Human & Labour Rights Policy

Date of last modification: December 9th 2025

Our Commitment

At SparkOptimus, we believe that respect for human rights reflects the belief that all people are entitled to basic rights and freedoms, regardless of their nationality, age, race, ethnicity, gender, language, sexuality, religion, political or other opinion. We believe that respecting the highest standards of human and labour rights is fundamental to how we operate and to the trust placed in us by our clients, colleagues, and partners. SparkOptimus is committed to upholding these standards in both internal and external operations.  

This policy affirms our commitment and sets principles that are guided by internationally recognized standards, including the Universal Declaration of Human Rights (UDHR), International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work (including follow-up), and the United Nations Guiding Principles on Business and Human Rights (UNGPs). This priority is consistent with the International Sustainability Standards Board’s identification, overseeing the Sustainability Accounting Standards Boards, of Employee Engagement, Diversity and Inclusion, being a key material issue for professional services.

Scope, Governance & Accountability

Our reporting covers all operations directly managed by SparkOptimus, and applies to all our employees,

The Founding Partners hold ultimate responsibility for this commitment, supported by the Leadership team and the Talent team.  

We monitor the effectiveness of our approach to human rights in various ways, including a periodic review of our adherence to our policies and standards, and ongoing dialogue with stakeholders.

Our People

We provide a safe, inclusive, and fair workplace that promotes equal opportunity, wellbeing, and professional development. We do not tolerate any form of forced or child labour, discrimination, or harassment or discrimination on the basis of gender, age, race, ethnicity, sexuality (including LGBTQIA+), religion, physical ability, political opinion, national or social origin. Our commitment to non-discrimination includes recruitment, job assignment, remuneration, training, and benefits. SparkOptimus will also not tolerate the use of child or forced labor, (modern) slavery or human trafficking. Moreover, we respect freedom of association and the right to collective bargaining, and we aim to ensure all our people receive fair and competitive compensation that supports a decent standard of living. These commitments are further supported by our Code of Ethics, Non-Discrimination Statement, Diversity, Equity & Inclusion Statement, and Neutrality Statement

Supplier expectations

As a consultancy firm, SparkOptimus has a relatively simple supply chain, with limited suppliers. Nevertheless, we aim to extend our commitment to human and labour rights beyond our own operations by encouraging our suppliers to uphold the same high standards of integrity, fairness, and respect.

We have developed a Supplier Code of Conduct that outlines the expectations and principles we aspire for our suppliers and service providers to follow, including environmental responsibility, health and safety, prohibitions against modern slavery, child labour and discrimination, and the promotion of economic inclusion for underrepresented groups.

Our Sustainable Procurement Policy further describes how we encourage and, where possible, aim to promote responsible business practices among our suppliers, covering areas such as business ethics, climate action, labour and human rights, and community development.

Where our bargaining power allows, we seek to embed these principles contractually with suppliers and service providers, and we encourage them to adopt equivalent standards in their own operations.

Data and Information Security

SparkOptimus respects human and labor rights by protecting personal data and dignity at work through robust information security. We process personal data lawfully and transparently under GDPR. More information on our commitments can be found in the Information Security Policy.

Human and Labor Rights KPIs

Base Year: 2024

  • Non-discrimination: Maintain low discrimination scores in eNPS; ensure 100% of interviewers use bias prevention technology during interviews; track and report annually on gender and minority representation.
  • Fair wages: 100% of employees earn above the national living wage (baseline confirmed 2024).
  • Grievance mechanisms: Maximum of 3 grievances filed per year, with ≥95% resolved within 2 months (tracked from 2024).
  • Whistleblowing awareness: ≥95% of employees to acknowledge the SpeakUp policy annually (starting 2024).

Monitoring

SparkOptimus will monitor and report on our performance in upholding human and labor rights according to key performance indicators (KPIs). Data will be updated annually (not older than 2 years) in a sustainability report and cover a minimum of 12 months. Where feasible, independent assurance will be sought on our human and labor rights data. In all cases, internal reviews are conducted annually to ensure completeness and accuracy of reported information.

Our Environmental Responsibility

At SparkOptimus, we realize that respect for human rights goes hand in hand with environmental responsibility. We are committed to measuring and minimizing our impact and to promoting sustainable practices in our operations. Our commitments and targets can be found in our Environmental Policy.

