Human Rights Policy - Pivotal International

Version 1.1 — Effective May 2026

1. Purpose and Commitment

Pivotal International is committed to conducting business ethically, responsibly, and in a manner that respects and promotes internationally recognised human rights across all aspects of our operations, projects, and business relationships.

As a multidisciplinary design consultancy providing architecture, engineering, planning, project management, and related professional services, we recognise our responsibility to uphold the dignity, equality, health, safety, and well-being of all individuals affected by our activities, including employees, contractors, suppliers, clients, communities, and other stakeholders.

This policy reflects our commitment to:

Respect human rights in accordance with internationally recognised principles, instruments, and conventions;
Prevent and mitigate adverse human rights impacts that we cause, contribute to, or are directly linked to through our operations, projects, products, services and business relationships;
Promote fair, safe, inclusive, and respectful working environments;
Operate with integrity, transparency, and accountability;
Provide effective grievance and remedy mechanisms for those affected by our activities.

2. Governance and Oversight

Board-level accountability for human rights is held by the Chairman of Pivotal International, who oversees the implementation of this policy and reports on human rights matters to the Board of Directors at least annually as part of our corporate governance and enterprise risk management framework.

Human rights responsibilities are integrated and assigned across the organisation:

Chairman and Board of Directors — overall accountability and policy approval;
Executive leadership and senior management — implementation and operational oversight;
Human Resources — workplace standards, training, recruitment, grievance handling;
Health, Safety and Wellbeing function — occupational H&S management and reporting;
Procurement and supply chain management — supplier due diligence and contractual compliance;
Project and operational management teams — project-level risk assessment and stakeholder engagement.

Performance expectations relating to ethical conduct, workplace standards, health and safety, diversity and inclusion, and compliance obligations form part of management accountability and performance evaluation processes.

3. Scope

This policy applies to:

All employees of Pivotal International and its affiliated entities in Ireland, the United Kingdom, the Kingdom of Saudi Arabia, the United Arab Emirates, and elsewhere;
All directors and officers;
All contractors, consultants, temporary workers, and interns;
All suppliers, subcontractors, and business partners operating on behalf of Pivotal International.

Suppliers and business partners are required, through contractual and procurement processes, to uphold standards consistent with this policy throughout their own operations and supply chains.

4. International Standards and References

This policy is informed by and aligned with the following internationally recognised instruments and frameworks:

Core international human rights instruments

Universal Declaration of Human Rights (UDHR);
International Covenant on Civil and Political Rights (ICCPR);
International Covenant on Economic, Social and Cultural Rights (ICESCR);
United Nations Guiding Principles on Business and Human Rights (UNGPs);
UN Global Compact Principles;
OECD Guidelines for Multinational Enterprises;
International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work and the eight ILO Core Conventions (C29, C87, C98, C100, C105, C111, C138, C182), together with ILO Conventions C1, C14 and C30 on working hours and weekly rest.

Instruments protecting specific groups

Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW);
Convention on the Rights of the Child (CRC);
International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families;
UN Declaration on the Rights of Indigenous Peoples (UNDRIP);
UN Guiding Principles on Extreme Poverty and Human Rights;
Protections for refugees, asylum seekers and internally displaced persons under the 1951 Refugee Convention.

Sector-specific and environment-related instruments

Voluntary Principles on Security and Human Rights;
FAO Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security (VGGT);
Stockholm Convention on Persistent Organic Pollutants;
Minamata Convention on Mercury;
Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.

This policy is also aligned with applicable national legislation in each jurisdiction in which Pivotal International operates, including, without limitation, employment, equality, health and safety, anti-modern-slavery, anti-bribery and data protection legislation in Ireland, the United Kingdom, the Kingdom of Saudi Arabia, and the United Arab Emirates.

5. Human Rights Risk Assessment

Pivotal International applies the UN Guiding Principles “cause, contribute, or directly linked to” framework when assessing human rights impacts associated with our operations, projects and business relationships. We undertake risk assessments at least annually and on an ad hoc basis whenever there is a significant change in business activity, geography, or supply chain, and prior to launching new business areas, products, or projects.

