CTP N : Suppliers Group Code of Conduct 2022

Foreword from the CEO

Dear Suppliers,

As an integral part of our company's owner/operator strategy, we have worked hard to become a long-term partner for our clients-one that they can depend on and trust over many years. Fulfilment of this mission would be impossible without our Suppliers and other partners, who play an essential role in our activities. We have had great success developing strong working-and ethical- relationships with you, based on a shared set of values.

As CTP is now a publicly traded company, we believe it is important to codify our values, as they underpin our commitment to our Environmental, Social & Governance efforts. We expect our Suppliers to act with care and in line with our values through the provision of materials, products, or services. We invite you to join us on our journey to sustainability, as we need your full commitment and support to make it happen.

Attached you will find the CTP Group Suppliers' Code of Conduct, which serves as a minimum standard of conduct for all CTP Group Suppliers with respect to our Environmental, Social and Governance (ESG) principles.

By reading the attached Code of Conduct and continuing in your capacity working with CTP, it is understood that you agree and accept our guidelines.

We thank you for your continued support and look forward to many long years working together.

Sincerely,

Remon L. Vos

CEO

CTP Group Suppliers'

Code of Conduct

About Us	What we do?
	The CTP Group is a full-service commercial real estate developer operating
	throughout the CEE region and beyond. We design, build, and manage sustain-
	able business parks using high-tech solutions and state-of-the-art materials to
	achieve the smallest possible environmental footprint. All our activities are geared
	toward making positive contributions to the communities where we operate.
	Our mission
	Our mission is to provide sustainable building solutions with the smallest possible
	environmental impact. We believe that by committing to sustainability and protec-
	tion of the environment, we work towards a better future not just for our custom-
	ers and ourselves, but for all communities where we operate. By 2023 we aspire
	to become an industry leader in the transition to a carbon-neutral economy and
	reach the goal of net carbon neutrality.
	Fulfilment of our mission would be impossible without our partners and suppliers,
	who play an essential role in our activities. We expect our suppliers to act with
	care and in line with our values through the provision of materials, products, or
	services. We invite them to join us on our journey to sustainability, as we need their
	full commitment and support to make it happen.
	Our main values
	At CTP, we value compliance and perform our activities in conformity with all ap-
	plicable laws and regulations. We regularly monitor and adapt to the most recent
	industry standards and respect best practices in all countries of operation.
	At CTP, we value ethical behaviour, both while doing business and at the work-
	place. We adhere to fairness, honesty and truthfulness in our relations with third
	parties and among ourselves. We support an objective business environment and
	denounce any form of bias.
	At CTP, we value respect towards the natural environment. We support environ-
	mental awareness and participate in sustainability initiatives such as forest res-
	toration. We promote the conscientious use of energy and sustainable sourcing
	of materials. All our buildings are carefully designed as complete ecosystems to
	ensure their sustainability and low environmental impact.

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Purpose & Scope

At CTP, we value socially responsible behaviour. We strive to be "a good neighbour" and engage in and support activities that help us to positively impact communities and society. We support a wide range of community-based organisations focused mainly on the provision of educational opportunities to underprivileged children or adolescents and other people in need.

The CTP Group Supplier Code of Conduct is based on the CTP Group Code of Conduct as well as other Governance policies available on our website: https://www.ctp.eu/. The purpose of the CTP Group Supplier Code of Conduct is to define a minimum standard of conduct for all CTP Group Suppliers with respect to our Environmental, Social and Governance (ESG) values. This Group Supplier Code of Conduct does not aim to cover every possible situation the Supplier may face in cooperation with CTP, but rather provides guidance and principles reflecting our values in the areas of:

ENVIRONMENTAL	SOCIAL	GOVERNANCE
Respect towards the	Respect of human rights		Anti-bribery and
environment			anti-corruption
Protection against pollution	No tolerance of forced		Business hospitality
				and child labour		and gifts
Sustainable sourcing	Inclusiveness		Prevention of money
of materials			laundering
				Freedom of association		Avoidance of conflict
						of interest
				Fair working conditions		Fair competition and
						market prices
				Work safety		Confidentiality and data
						protection
				Health & wellbeing

At CTP, we conduct our business lawfully and with integrity. We are committed to following and to be fully compliant with all applicable laws, regulations, and rules (including internal codes, guidelines, or best practice standards applicable to CTP) valid across all countries of operation. We value trustworthy business partners that conduct their activities in compliance with all applicable laws and regulations, industry standards and best practices. In case we become aware of any violation of laws, rules, or regulations, we act to address the problem and prevent any future occurrences.