Identification and managing of Human Rights and Labour Rights Risks

In order to meet our responsibility, SparkOptimus seeks to avoid causing or contributing to adverse human rights and labor rights impacts in areas which we can directly influence through our management control and address such impacts if they occur. We also seek ways to identify, prevent or mitigate adverse human rights and labor rights impacts that are linked to our business operations, investments or products and services by a business relationship even if we do not contribute to those impacts ourselves. By carefully analyzing our business activities, customers, partners, and suppliers, we identify the areas with the most risks. We conduct a regular materiality assessment to identify the most salient human and labor rights issues based on the severity and likelihood of potential negative impacts. This analysis is used to prioritize action and reporting and is reviewed annually as part of our due diligence cycle. This means that we identify the most salient human and labor rights issues that have the most severe negative impact on people through our company’s activities or business relationships. We conduct due diligence to identify actual and potential adverse human and labor rights related to our business operations, products and services of our business relations and our financing and investments. If adverse impacts occur and have been verified, we provide for or cooperate in the remediation of those impacts where we identify that we have caused or contributed to these impacts.

Complaint Process

Having complaints mechanisms in place for employees, customers, business partners and other stakeholders related to human rights and labor rights is key for effective remediation.

Concerns or potential breaches can be reported confidentially and without fear of retaliation through our established whistleblower procedure in our SpeakUp Policy.

Scope of the Complaint Process

The mechanism applies to:

  • All SparkOptimus employees (current and former)
  • Clients
  • Other relevant stakeholders

Types of Complaints Covered

The mechanism covers two primary categories:

  • Inappropriate conduct: (Sexual) harassment, bullying, discrimination, aggression, and violence
  • Integrity violations: Fraud, legal violations, EU law breaches, and misconduct affecting SparkOptimus or public interest

Access to the Complaint Process

Reports can be made via three routes:

  1. Internal informal route
    Confidential consultation with an internal or external confidentiality counsellor to explore concerns and next steps.
  1. Internal formal route
    Official complaints can be submitted to the Talent Team for formal investigation and resolution.
  1. External route
    If internal resolution is not appropriate, complaints may be submitted to external authorities such as:
  • House for Whistleblowers (Huis voor Klokkenluiders)
  • Dutch regulators (e.g., ACM, AFM, DNB, AP, IGJ)
    (Full list available in the policy appendix)

Confidentiality and Protection

  • All reports are treated in strict confidence.
  • The identity of the whistleblower or complainant will not be disclosed without consent, unless required by law.
  • SparkOptimus guarantees protection against retaliation and ensures that no disadvantage arises from raising a concern.
  • Both internal and external confidentiality counsellors are available to support and guide individuals throughout the process.

Investigation and Resolution

  • Written acknowledgement is provided within 7 days of receiving a formal complaint.
  • Investigations are carried out by People OPS and completed within 2 months.
  • Outcomes may include warnings, suspensions, or dismissal in cases of confirmed violations.
  • All parties involved are heard during the investigation, and support is offered to those participating.

This process is in line with the Whistleblower Protection Act and forms part of SparkOptimus' commitment to upholding the highest standards of human and labour rights.

Awareness and training

Our onboarding and ongoing training programs incorporate environmental, ethical, and operational content relevant to our policy focus areas, including climate impact, waste management, business ethics, and human rights. This enables employees to make informed decisions, adopt sustainable behaviours, and contribute meaningfully to our goals.

Core trainings supporting this policy include:

  • Anti-corruption and anti-bribery training: ensures employees understand and comply with our zero-tolerance approach to unethical and corrupt conduct
  • Bias awareness training: supports inclusive decision-making and helps mitigate discrimination in people processes and during daily life at SparkOptimus
  • Code of Conduct and SpeakUp training: reinforces ethical behaviour, reporting mechanisms, and legal obligations related to human rights and sustainability
  • Sustainability onboarding training: introduces SparkOptimus’ approach to sustainability, covering our environmental commitments, key focus areas, and how each employee can contribute  

We update training content annually to reflect emerging risks and best practices. All employees are expected to complete relevant modules as part of their onboarding and continuous development at SparkOptimus. Trainings are often repeated after a year to ensure understanding.  

Tracking and 360 Degrees Watch

Our KPIs will be tracked and reviewed annually to monitor progress and ensure continuous improvement. Moreover, we will monitor credible external sources and act on findings to ensure consistency with our policy and disclosures.

Questions?

Reach out to the Talent Team anytime at hrm@sparkoptimus.com.