HUMAN RIGHTS POLICY

I. Firnal’s Commitment to Human Rights

1. Policy Purpose and Principles

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Firnal Inc. (“Firnal”) is committed to respecting, protecting, and promoting human rights across all of our operations, relationships, and areas of influence. This policy articulates our responsibilities and expectations in line with internationally recognized frameworks, including:

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• The Universal Declaration of Human Rights (UDHR)

• The UN Guiding Principles on Business and Human Rights (UNGPs)

• The International Labour Organization (ILO) Fundamental Conventions

• The OECD Guidelines for Multinational Enterprises

• The International Covenant on Civil and Political Rights (ICCPR)

• The International Covenant on Economic, Social and Cultural Rights (ICESCR)
   

Firnal recognizes that businesses can impact human rights both directly and indirectly. As such, we commit not only to avoiding harm, but also to using our platform and capabilities to positively influence systems and communities.
 

2. Scope

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This policy applies to:
 

• All Firnal employees, officers, and board members;

• Contractors, interns, and advisors;

• Joint ventures and strategic partners acting in Firnal’s name;

• Suppliers and vendors in our global value chain;

• Clients and public engagements where Firnal has operational or strategic influence.
   

Where local laws fall short of international standards, Firnal will operate to the higher standard, provided it does not violate local statutory obligations.

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3. Foundational Commitments

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Firnal commits to:

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• Upholding dignity, autonomy, and freedom from coercion in every employment, advisory, and operational setting.

• Avoiding complicity in human rights abuses, whether through direct action, business relationships, or silent tolerance.

• Proactively identifying and mitigating risks to vulnerable populations, especially in conflict-affected regions, resource-extractive contexts, and infrastructure engagements.

• Embedding human rights due diligence into all major project evaluations and operational expansions.

II. Areas of Focus and Enforcement

1. Labor Rights and Fair Employment

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Firnal supports and upholds:

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• Freedom of association and the right to collective bargaining.

• Prohibition of child labor, forced labor, or modern slavery in any form.

• Safe and healthy working conditions in compliance with ILO standards.

• Fair wages aligned with local living wage benchmarks, not just minimum legal thresholds.

• Non-discrimination in hiring, promotion, compensation, and termination.
   

We require these standards from all suppliers and subcontractors via explicit contractual provisions and independent audits.
 

2. Rights of Vulnerable Populations
 

Firnal actively protects the rights of:
 

• Women, LGBTQ+ individuals, and gender-diverse persons

• Refugees, migrants, and displaced communities

• Indigenous peoples and tribal communities

• Individuals impacted by conflict, occupation, or infrastructure displacement
   

Our Human Rights Impact Assessments (HRIAs) are designed to flag these groups in advance and apply equity-driven mitigations throughout our work.
 

3. Digital Rights and Data Privacy
 

As a firm operating in intelligence, advisory, and technology:
 

• Firnal protects freedom of expression, data sovereignty, and digital privacy.

• We do not participate in or enable surveillance, censorship, or algorithmic discrimination.

• Our platforms—including Moonbrush and Hikmah—adhere to data minimization, algorithmic transparency, and user dignity principles.
   

4. Public Sector Engagements

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Firnal frequently partners with governments and sovereign institutions. In these settings, we:

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• Conduct enhanced human rights due diligence for any engagement in countries with elevated risk scores (e.g., conflict zones, authoritarian regimes, extractive industries).

• Decline or withdraw from engagements where our work may directly or indirectly enable human rights abuses.

• Consult third-party watchdogs, NGOs, and legal advisors when concerns arise.
   

5. Internal Accountability and Reporting

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• Firnal provides internal and third-party channels to report human rights concerns.

• The Office of Human Rights & Social Impact investigates all reports involving potential or actual violations.

• Confirmed violations may lead to:

  • Disciplinary action or termination of employment

  • Termination of supplier or client contracts

  • Regulatory disclosures or public reporting