of The Commemorative Brands Inc. (COMMEMORATIVE BRANDS INC DBA BALFOUR & CO).

We strive to respect and promote human rights in accordance with the UN Guiding Principles on Business and Human Rights in our relationships with our employees, suppliers and

independent bottlers. Our aim is to help increase the enjoyment of human rights within the communities in which we operate.

This Policy is guided by international human rights principles encompassed by the Universal Declaration of Human Rights, including those contained within the International Bill of Rights

and the International Labor Organization’s 1998 Declaration on Fundamental Principles and  Rights at Work.

This policy applies to all COMMEMORATIVE BRANDS INC DBA BALFOUR & CO entities that we own, the entities in which we hold a majority interest and the facilities that we manage. The Company also expects suppliers to uphold these principles and urges them to adopt similar policies within their own businesses.

We use due diligence as a means to identify and prevent human rights risks to people in our business and value chain. Where we have identified adverse human rights impacts resulting

from or caused by our business activities, we are committed to provide for or cooperate in,their fair and equitable remediation. We seek to promote access to remediation where we are

linked to or involved in those adverse impacts through our relationships with third parties.

Community and Stakeholder Engagement

We recognize that we are part of the communities in which we operate.

Our aim is to ensure through dialogue that we are listening to, learning from and considering their views as we conduct our business. We believe that local issues are most appropriately addressed at the local level.

Where appropriate, we engage with a wide range of civil society and stakeholders on human rights issues related to our business. This includes issues in our Company and across our value chai, through which we seek to promote respect for human rights.

Diversity and Inclusion

We value and advance the diversity and inclusion of the people with whom we work.

We are committed to equal opportunity and are intolerant of discrimination and harassment.

We work to maintain workplaces that are free from discrimination or harassment on the basis of race, sex, color, national or social origin, ethnicity, religion, age, disability, sexual orientation, gender identifi­cation or expression, political opinion or any other status protected by applicable law. The basis for recruitment, hiring, placement, development, training,

compensation and advancement at the Company is qualifi­cations, performance, skills and experience.

We do not tolerate disrespectful or inappropriate behavior, unfair treatment, or retaliation of any kind. Harassment is not tolerated in the workplace and in any work-related circumstance

outside the workplace.

Freedom of Association and Collective Bargaining

We respect our employees’ right to join, form or not to join a labor union without fear of reprisal, intimidation, or harassment. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives. The Company is committed to bargaining in good faith with such representatives.

Safe and Healthy Workplace

The safety and health of our employees is of paramount importance. Our policy is to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations, as well as internal requirements. We work to provide and maintain a safe, healthy and productive workplace, in consultation with our employees, by addressing and remediating identifi­ed risks of accidents, injury and health impacts.

Workplace Security

We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats.

Security safeguards for employees are provided, as needed, and are maintained with respect for employee privacy and dignity.

Forced Labor and Human Trafficking

We prohibit the use of all forms of forced labor, including prison labor, indentured labor,

bonded labor, military labor, modern forms of slavery and any form of human traffi­cking.

Child Labor

We prohibit the hiring of individuals that are under 18 years of age.

Work Hours, Wages and Benefits

We compensate employees competitively relative to the industry and local labor market, and in accordance with terms of applicable collective bargaining agreements. We work to ensure

full compliance with applicable wage, work hours, overtime and benefi­ts laws.

Land Rights and Water Resources We strive to create workplaces in which open and honest communications among all employees are valued and respected. The Company is committed to comply with applicable labor and employment laws wherever we operate. The Company also ensures employees are aware of the Human Rights Policy through training and an annual certi­fication process.

Any employee who believes a conflict arises between the language of the policy and the laws, customs and practices of the place where he or she works, or who has questions about this policy or would like to con­fidentially report a potential violation of this policy, should raise those questions and concerns with local management, Human Resource or the Legal Department.

No reprisal or retaliatory action will be taken against an employee for raising concerns under this policy. The Company will investigate, address, and respond to the concerns of employees and will take appropriate corrective action in response to any violation.

The Human Rights Policy is aligned with the Company’s Code of Business Conduct. To report issues under the Human Rights Policy, please contact Human Resources at [email protected] .

We report to the public on our human rights-related commitments, efforts and statements, consistent with this Human Rights Policy, as part of our Human Rights Report and annual

Sustainability Report. This reporting cross references the UN Guiding Principles Reporting Framework.

Human Rights Due Diligence Efforts

Human Rights Due Diligence Findings

Findings:

Here at Commemorative Brands Inc dba Balfour & Co, all our business partners undergo audits by outside auditing firms either yearly or bi-yearly to review Human Rights, Environmental Policies/Procedures and Health/Safety Policies & Procedures.

During these audits, no adverse issues covering Human Rights, Environmental or Health/Safety were documented within any of our business partners organizations.  In fact, all or our business partners have received high marks in Human Rights, Environmental and Health/Safety areas.

Commemorative Brands Inc dba Balfour & Co will continue to audit and monitor all business partners to ensure compliance with the United Nations Human Rights Guiding Principles on Business and Human Rights.

Grievance Policy

It is the policy of Commemorative Brands, Inc. dba Balfour & Co to treat all clients with fairness and professionalism and to strive for excellence in providing services to clients. COMMEMORATIVE BRANDS INC DBA BALFOUR & COs policy provides clients and their families or legal guardians with the opportunity to express a problem or grievance related to the quality of services.  If you feel you have been treated unfairly, unprofessionally or feel that your rights have been breached, the following procedure should be used.

COMMEMORATIVE BRANDS INC DBA BALFOUR & CO grievance procedure is designed to provide a means for clients to bring a grievance to the attention of COMMEMORATIVE BRANDS INC DBA BALFOUR & CO and to reach a speedy resolution. COMMEMORATIVE BRANDS INC DBA BALFOUR & COs has a strict policy prohibiting retaliation in any form against anyone who files a grievance.

A grievance is defined as any situation or condition that a client thinks is unfair, unjust, or inequitable. In addition, if a client merely states they want to file a grievance, a grievance should be completed.  Under this Client Grievance Procedure, you should submit a grievance in the following sequence:

If you have a grievance, the concern can be discussed with a COMMEMORATIVE BRANDS INC DBA BALFOUR & COs staff. If you decide to speak to a COMMEMORATIVE BRANDS INC DBA BALFOUR & COs staff and an agreement cannot   be reached, you should proceed to the next step of this grievance procedure.  You can also file a grievance without any discussion and proceed to the next step.  Grievance forms can be found at the following on our website at https://www.balfour.com/HelpCenter/About-us/Contact-Us. Click "Grievance Form" on home page

Once notified in writing, COMMEMORATIVE BRANDS INC DBA BALFOUR & COs will initiate an investigation within 10 business days and provide an acknowledgment to you within 14 business days.

COMMEMORATIVE BRANDS INC DBA BALFOUR & COs will report the outcome of the complaint investigation to you within 14 business days after the complaint is received.  If it has not been possible to gather the necessary information that would lead to a resolution by 14 days, you will be notified and given a new date, up to 30 days, by which a resolution or determination will be made.

If for any reason you are unsatisfied with the results, you may contact COMMEMORATIVE BRANDS INC DBA BALFOUR & COs Chief Operating Officer (COO) to further discuss the matter. The COO will conduct a review of the matter and will respond to you in writing within 30 business days.  The COO's decision and recommendations will be final.