Risk assessment covers the following stages of the value chain:

Direct operations and offices in Ireland, the United Kingdom, the Kingdom of Saudi Arabia, the United Arab Emirates and other locations;
Majority-owned and affiliated entities in all countries of operation;
Direct supply chain — suppliers, subcontractors and consultants in a direct contractual relationship with Pivotal International;
Indirect supply chain — suppliers further upstream;
Products, services and project business — the projects we design, manage or deliver on behalf of clients.

Potentially affected groups considered include:

Employees and contract workers in own operations and in affiliated companies;
Employees in the direct and indirect supply chain;
Migrant workers, young workers and apprentices;
Women and persons belonging to ethnic, religious or linguistic minorities;
Indigenous peoples, refugees, asylum seekers and internally displaced persons where relevant;
Local communities affected by Pivotal’s operations, direct supply chain or indirect supply chain;
Business partners and customers, and other stakeholders such as local residents.

Risks identified may include child labour; forced or compulsory labour; modern slavery and human trafficking; discrimination and harassment; unsafe working conditions; excessive working hours; wage and labour rights violations; restrictions on freedom of association; community health and safety concerns; diversity, equity and inclusion issues; harmful environmental impacts; unlawful eviction and land appropriation; misuse of security forces; corruption and bribery; and data protection and privacy concerns.

Identified risks are prioritised according to:

Severity of potential impact;
Irreversibility of potential impact;
Scale and number of potentially affected persons;
Likelihood of occurrence;
Nature of the causal contribution of Pivotal International to the risk or violation (cause, contribute, or directly linked to);
Ability of Pivotal International to influence the party directly responsible;
Ability to remediate or mitigate impacts;
Potential impact on the company’s reputation and possible legal implications.

Risk analysis draws on internal discussions, dialogue with business partners and (where relevant) potentially affected persons or their legitimate representatives, qualitative document research, internal and external data, and external expertise on human rights.

6.Workplace Standards

Pivotal International commits to the following workplace standards in all locations of operation and expects equivalent standards from suppliers and business partners.

6.1 Non-discrimination, equal opportunity and equal pay

Pivotal International prohibits discrimination, harassment, victimisation and bullying at work and in recruitment on the grounds of race, colour, sex, gender identity, religion or belief, political opinion, national extraction, social origin, age, disability, sexual orientation, marital or civil partnership status, family status, pregnancy or maternity, or any other protected characteristic under applicable law or under ILO Convention 111.

We are committed to providing equal pay for equal work in accordance with ILO Convention 100 and CEDAW, and to providing equal opportunities throughout all levels of employment including recruitment, training, promotion, development and compensation. Our regular HR processes review pay and progression to identify and address any inequalities, and we are committed to taking corrective action where disparities are identified.

6.2 Freedom of association and collective bargaining

Pivotal International respects the right of all employees to freedom of association and to collective bargaining, in accordance with ILO Conventions 87 and 98 and applicable national legislation. Employees are free to join (or refrain from joining) trade unions or workers’ representative bodies of their choosing, and we will not discriminate, retaliate against or disadvantage any employee or worker on the grounds of trade union membership or lawful collective activity. Where collective bargaining structures are in place, we engage with them in good faith.

6.3 Living wage

Pivotal International is committed to paying all employees of its own operations at least a living wage. Compensation will at minimum meet, and where reasonably practicable exceed, the higher of (a) the statutory minimum wage in each jurisdiction of employment, and (b) an independently benchmarked living wage appropriate to the local cost of living (for example, the Living Wage Ireland benchmark in the Republic of Ireland). The definition of a living wage is reviewed regularly. We also expect direct suppliers to pay their workers a wage that meets at minimum the applicable statutory or industry standard and that is paid directly, in full, and on time.

