Introduction
Wolters Kluwer is an international company with a footprint in many countries around the world. The Company is aware of the diversity in business cultures and practices around the world. Recognizing its responsibility to promote and protect human rights, Wolters Kluwer commits to apply its Human Rights policy on a company-wide basis.

Wolters Kluwer abides to the laws and regulations of the countries in which it is present. Furthermore, all business activities are guided by the articles of the United Nations Universal Declaration of Human Rights and the eight core labor standards of the International Labor Organization. The eight ILO conventions which make up the core conventions are: conventions 87, 98, 100, 111, 29, 105, 138 and 182.

Link with Wolters Kluwer Company Values and Business Principles
The Company Values are at the heart of the Company’s success and represent the common bond across all Wolters Kluwer businesses and employees. The Business Principles reflect the high ethical standards that are the basis for achieving the Company’s goals. Together, they are an important means to enable the Company and its employees to live up to high professional and ethical standards. In the Business Principles it is stated that Wolters Kluwer supports and respects human rights and it strives to ensure that its activities will not infringe upon them. The Wolters Kluwer Human Rights Policy is best seen as an expansion and articulation of this statement.

Human Rights & Suppliers Policy
The United Nations Universal Declaration of Human Rights and the core labor standards of the International Labor Organization are the fundament for this Human Rights Policy. Wolters Kluwer has further emphasized Human Rights issues which are most relevant for the Company.

Access to information
In its role as an information provider, Wolters Kluwer strives to assist in shaping the investment climate and public opinion of emerging economies where the Company has influence, by providing adequate knowledge on regulation, law, health and actual practice. Wolters Kluwer can improve access to information around the world by expanding its business in upcoming countries.

Freedom of publishing
Wolters Kluwer is aware of the fact that complete freedom of publishing is not self-evident in some parts of the world. Even if freedom of publishing is not fully secured, this is not a sufficient reason to stop providing information. While Wolters Kluwer cannot change such a situation, the Company can stimulate the distribution of information. Steps in the right direction can be made by working together with local partners.

Data protection
Wolters Kluwer needs to store and use personal data about customers to deliver appropriate service. The Company is committed to protecting the rights and privacy of past, present and prospective customers. Information about individuals must be collected and used fairly, stored safely and securely and only be disclosed in a way that is consistent with international best practices. Furthermore, the information will not be stored for longer than necessary.

Equal Opportunity
As a diverse, multinational company, Wolters Kluwer aims to create equal opportunities for all employees regardless of personal background, race, gender, nationality, age, sexual preference, physical disability or religion. Wolters Kluwer will treat all individuals equal considering the responsibilities of their position during recruitment and selection, compensation and benefits and training, promotion, transfer or termination.

Harassment
Wolters Kluwer will not tolerate any form (physical or verbal) of sexual harassment, intimidation and discrimination on the basis of race, gender, nationality, age, sexual preference, physical disability or religion.

Privacy of employees
Wolters Kluwer has the right to monitor the appropriate business use of its own internal information and communication systems. For this reason, Wolters Kluwer cannot guarantee the privacy of the information that employees insert in or exert out of the Company’s systems or facilities. This applies to movements on the internet or e-mail, but also to phone and fax communications. Wolters Kluwer will always act in conformity with local laws and to the extent applicable agreements with employee representative bodies (works councils) with respect to this subject.

Freedom of Association
Wolters Kluwer respects the rights of employees to associate, organize and bargain collectively in a lawful and peaceful manner, without penalty or interference.

Supplier Principles
Wolters Kluwer expects all suppliers to adhere to local laws and regulations, to the articles of the United Nations Universal Declaration of Human Rights and the core standards of the International Labor Organization. Human Rights standards which Wolters Kluwer Suppliers have to meet at a minimum are:

• Forced Labor
  Suppliers will not use forced, bonded, prison, military or compulsory labor.
• Child Labor
  Suppliers will not use child labor. The term “child” refers to any person employed under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest.
• Abuse of Labor
  Suppliers will treat each employee with dignity and respect, and will not use corporal punishment, threats of violence or other forms of physical, sexual, psychological or verbal harassment, abuse or intimidation.
• Freedom of Association
  Suppliers will respect the rights of employees to associate, organize and bargain collectively in a lawful and peaceful manner, without penalty or interference.
• Non-discrimination
  Suppliers will not discriminate in hiring and employment practices on the basis of race, gender, nationality, age, sexual preference, physical disability or religion. 
• Wages and Benefits
  Supplier will comply with all applicable local and national wages and benefits laws.
• Health and Safety
  Suppliers will provide their employees with a safe and healthy workplace in compliance with all applicable local and national laws and regulations.
• Environment
  Suppliers will operate in a manner that is protective of the environment. Suppliers will comply with all applicable local and national environmental laws.
• Anti-Corruption
  Suppliers will comply with local and national laws related to bribery, extortion and other forms of corruption.

Scope
Wolters Kluwer is responsible and accountable for upholding Human Rights by monitoring Human Rights performance for:

• All Wolters Kluwer companies and business units worldwide

• Joint Ventures where Wolters Kluwer owns 50 percent of the shares and exerts full management control

Wolters Kluwer is responsible for assessing the Human Rights situation at the time a commitment is made and for continuously influencing situations that are unsatisfactory but Wolters Kluwer is not responsible and not accountable for the actions and practices thereafter for:

• Companies or joint ventures where Wolters Kluwer has a minority share or where it cannot exert management control

Wolters Kluwer is responsible for assessing the Human Rights situation at the time a commitment is made and for random and non-random monitoring of Human Rights practices but Wolters Kluwer is not accountable for the actions and practices thereafter for:

• All suppliers worldwide

Responsibilities and Management
The Wolters Kluwer Executive Board attaches great importance to the implementation of this policy. The Senior Vice President Human Resources, together with the Corporate Legal Department, under the accountability of the CEO and Chairman of the Executive Board of Wolters Kluwer, are responsible for embedding the Human Rights policy in the management cycle and monitoring compliance and reporting violations.

All employees who want to report breaches or violations regarding the Wolters Kluwer Human Rights policy can take action according to the rules and procedures described in the Wolters Kluwer Whistleblower Policy.

To ensure the appropriate integration of the Human Rights Policy, the Company will take the following actions:

• Educating Wolters Kluwer employees and particularly managers in the implications of the Human Rights policy.

• Integrating the monitoring of the Company’s own performance against its Human Rights Policy in the current sustainability information system.

• Monitoring the performance of joint ventures where Wolters Kluwer owns 50 percent of the shares and exerts full management control by performing random and non random assessments.

• Assessing the Human Rights situation at the time a commitment is made for joint ventures where Wolters Kluwer has a minority share or where it cannot exert management control and for suppliers worldwide

• Monitoring the performance of suppliers by performing random and non-random assessments. Wolters Kluwer reserves the right to inspect any site used for work for the Company. Suppliers who do not comply with the Wolters Kluwer Supplier Principles will be asked to improve their standards. The ultimate measure is to terminate any agreement with suppliers who fail to comply with the Wolters Kluwer Supplier Principles.

Appendices