Upholding Human Rights and Preventing Child Labour

Respect for human rights is embedded throughout SMG’s operations. Commitments apply to all activities, including the treatment of employees, collaboration with business partners, engagement with communities, as well as stakeholders throughout the value chain. SMG reports on this topic in accordance with Swiss law, including the CO and the DDTrO.

Human Rights Due Diligence

SMG integrates human rights considerations into its compliance and governance structures and regularly assesses its own activities and business relationships through the ERM framework. The latest assessments, including the 2025 DMA, determined that exposure to severe human rights risks is still generally low and indirect due to SMG’s digital business model and the nature of services it procures – primarily, software development. Human rights violations are therefore not considered a material topic for SMG.

Nevertheless, respect for human rights underpins SMG’s vision and core values. As well as complying with national law and binding international obligations, SMG aims to promote international best practice based on the UNGPs, as set out in the CoC. It evaluates human rights and child labour through structured governance processes, with the Group Compliance Officer overseeing adherence to relevant policies and due diligence expectations.

To extend due diligence to the supply chain, SMG formalised supplier expectations on human rights in 2025 through a standard contractual clause. This requires supplier contracts above a certain threshold to comply with applicable laws and SMG’s CoC, which includes respect for human rights. Compliance monitoring is the joint responsibility of Legal & Compliance and Procurement. Relevant suppliers can access the latest CoC via an online link in the contractual clause.

As described in Ethical Business Conduct, employees and external parties can report concerns, including concerns related to human rights, through established channels, with follow-up led by the Group Compliance.

Child Labour

SMG conducts an annual child labour risk assessment in line with CO and DDTrO.²³ The 2024 assessment found no indications or reasonable suspicion of child labour, consistent with SMG’s low inherent risk profile.

SMG continued to improve its processes and introduced an enhanced Child Labour Self-Assessment Guideline in 2025. Under this guideline, subsidiaries in countries classified above “basic risk” according to the UNICEF Children’s Rights in the Workplace Index must complete annual self-assessments,²⁴ so too suppliers that are key to value creation upon conclusion of their contracts. The 2025 assessment was carried out for the relevant subsidiaries and relevant parts of the supply chain in Q1 2026, and showed no indication of potential child labour in connection with services provided to SMG. As a result, SMG is exempt from the due diligence and reporting obligations pursuant to Art. 964k and 964l CO. The results were presented to the RAC in March 2026.

While the overall risk remains low, mechanisms including transparent external reporting, ongoing monitoring, and access to reporting channels support SMG’s long-term commitment to respecting human rights.