6.4 Working hours, breaks and rest periods

Working hours, weekly rest, daily breaks and annual leave for Pivotal employees comply with applicable national legislation and with the relevant ILO Conventions (ILO C1 and C30 on hours of work, and ILO C14 on weekly rest in industry). Overtime, where it occurs, is voluntary, properly recorded and properly compensated. When allocating work or setting deadlines, Pivotal assesses whether commitments can be met within reasonable working hours, and adjusts scoping, resourcing or timelines rather than requiring sustained excessive hours.

6.5 Health, safety and wellbeing

Pivotal International is committed to maintaining safe and healthy working environments across all operations, offices and projects, and to integrating health and safety standards into procurement and project delivery.

Health and safety metrics monitored and reported include:

Fatal accident rate (FAR) and fatal incident rate (FIR);
Total recordable injury rate (TRIR);
Lost time injury (LTI) and lost time injury frequency (LTIF / LTIFR);
Recordable injuries — fatalities, lost work-day cases, restricted work-day cases, medical treatment cases;
Near-miss reporting, safety observations and inspections;
Training completion rates;
Occupational health incidents and employee wellbeing initiatives.

Corrective and preventive actions are implemented promptly where risks or incidents are identified.

7. Prevention of Child Labour, Forced Labour and Modern Slavery

Pivotal International maintains zero tolerance for child labour, forced labour, bonded labour, human trafficking, modern slavery or any form of exploitation, in our own operations and across our supply chain.

Preventive measures include:

Verification of legal working age (age verification) for workers recruited into our own operations, in accordance with ILO Conventions 138 and 182;
Requiring direct suppliers and third-party service providers to verify the age of their workers;
Supplier due diligence and screening prior to engagement;
Ethical procurement procedures and fair recruitment practices;
Reporting and whistleblowing mechanisms (see Section 11, Grievance Mechanism);
Monitoring and audits of subcontractors and labour providers, where practicable;
Supplier training and capacity-building on labour rights.

Pivotal’s standard supplier contractual terms require suppliers to:

Prohibit suppliers and any third-party intermediaries from imposing financial burdens on job seekers and workers, including recruitment fees and related costs (“Employer Pays Principle”);
Pay workers directly, in full and on time, in accordance with applicable laws and contracts;
Refrain from retaining workers’ personal documents (passports, identity papers, work permits) or restricting their freedom of movement;
Refrain from requiring workers to use employer-provided accommodation as a condition of employment, except where freely accepted and in compliance with applicable standards;
Comply with all applicable child labour and forced labour legislation and with this policy.

8.Protection of Specific Groups

Pivotal International commits particular attention to the rights of groups and populations who may face heightened vulnerability or marginalisation. In addition to the general commitments in this policy, we specifically commit to respect:

Women — in accordance with CEDAW (see Section 6.1 on equal pay and equal opportunities);
Children — in accordance with the Convention on the Rights of the Child (see Section 7 on prohibition of child labour);
Migrant workers and their families — in accordance with the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, including the Employer Pays Principle and prohibition on retention of personal documents (see Section 7);
Indigenous peoples — in accordance with UNDRIP, including the principle of free, prior and informed consent (FPIC) where Pivotal’s project activities may affect indigenous lands, territories or resources;
Persons belonging to national, ethnic, religious or linguistic minorities;
Refugees, asylum seekers and internally displaced persons, where their employment or community involvement is connected to our operations or projects;
Persons living in extreme poverty, in line with the UN Guiding Principles on Extreme Poverty and Human Rights;
Persons with disabilities, in accordance with applicable national and international standards on accessibility and inclusion.

9. Environmental and Community Rights

Pivotal recognises that environmental harm can directly affect human rights — particularly the rights to health, water, food, an adequate standard of living, and culture. In our own operations and in the projects, we design and manage on behalf of clients; we commit to the following standards.

9.1 Environmental pollution prevention

Pivotal will not cause, and will design and specify so as to avoid, harmful soil change, water pollution, air pollution, harmful noise emission, or excessive water consumption that would impair an individual’s natural basis for food and drinking water, or impair access to sanitary facilities, where such impacts are within our control or influence. Where impacts cannot be entirely avoided, we will design mitigation and minimisation in accordance with applicable environmental legislation and good industry practice.

