Bright Data Ltd.

Effective date: January 1st, 2026

Applies to: Employees, officers, directors, contractors, suppliers and other stakeholders worldwide.

Preamble

Bright Data is committed to respecting and promoting human rights across our operations,
products, and business relationships. This Policy formalizes our commitments and complements
the Bright Data Code of Conduct, privacy and security policies, and sustainability commitments.

1. Scope and applicability
   This Policy applies globally to Bright Data Ltd. and to all employees, officers, directors,
   contractors, suppliers, partners and affiliates. We expect suppliers and partners to uphold
   these commitments and to cascade equivalent standards to their own supply chains.
2. Guiding standards
   Our commitments are informed by:
   • The UN Guiding Principles on Business and Human Rights (UNGPs)
   • The International Bill of Human Rights
   • The ILO Core Conventions
   • The OECD Guidelines for Multinational Enterprises
3. Our human rights commitments
   1. Labour rights and working conditions – We prohibit all forms of forced or
      compulsory labour, human trafficking and child labour. We seek to provide safe and healthy
      workplaces, respect freedom of association and collective bargaining, and support fair
      remuneration and reasonable working hours.
   2. Diversity, equity and inclusion (DEI) – We prohibit discrimination,
      harassment and bullying on any protected basis. We promote equal opportunity, inclusion and
      dignified treatment for all.
   3. Privacy and data protection – We respect the right to privacy and process
      personal data in accordance with applicable laws and our privacy/security policies. We build
      privacy-by-design and data minimisation into our products and services.
   4. Responsible technology and freedom of expression – We will not knowingly
      enable misuse of our services to suppress free expression, enable unlawful surveillance, or
      disseminate harmful content. We consider human-rights risks in product design and use and act
      to prevent, mitigate and remediate misuse.
   5. Modern slavery and human trafficking – We maintain zero tolerance for modern
      slavery and human trafficking in our operations and supply chains and will take appropriate
      action if we identify related risks or violations.
   6. Community and environmental stewardship – We assess potential impacts on
      communities and aim to contribute positively (e.g., via the Bright Initiative), while
      aligning with broader sustainability commitments.
4. Human rights due diligence (HRDD)
   We conduct risk-based human-rights due diligence, including:
   • Screening of customers and suppliers; enhanced due diligence for higher-risk geographies/sectors
   • Integrating human-rights considerations into procurement and product decisions
   • Contractual commitments (e.g., Supplier Code/clauses), monitoring, and audits or
     assurance where appropriate
   • Corrective action plans or disengagement where violations persist
5. Grievance and remedy
   Employees, contractors and external stakeholders (including suppliers) may report concerns to the
   Legal Department at [email protected]. Reports are
   handled confidentially, investigated promptly, and remediated as appropriate. Retaliation against
   anyone who reports in good faith is prohibited. Suppliers are encouraged to maintain effective
   grievance mechanisms and to notify us without undue delay of material allegations.
6. Training and awareness
   We promote awareness of this Policy through onboarding materials, internal communications, and
   targeted briefings for teams whose work may impact human rights (e.g., procurement, vendor
   management, engineering, security, trust & safety, sales). Where relevant, role-specific
   guidance (e.g., modern slavery, fair recruitment, responsible technology) is provided. Expectations
   are communicated to suppliers via our Supplier Code of Conduct and contractual clauses, and
   supporting resources are available on request.
7. Governance and oversight
   The Board of Directors has ultimate oversight. Senior management is responsible for
   implementation. The Legal Department monitors adherence, reports material issues to the Board,
   and coordinates annual review and public reporting.
8. Measuring effectiveness and transparency
   We will define and monitor KPIs (e.g., risk screenings, training completion, supplier coverage,
   issues raised/resolved) and publicly report progress through our Trust Center/Impact Report,
   subject to confidentiality and legal constraints.
9. Review and enforcement
   This Policy is reviewed at least annually or upon material regulatory change. Breaches may result
   in disciplinary action up to and including termination of employment or business relationship.
10. Questions
    Questions about this Policy may be addressed to
    [email protected].