Divine Chocolate is part of the Weinrich Group and is committed to protecting human rights and the environment across our own operations and throughout our supply chain. As a company co-owned by cocoa farmers, these commitments sit at the heart of how we do business.

The following statements set out our approach to human rights and environmental due diligence, and our commitment to preventing modern slavery in all its forms. Both apply across the entire Weinrich Group (Ludwig Weinrich GmbH & Co KG, EcoFinia GmbH and Divine Ltd), with each company responsible for implementing these standards within its own operations and areas of responsibility. These statements are reviewed and updated annually.

Policy Statement on Human Rights and Environmental Due Diligence

1. Scope

As a company, we assume responsibility for protecting human rights and preserving our natural environment. Therefore, we are expressly committed to identifying, preventing and minimizing human rights and environmental risks within our own operations and throughout our supply chain, including the associated risks for our business.

This Policy Statement describes our approach to implementing human rights and environmental due diligence (HREDD) and forms an integral part of our group-wide sustainability management system. It applies to the entire Weinrich Group (Ludwig Weinrich GmbH & Co KG, EcoFinia GmbH and Divine Ltd). The respective companies are responsible for implementing HREDD within their own operations and areas of responsibility. This Policy Statement is reviewed annually and updated as required.

2. Commitment to Human Rights

We are committed to protecting human rights. By human rights, we mean the rights to which every person is entitled by virtue of being born human, regardless of their status in the state, society, family, profession, religion or culture.

We are guided by the following internationally recognized standards and frameworks, which define the principles of human rights due diligence:

• United Nations Universal Declaration of Human Rights
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises and OECD-FAO Guidance for Responsible Agricultural Supply Chains
• ILO Core Labour Standards
• UN Convention on the Rights of the Child
• UN Convention on Women's Rights

We tolerate no form of forced labour, modern slavery, human trafficking, child labour, discrimination, inhumane working conditions or restrictions on freedom of association.

3. Environmental Commitment

We are committed to minimizing the negative impacts of our business activities on the environment and climate, in particular through:

• Efficient and responsible use of resources
• Reduction of emissions and waste
• Responsible handling of hazardous substances
• Climate-friendly production processes
• Protection of natural ecosystems and biodiversity
• Continuous improvement of our environmental performance

4. Industry-Specific Sustainability Risks

As part of our risk assessment, we have identified the following key sustainability risks that require particular attention in the chocolate sector:

• Wages and remuneration in the supply chain, including living income for smallholder farmers
• Child labour and forced labour
• Use of pesticides in the cultivation of agricultural raw materials
• Deforestation in raw material sourcing regions

5. Implementation at Weinrich

Our due diligence management system comprises the following elements: risk assessments of high-risk raw materials and our company location, Supplier Code of Conduct, supplier data collection and assessment, access to a grievance mechanism, as well as preventive and corrective measures.

As part of our Sustainability Strategy, we define objectives to continuously improve our performance in the areas of human rights and environmental protection and regularly monitor progress against these objectives.

To assess risks, we collect relevant information throughout our supply chains. Through a hotspot analysis, we regularly identify high-risk raw materials within our supply chains. Based on this analysis, we conduct specific risk assessments for identified high-risk raw materials (cocoa, nuts and sugar) to enable the implementation of preventive and corrective measures.

Overall responsibility for implementing human rights and environmental due diligence lies with the CEO. The Sustainability Department acts as the Human Rights Officer and is responsible for the operational management of these topics.

6. Expectations Towards Suppliers and Business Partners

The Weinrich Group fully supports human rights and expects all suppliers and business partners to ensure:

• Respect for human rights
• Safe and fair working conditions
• Environmentally sound and climate-friendly production processes
• Cooperation in the implementation of our human rights and environmental due diligence requirements

We further expect our suppliers to promote these requirements throughout their own supply chains.

We communicate our detailed expectations to suppliers and business partners through our Supplier Code of Conduct. The Code of Conduct specifies our requirements and is a key component of our due diligence system. Risks are continuously assessed. When risks or violations are identified, we rely on dialogue, the implementation of preventive measures, corrective action, and — if necessary — consequences, up to and including the termination of the business relationship.