9.2 Land tenure and prevention of unlawful eviction

Pivotal will not engage in, support, or knowingly enable unlawful eviction, or the unauthorised appropriation of land, forests, or water. In master planning, urban design, landscape and large-scale development projects, we will conduct land-tenure due diligence and recognise tenure rights — including informal and customary rights — in accordance with the FAO Voluntary Guidelines on the Responsible Governance of Tenure (VGGT). Where projects may affect indigenous lands, territories or resources, we will support the application of free, prior and informed consent in line with UNDRIP.

9.3 International environmental conventions

Pivotal is committed to the principles of the following international environmental instruments and will, in materials specification, project design, and procurement, support compliance with:

Stockholm Convention on Persistent Organic Pollutants — avoiding the use of persistent organic pollutants where alternatives exist;
Minamata Convention on Mercury — avoiding the use of mercury and mercury-containing products where alternatives exist;
Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal — designing for proper handling, segregation and disposal of construction, demolition and refurbishment wastes.

9.4 Protection of legally established rights and positions

Pivotal will not act to impair legally established rights and positions — including legally established property rights, tenure rights, customary rights, easements, and protected legal interests of communities or individuals — through our project activities.

10. Use of Security Forces

Where Pivotal International engages in public or private security services, or where security services are deployed in connection with our project sites, we will apply the Voluntary Principles on Security and Human Rights. In particular, we will:

Conduct a risk assessment before engaging security services, considering the human rights record of providers and the operational context;
Include human rights expectations and proportionate use-of-force requirements in contracts with security providers;
Ensure that security personnel are appropriately instructed and trained, including on this policy, to prevent interference with human rights through lack of instruction or control;
Provide accessible channels for affected persons to report concerns about the conduct of security personnel through our Grievance Mechanism (Section 11);
Investigate any allegations of misuse of security forces and take appropriate corrective and remedial action.

11. Grievance Mechanism

Pivotal International provides a formal, confidential, and accessible grievance mechanism that is open to all potentially affected parties — including our own employees, employees in affiliated companies, workers in our direct and indirect supply chain, local communities affected by our operations or projects, business partners, customers, and other stakeholders such as local residents.

How to raise a concern:

By email — confidential reports may be sent to [email protected];
By post — addressed in confidence to the Chairman, Pivotal International, Studio 14, The Atrium, Maritana Gate, Canada Street, Waterford, Ireland, X91 A250;
Verbally — to a line manager, HR representative, project manager, site supervisor, or any director;
On project sites — via project notice boards displaying the email channel and contact details in English and, on projects in the Kingdom of Saudi Arabia and the United Arab Emirates, in Arabic.

Reports may be made anonymously. Pivotal International strictly prohibits any form of retaliation or detrimental treatment against any person who, in good faith, raises a concern or participates in an investigation.

The grievance mechanism covers all topics addressed in this policy, including (but not limited to) child labour; forced labour, modern slavery and human trafficking; occupational health and safety; freedom of association and collective bargaining; discrimination, harassment, diversity and inclusion; living wage; environmental pollution; unlawful eviction; misuse of security forces; protection of legally established rights; and compliance with the Minamata, Stockholm and Basel Conventions.

The procedure is designed to be accessible to affected parties by (a) involving stakeholder representatives in the design and review of the procedure where appropriate; (b) providing multilingual access on international project sites; (c) avoiding technical or legal language; (d) protecting the identity of complainants; and (e) committing to a defined response and resolution timeframe. The procedure is published on www.pivotalinternational.com.

12. Mitigation and Remediation

Where adverse human rights impacts are identified — whether through risk analysis, the grievance mechanism, audits, or other means — Pivotal International will:

Investigate concerns promptly and fairly;
Mitigate identified risks and stop or prevent ongoing impacts;
Implement corrective action plans with assigned responsibilities and timelines;
Engage affected stakeholders and their representatives in the design and review of remedial measures where appropriate;
Provide for, contribute to, or co-operate in remediation proportionate to our involvement in the impact (cause, contribute, or directly linked to);
Improve policies, controls and oversight to prevent recurrence;
Monitor the effectiveness of measures taken (see Section 14).

