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# Human Rights Policy

Purpose

The Andersons, Inc., strives to conduct business in accordance with our Statement of Principles. We believe that, through our collective action, we greatly magnify the impact of our individual efforts to provide extraordinary service to our customers, help each other improve, support our communities, and increase the value of our company. We also believe that profit or personal gain must never come at the expense of personal integrity or the public welfare. We expect to do business with others who share our values and conduct business with the same level of integrity.

Scope

This policy applies to all employees and all business operations.

Policy

1. Human Rights

1.1 Respect for human rights is a fundamental value of The Andersons. We strive to respect and promote human rights in our relationships with our employees and suppliers. We are dedicated to protecting the rights, safety, and well- being of all people and communities, and to sustainable use of resources in our direct operations and our supply chain.

1.2 We strive to provide a workplace free of discrimination, harassment or other unfair or disrespectful treatment, and prohibit retaliation for concerns raised in good faith.

1.3 The health and safety of our employees is of high importance. We work to provide a safe and healthy workplace and comply with applicable health and safety laws and regulations, as well as internal requirements, and ask each employee to take personal responsibility for their own safety and the safety of others by complying with safety requirement and instructions, and by recognizing and reporting potentially unsafe conditions.

1.4 The Andersons is an equal opportunity employer. We encourage applications from suitably qualified and eligible candidates regardless of sex, race, national origin or ancestry, disability, age, veteran status, sexual orientation, gender identity, religion or belief, marital status, or pregnancy and maternity. Our aim is to employ people who reflect the diverse nature of society. We strive to provide an inclusive environment where individuality is celebrated, and we can unleash the potential of a brilliant mix of people.

1.5 We respect the rights of indigenous and local communities to give or withhold their free, prior and informed consent to operations on lands to which they hold legal rights.

1.6 We respect the right to safe and clean drinking water and sanitation in our operations and supply chain. Where possible, we strive to work collaboratively with stakeholders to improve working, environmental and safety conditions in agricultural supply chains.

2. Fair Employment

2.1 We do not:

- Charge fees to jobseekers in exchange for employment or use labor brokers who charge such fees.
- Withhold collateral in the form of money, identification or other personal belongings – without workers’ consent – as a condition of employment.
- Discriminate in employment-related decisions.

2.2 We do:

- Have appropriate measures in place to ensure eligibility for employment.
- Maintain systems and procedures designed to keep workers safe and protect them from occupational hazards, harassment and abuse.
- Compensate and schedule workers in accordance with all applicable local laws and regulations – including those pertaining to minimum age, minimum wage and hours worked – and provide working conditions that comply with applicable laws and industry standards.
- Respect workers’ rights, including freedom of association and collective bargaining.

3. Anti-Slavery and Human Trafficking

3.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery, all forms of forced or bonded labor and any form of human trafficking. (See Appendix for full definition of forced or bonded labor.)

3.2 We expect the same high standards from all of our contractors, suppliers and other business partners.

3.3 We do not hire individuals under 18 years of age for positions in which hazardous work is required. (See Appendix for full definition of child labor.)

4. Compliance

4.1 Employees working with contractors, suppliers or other third parties are responsible for making them aware of The Anderson’s position with regard to human rights and fair employment.

4.2 Employees should notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future at the earliest possible stage.

4.3 If an employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, it should be raised with their manager.

4.4 Reports also can be made through The Andersons Ethics Call Line at: www.lighthouseservices.com/andersonsinc. Reports through the Call Line may be made anonymously.

5. Breaches of this policy

5.1 Any employee who breaches this policy may face disciplinary action, up to and including termination of employment.

5.2 We may terminate our relationship with other individuals and organizations working in our supply chain if we find that their behavior and activities do not comply with this policy.

Appendix

Forced Labor

All work or service which is exacted from any person under the threat of any penalty and for which the said person has not offered himself voluntarily.

Child Labor

Work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development.

- This includes work that

- Is mentally, physically, socially or morally dangerous and harmful to children; and
- Interferes with their schooling by depriving them of the opportunity to attend school, obliging them to leave school prematurely, or requiring them to attempt to combine school attendance with excessively long and heavy work.

- This includes the worst forms of child labor listed in Convention 182 of The General Conference of the International Labour Organization, and specifically:

- All forms of slavery or practices similar to slavery, such as the sale and trafficking of children, debt bondage and serfdom and forced or compulsory labor, including forced or compulsory recruitment of children for use in armed conflict;
- Work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children.

Internal – These additional policies support and complement this policy:

- Standards of Business Conduct and Response Program
- Open Door Policy
- Harassment Free Workplace
- Payroll Safe Harbor
- Life Critical Policy
- Statement of Principles

External – This policy is based on company values and these external publications:

- International Labour Organization (ILO) Conventions 29, 105, 138 and 182
- United Nations (UN) Universal Declaration of Human Rights
- UN Guiding Principles on Business and Human Rights
- UN General Assembly Resolution A/RES/64/292

May 2021