Human Right's Policy

April 2026

This policy applies to all employees or individuals engaged by the World of Books Group, including our operations in the United Kingdom, the United States, and Hungary.

This policy is non-contractual and may be amended or withdrawn to reflect any changes in law, regulation, or Company practice in the jurisdictions in which we operate. This policy complies with applicable employment law across all relevant territories and will be updated as required to reflect statutory changes.

Introduction

At World of Books, we believe that business and human rights go hand in hand. We are committed to respecting the rights of everyone connected to our operations, including our employees, supply chain partners, charities and goodwill, and the communities we serve.

This policy sets out our commitments to respecting, assessing, and remediating human rights impacts connected to our business activities. It is grounded in three internationally recognised frameworks — set out in full later in this policy — which together define what respecting human rights means in practice: fair treatment, safe and decent work, and freedom from forced or child labour, across our operations and our supply chain.

Our Commitments

Commitment to Respect Human Rights

World of Books Group commits to respecting internationally recognised human rights wherever we operate. We seek to avoid infringing on the human rights of others and to address adverse human rights impacts with which we are involved. Our respect for human rights is embedded in how we treat our employees, how we manage our supply chain, and how we engage with the communities in which we operate.

Commitment to Assess Human Rights Impacts

We commit to understanding and keeping under review the potential and actual human rights impacts connected to our own operations and our value chain, with a focus on risks to people. This is a shared responsibility across the functions whose work touches these areas — Sustainability, the People Team, Health & Safety and Facilities, Finance (Purchasing), and Operations — coordinated so that the areas of greatest impact are understood and acted upon.

Where we identify areas of concern, we commit to addressing them — integrating what we learn into relevant business decisions, assigning clear ownership for any follow-up, and tracking progress over time.

Commitment to Remediate Negative Impacts

Where World of Books Group has caused or contributed to a negative human rights impact, we commit to providing or cooperating in remediation. This may include:

Taking corrective action within our own operations
Working with suppliers or partners to address identified issues
Supporting affected individuals or communities in accessing appropriate remedies

We will ensure that employees and other stakeholders are able to raise concerns without fear of retaliation. Concerns can be raised through our existing grievance mechanisms, including line management, HR, our whistleblowing process, and employee representatives where established.

International Frameworks

This policy is explicitly committed to and grounded in the following three internationally recognised frameworks:

UN Guiding Principles on Business and Human Rights (UNGPs)

The UNGPs provide the global framework for how businesses should respect and remediate human rights. Our due diligence approach directly follows the UNGPs’ protect, respect, remedy pillars. We are committed to upholding the UNGPs across our operations and in how we work with our suppliers and partners.

International Bill of Rights and the Universal Declaration of Human Rights (UDHR)

The International Bill of Human Rights, including the rights under the Universal Declaration of Human Rights, sets out the fundamental rights of all people. We commit to upholding these rights in how we treat our employees, workers in our supply chain, customers, and the communities we are part of.

ILO Declaration on Fundamental Principles and Rights at Work

The ILO Declaration covers core labour standards including freedom of association, elimination of forced labour, abolition of child labour, and non-discrimination. We commit to upholding these principles in our employment practices and expect the same of our suppliers and partners.

Scope

This policy applies to all employees of World of Books Group . It also extends to our suppliers, contractors, and business partners, who are expected to uphold equivalent standards.

We expect all third parties acting on our behalf to adhere to the principles set out in this policy. Where we identify that a supplier or partner falls below these standards, we will work with them to improve, and where necessary, review our relationship with them.

Key Human Rights Themes

Based on the nature of our business in the book resale and circular economy sector, the following human rights themes are particularly relevant to World of Books Group.

Labour Rights

Fair pay, including payment of at least the applicable statutory minimum wage in each jurisdiction1
Safe and healthy working conditions across all sites
Freedom of association and the right to collective bargaining, including the right to establish or join works councils and trade unions in accordance with local law
Prevention of discrimination and promotion of equality and inclusion
Zero tolerance of forced labour, child labour, or modern slavery in any form

Supply Chain

Responsible sourcing of donated books and traded stock
Ethical standards in relationships with logistics, fulfilment, and technology partners
Procurement practices that do not create or exacerbate human rights risks

Data and Privacy

Respect for the privacy and personal data of employees, customers, charities and goodwill in line with applicable data protection law

Community and Environment

Recognition of the potential impact of our operations on local communities
Commitment to our environmental responsibilities as part of our broader social obligations

Governance and Accountability

Overall accountability for this policy sits with the Executive Leadership Team. Day-to-day responsibility for implementation is held by the Chief People Officer, supported by the People Team.

We will review this policy annually, or sooner if there is a material change to our business or operating context. The results of our human rights assessments will be reported to senior leadership and, where appropriate, published publicly.

Jurisdiction Addendum

This addendum sets out jurisdiction-specific context relevant to implementation of this policy. It does not create additional obligations beyond those set out in the main policy, but provides local context to support compliance.

United Kingdom

Fair pay: National Living Wage applies to workers aged 21 and over; National Minimum Wage applies to those under 21.
Data protection: UK GDPR and the Data Protection Act 2018 apply.
Whistleblowing: the Whistleblowing Policy reflects the requirements of the Public Interest Disclosure Act 1998.

United States

Fair pay: the higher of applicable Federal or State minimum wage applies. State minimums may exceed the Federal rate.
Equal treatment: US employees have protections under federal law (Title VII, ADA, ADEA) and applicable state law. Illinois employees additionally have rights under the Illinois Human Rights Act, including freedom from unlawful discrimination and sexual harassment, and access to the Illinois Department of Human Rights (IDHR) complaints process.
Data protection: applicable federal and state data privacy laws apply, which may vary by state.

Hungary

Fair pay: Kötelező minimuumbér (statutory minimum wage) and Garantált bérminimum (guaranteed minimum wage for skilled workers) apply under Hungarian law.
Works councils: in organisations with 50 or more employees, workers may establish a works council (üzemi tanács) with statutory consultation and information rights under Act I of 2012 (Labour Code).
Data protection: GDPR applies directly, supplemented by Act CXII of 2011 (Hungarian data protection law).
Equal treatment: Act CXXV of 2003 (Equal Treatment and Promotion of Equal Opportunities) applies.
Whistleblowing: Act XXV of 2023 imposes specific requirements for Hungary, including designated whistleblower protection channels, defined timelines, and Hungarian-language publication. A Hungarian Annex to the Whistleblowing Policy is being developed to address these requirements.