Human Rights Risk Analysis

1.PURPOSE

This document describes Scorp Group Ltd's systematic procedure for identifying, assessing, and prioritising potentially negative impacts of its own operations and business relationships on human rights — hereinafter referred to as the Human Rights Risk Analysis (HRRA).

The HRRA ensures that Scorp Group fulfils its responsibility to respect human rights across its value chain, in line with the following international frameworks:

2.SCOPE

The HRRA covers:

3.DEFINITIONS

Human Rights Impact: Any actual or potential adverse effect on individuals' or communities'

human rights resulting from Scorp Group's activities or business

relationships.

Salient Human Rights Risk: The human rights at risk of the most severe negative impact through

Scorp Group's activities or relationships (per UNGPs and UNGP

Reporting Framework).

Risk Analysis (HRRA): The structured, systematic process of identifying and assessing

human rights risks across Scorp Group's value chain.

Cause: Scorp Group directly causes an impact through its own activities.

Contribution: Scorp Group contributes to an impact caused by another party.

Direct Linkage: Scorp Group's operations or products are linked to an impact by

a business relationship, even without direct causation.

4.HUMAN RIGHTS RISK ANALYSIS PROCESS

STEP 1 — ESTABLISH CONTEXT & SALIENT ISSUES IDENTIFICATION

1.1 Scorp Group's Sustainability Team, in collaboration with Legal, HR, and Procurement, conducts an annual review to identify the salient human rights issues most relevant to its business model, sector, and geographies of operation.

1.2 Salient issues are identified through:

1.3 Current salient human rights issues identified for Scorp Group include:

Reference Standard: UNGP Principle 17; UNGP Reporting Framework — Section B (Salient Issues);

OECD DDG Step 1 (Embed Responsible Business Conduct).

STEP 2 — HUMAN RIGHTS RISK IDENTIFICATION

2.1 Scorp Group maps its full value chain annually, identifying all entities and activities that could cause, contribute to, or be directly linked to human rights impacts.

2.2 Risk identification tools and methods used include:

All Tier 1 suppliers complete Scorp Group's SAQ covering the ILO Core Conventions,

working conditions, health & safety, grievance mechanisms, and management systems.

Independent social compliance audits are conducted using recognised standards:

All supplier countries and business sectors are screened using:

Automated and manual media screening for human rights incidents linked to

specific suppliers, partners, or geographies. Conducted quarterly for high-risk

suppliers.

Worker complaints, hotline reports, and audit non-conformances are reviewed

as early warning indicators of systemic human rights risks.

Periodic consultation with workers' representatives, local communities, NGOs,

and industry associations to surface risks not captured by formal assessments.

Reference Standard: OECD DDG Step 2 (Identify and Assess Adverse Impacts);

UNGP Principles 18-19; LkSG Section 5 (Risk Analysis).

STEP 3 — HUMAN RIGHTS RISK ASSESSMENT & PRIORITISATION

3.1 Identified risks are assessed and prioritised using a structured Risk Scoring Matrix based on two dimensions aligned with the UNGPs:

SEVERITY (S): Assessed across three sub-criteria:

LIKELIHOOD (L): Probability that the risk materialises, based on:

3.2 Risk Score = Severity (1-5) x Likelihood (1-5), producing a score of 1-25:

Score 1-6: LOW RISK — Monitor; annual review

Score 7-12: MEDIUM RISK — Active monitoring; bi-annual review; supplier engagement

Score 13-18: HIGH RISK — Priority action; third-party audit within 6 months; CAP

Score 19-25: CRITICAL RISK — Immediate escalation; on-site audit within 30 days;

potential suspension

3.3 Scorp Group also applies a vulnerability lens, giving additional weight to risks affecting:

3.4 All risks are documented in Scorp Group's Human Rights Risk Register, maintained in the

Supplier Management System (SMS) and updated at minimum annually, or upon identification

of a new significant risk.

Reference Standard: UNGP Principle 24 (Prioritisation); OECD DDG Step 2;

ISO 26000 Section 6.3.4 (Due Diligence); LkSG Section 5(2).

STEP 4 — RISK RESPONSE & MITIGATION

4.1 Based on risk scores, Scorp Group deploys appropriate risk response measures:

LOW RISK:

MEDIUM RISK:

HIGH RISK:

CRITICAL RISK:

4.2 For risks caused or contributed to by Scorp Group's own operations, the relevant

Business Unit Head and HR Director are responsible for developing and implementing

corrective measures within 60 days of identification.

Reference Standard: OECD DDG Step 3 (Cease, Prevent or Mitigate);

UNGP Principles 19, 22; LkSG Sections 6-7.

STEP 5 — TRACKING, MONITORING & REVIEW

5.1 Scorp Group tracks the effectiveness of its risk mitigation measures through:

Key Performance Indicators (KPIs):

5.2 The Human Rights Risk Register is reviewed:

5.3 The effectiveness of the HRRA procedure itself is reviewed annually by the CSO,

with results reported to the Board of Directors.

Reference Standard: OECD DDG Step 4 (Track Implementation and Results);

UNGP Principle 20; GRI 414-2; LkSG Section 10 (Documentation).

STEP 6 — COMMUNICATION & REPORTING

6.1 Scorp Group communicates the results of its Human Rights Risk Analysis through:

Disclosures aligned with:

Individual suppliers are informed of their risk assessment results, required

corrective actions, and performance scores through the Supplier Management System.

Where required by applicable law (e.g. LkSG, UK Modern Slavery Act, French Duty

of Vigilance Law), Scorp Group publishes statutory disclosures on human rights

due diligence outcomes.

Summary findings are shared with relevant civil society stakeholders, workers'

representatives, and affected communities through regular dialogue.

Reference Standard: OECD DDG Step 6 (Communicate); UNGP Principles 20-21;

LkSG Section 10; GRI 2-27.

5.ROLES AND RESPONSIBILITIES

Chief Sustainability Officer (CSO):

Sustainability Team:

Procurement Team:

Legal & Compliance:

HR Department:

Business Unit Heads:

PSRC (Procurement & Sustainability Review Committee):

6.RECORD KEEPING

7.RELATED DOCUMENTS

8.INTERNATIONAL STANDARDS REFERENCED

Next Review: June 2026