13. Training and Awareness

All Pivotal International employees receive baseline human rights and Code of Conduct training as part of induction, and refresher training at regular intervals. Additional, targeted training is provided to employees in higher-risk roles, geographies, or functions, including:

Senior leadership and management — human rights governance and accountability;
Human Resources personnel — anti-discrimination, anti-harassment, equal pay, recruitment;
Procurement and supply chain teams — ethical procurement, supplier due diligence, modern slavery awareness;
Project managers and operational staff — project-level risk assessment, community engagement, security and health & safety;
Employees deployed to higher-risk geographies — context-specific human rights briefings.

Suppliers, contractors and consultants may, where appropriate, be required to complete training or attestations relating to this policy.

14. Supplier and Business Partner Standards

Pivotal International integrates human and labour rights factors into its procurement and business-partner management processes, including:

Integration of human and labour rights clauses into supplier contracts and supplier codes of conduct;
Human and labour rights risk analysis prior to supplier engagement and during supplier review;
Supplier assessment on human, labour and health & safety practices;
Training of buyers and procurement staff on human and labour rights issues in the supply chain;
On-site audits of suppliers where practicable and proportionate to risk;
Capacity-building and collaborative workshops with key suppliers to improve performance;
Preference, where appropriate, for suppliers who demonstrate strong human rights performance through audits, certifications, or assessments.

Where a supplier or business partner is found to be in breach of this policy, Pivotal will engage with them to identify root causes, agree corrective action with timelines, and verify remediation. Where corrective action is refused or unsuccessful, Pivotal reserves the right to terminate the business relationship.

15. Organisational Integration

Human rights considerations are integrated into:

Corporate governance and board oversight;
Enterprise risk management;
Procurement and supplier management;
Recruitment and HR practices;
Health, safety and wellbeing systems;
Project planning, design and delivery;
Compliance and ethics programmes;
Diversity, equity and inclusion initiatives.

When implementing measures, Pivotal considers (a) the assignment of responsibilities; (b) the formulation of objectives for measures implemented; (c) the internal and (where appropriate) external communication of those objectives; and (d) compliance verification mechanisms.

16. Reporting, Monitoring and Record Retention

Pivotal International monitors the effectiveness of this policy and of measures taken to prevent or mitigate adverse human rights impacts. Effectiveness checks are carried out at least once a year, and on an ad hoc basis when there is a significant change in the risk situation.

Within the framework of effectiveness monitoring, we enter into dialogue with (potentially) affected parties or their legitimate representatives where appropriate, and use their feedback to refine our approach.

Pivotal reports externally on the implementation of human rights due diligence at least annually. Reporting covers:

The risk analysis procedure and outcomes;
Identified human rights aspects and any actual adverse effects;
Measures taken and their effectiveness;
Defined responsibilities within the company.

The annual report is made publicly available on www.pivotalinternational.com.

Records relating to human rights risk analysis, preventive and remedial measures, supplier assessments, training, and grievances received are retained for a minimum of seven (7) years, subject to applicable data-protection legislation.

17. Continuous Improvement

Pivotal International is committed to continuous improvement in the management of human rights risks and impacts. We will review this policy and related procedures at least annually, and update them in response to changes in the law, in international standards, in our risk profile, or in light of feedback from employees, affected stakeholders, and external assessments.

18. Approval

This Human Rights Policy Statement is approved by the Chairman on behalf of the Board of Directors of Pivotal International and applies across all company operations and business relationships.

Version: 1.1
Effective Date: May 2026
Supersedes: Version 1.0 (May 2026)
Review Cycle: Annual, at minimum
Record Retention: Minimum 7 years
Owner: Chairman, Pivotal International
Grievance contact: [email protected]

Signed on behalf of Pivotal International:

Kevin Rudden
Chairman

Pivotal International

Date: 15 May 2026