7. Grievance Mechanism

Internal and external stakeholders may confidentially report human rights-related or environmental risks or violations within our supply chains or at our own operations to our Compliance Team, while benefiting from effective protection against discrimination. Reports can be submitted by e-mail to compliance@weinrich-schokolade.de or through the Complaint Form available on our website. Information obtained through the grievance mechanism is used to improve our risk assessments and due diligence processes.

8. Reporting

We report on our activities and progress in implementing human rights and environmental due diligence in our Sustainability Report. We ensure transparency regarding compliance with our due diligence obligations and provide further relevant information to our business partners upon request. In addition, we undergo external assessment by EcoVadis.

Modern UK Slavery Act Statement

Overview

This statement outlines the approach of the entire Weinrich Group (Ludwig Weinrich GmbH & Co KG, EcoFinia GmbH and Divine Ltd) to prevent and address modern slavery, including forced labour and human trafficking, in its business activities and supply chains. The respective companies are responsible for implementing human rights and environmental due diligence within their own operations and areas of responsibility.

This statement is published in accordance with the Modern UK Slavery Act 2015. We recognise that modern slavery can occur in global supply chains of any kind, particularly in complex agricultural supply chains. We are committed to identifying, preventing and mitigating risks related to modern slavery across our operations and upstream supply chain.

Our Approach to Preventing Modern Slavery

Our approach to preventing modern slavery is based on our human rights and environmental due diligence (HREDD) system as outlined in our Policy Statement on HREDD.

We are committed to respecting internationally recognised human rights standards, including:

• United Nations Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• OECD-FAO Guidance for Responsible Agricultural Supply Chains
• ILO Core Labour Standards

To implement these principles, we have established a risk-based due diligence process, including risk analysis, monitoring and remediation. It contains the following elements:

• Policy Statement on HREDD
• Supplier Code of Conduct defining requirements for our suppliers and business partners
• Grievance mechanism accessible to internal and external stakeholders

Measures to Prevent Modern Slavery

To prevent modern slavery, we implement a range of measures across our operations and supply chains:

• Sourcing only certified cocoa (since January 2014) with certifications such as Naturland, EU Organic, Fairtrade and Rainforest Alliance
• Implementation of our Supplier Code of Conduct, which prohibits forced labour, modern slavery and human trafficking
• Risk analysis, including structured supplier questionnaires, for high-risk raw materials
• Increasing transparency and traceability in our supply chains, particularly for cocoa
• Direct sourcing relationships with cooperatives in selected origin countries
• Implementation of sustainability projects in sourcing countries
• Participation in multi-stakeholder initiatives such as the German Initiative on Sustainable Cocoa (GISCO)

We have a zero-tolerance approach to modern slavery in all our business activities and supply chains. We take measures to ensure that products supplied by Weinrich are not linked to modern slavery, including forced labour and human trafficking.

Sector-Specific Risks and Actions

We recognise that the risk of modern slavery is particularly relevant in global agricultural supply chains. Based on our risk analysis, key risk areas include:

• Wages in the supply chain (including living income for smallholder farmers)
• Child labour and forced labour
• Use of pesticides in raw material cultivation
• Deforestation in growing regions for raw materials

To address these risks, we aim to continuously improve supply chain transparency and increase traceability of our raw materials. We also support and implement projects that contribute to improving working and living conditions in sourcing regions.

Monitoring and Effectiveness

Weinrich follows a risk-based approach to monitor the effectiveness of its measures to prevent modern slavery. This includes:

• Regular risk analysis
• Engagement with suppliers through dialogue and follow-up processes

We use the insights gained through our due diligence processes to continuously improve our risk management.

Awareness

We have communicated an internal Code of Conduct which defines our values and guidelines for working together and collaborating with customers and business partners.

Approval and Publication

This statement has been approved by the management of Ludwig Weinrich GmbH & Co. KG and will be reviewed and published on an annual basis.

Jelena Radeljić, Sustainability Manager
Cord Budde, CEO