Human Rights in the value chain

Yes. The Roche Supplier Code of Conduct, required to be included in every Roche contract, incorporates the five auditable key principles of the Pharmaceutical Supply Chain Initiative (PSCI):

• Ethics: Suppliers shall conduct their business responsibly, ethically, and act with integrity.

• Human Rights: Suppliers shall be committed to respect the human rights of internal and external stakeholders ensuring to treat them with dignity and respect.

• Health and Safety: Suppliers shall provide a safe and healthy environment and support the wellbeing of workers.

• Environment: Suppliers shall operate in an environmentally responsible and efficient manner to minimize adverse impacts on the environment, and to help their own suppliers do the same. Suppliers are encouraged to conserve natural resources, reduce greenhouse gas (GHG) emissions, preserve biodiversity and clean water, and minimize and control the use of hazardous materials.

• Governance and Management Systems: Suppliers shall use appropriate systems to conduct due diligence on risk and impact, monitor legislation, set priorities, assign responsibility, adopt risk-mitigation measures, and facilitate continual improvement and compliance.

Readexpectations related to “Human Rights”.

Yes. We have a formal process and methodology for assessing our suppliers in order to identify those at higher risk for Human Rights violations due to:

• Being associated with an industry that is likely to employ vulnerable populations

• Being located in a region at higher risk for Human Rights violations, per respected Human Rights indices

• Being associated with government, media or internal reports of alleged behavior or operations that indicate real or potential noncompliance with the Roche Supplier Code of Conduct

This Human Rights risk assessment is embedded in our standardized due diligence process conducted before engaging new suppliers. It is used to identify suppliers for inclusion in our Supplier Sustainability Assurance Visit (SSAV) program, through which we directly evaluate supplier Human Rights compliance.

In 2024 we conducted 118 sustainability visits (SSAVs) during which we identified 284 Human Rights related findings. The findings included excessive overtime and incorrect overtime compensation, improper maintenance of HR and payroll documentation, delayed or improper payment calculation of wages. Each of the audited suppliers with identified findings was required to establish and make progress on a formal corrective action plan

Formal SSAV follow-up ensures progress on, and closure of the audit findings. Roche’s expectation that suppliers adhere to our Human Rights protection requirements is non-negotiable.

Roche has set a global goal to reduceby transitioning our fleet to electric vehicles. Because we understood the Human Rights risks associated with the mining of conflict minerals used in electric vehicles, our Global Procurement fleet team established Human Rights criteria for selecting electric vehicle providers. Electric vehicle manufacturers must:

1. Accept Roche’s Supplier Code of Conduct, including Roche’s right to audit electric vehicle manufacturers for related labor and Human Rights compliance,

2. Be in full compliance with the OECD Guidance on Responsible Supply Chains,

3. Have an ethical mineral sourcing code of conduct that protects miners and families, and

4. Have a recycling program for conflict minerals.

Electric vehicle manufacturers who cannot meet these requirements are excluded from opportunities related to our fleet.