As our Supplier you are required to be compliant and fully follow all applicable laws, regulations, and rules (including internal codes, guidelines, or best practice stan- dards) related to or affecting your business operation. Your actions must meet our high ethical and legal standards. You are expected not to tolerate unethical behaviour in any form and to consult with CTP if such behaviour relates to interactions with CTP.

This document is also part of our continuous efforts to have all buildings constructed or maintained by CTP certified according to BREEAM standards.

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Environmental

As our supply chain plays an important role in achieving our goals, we invite you, our Supplier, to act, communicate and make your decisions in conformity with our values and expectations listed in this Supplier Code of Conduct.

Respect towards the environment

At CTP, we care strongly about the environmental impact of our activities. We build highly efficient buildings designed as whole ecosystems to secure their long- term durability and low environmental impact. We also participate in various initiatives that help to secure sustainability and preserve nature's biodiversity.

As our Supplier, you are required to carry out your business in a sustainable manner and take into consideration the impact it has on the environment. You should secure awareness of employees of environmental issues and ways to prevent negative impacts. You are also encouraged to engage in sustainability initiatives that help to preserve the environment and communities that are part of it.

Protection against pollution

At CTP, we take great effort to reduce any negative impact that the production, storage and disposal of materials have on the environment. We adhere to rules and protocols of proper handling and storage of materials and continuously seek new and safe solutions to prevent pollution and maximise sustainability.

As our Supplier, you are expected to follow all applicable rules on the manipulation, storage and disposal of materials depending on their nature. You are also expected to apply pre-emptive measures against all types of environmental pollution so that the incidence of pollution is reduced to a minimum.

Sustainable sourcing of materials (be mindful of environmental impact)

At CTP, we care about natural resources and strive to protect them through various solutions and initiatives. We participate in the circular economy, through which we minimise waste and resource consumption with the reduction and reuse of raw materials and the recycling of products. Our vision is highly efficient circular parks powered by renewable energy with zero-waste and eco-friendly solutions that help attain sustainability and protect the environment.

As our Supplier, you shall gather, use, and consume natural resources conscientiously with regard to the environment. You are expected to adopt basic elements of the circular economy, such as waste recycling, and are encouraged to apply eco-friendly solutions where possible. You are also encouraged to optimise energy consumption in the workplace and to support the usage of renewable energy.

Social

Human rights & labour conditions

Respect of human rights

At CTP, we respect the rights of individuals and communities and provide support in exercising them. We are a community-oriented company and the wellbeing of people both outside and inside our company is very important to us. We promote social affinity and respect towards human rights by engaging in support of various social initiatives focused mainly on children and adolescents in need.

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As our Supplier, you are required to treat people with dignity and to abide by the general principles of human rights according to universal declarations and guidelines proposed by the relevant authorities. You are especially encouraged to protect the rights of groups and individuals particularly vulnerable to human rights abuse, e.g., women, children, migrant workers, or disabled people.

Forced and child labour

At CTP, we strongly stand against any form of illegal employment, including but not limited to compulsory, forced and child labour, modern slavery, or human traf- ficking. We distance ourselves from all illegal practices against our employees that may cause a breach of their human rights and rights arising from labour law.

As our Supplier, you are expected to have zero tolerance towards all illegal forms of employment, including related unlawful practices such as the withholding of wages or restriction of an employee's movement by confiscating identification documents. You are also encouraged to raise awareness on this matter and to engage in activities that will contribute to the prevention of such actions from occurring.

Inclusiveness

At CTP, we consider people as one of our most important assets. We believe that all people deserve to be treated equally with respect and should be included and welcomed by society. We support diversity and disregard any form of discrimination based on age, sex, marital status, race, ethnicity, religion, sexual orientation, disability, or political preferences.

As our Supplier, you are expected to promote diversity in the workplace and condemn any form of discrimination. You should hire and give promotion to both staff and executives based on their performance, professional experience, or work re- sults. You are also expected to condemn and apply measures against any form of harassment or abuse in the workplace, so that your employees feel safe and included.

Freedom of association

At CTP, we encourage our employees to create social groups in order to speak freely and share ideas and concerns to company management. We strive to create a safe and comfortable environment, where all employees can communicate without fear of judgement and discrimination.

As our Supplier, you are encouraged to support associations for the constructive discussion of ideas and concerns regarding work conditions and other work-related topics. You are also encouraged to recognise those suggestions and concerns in order to support the motivation of employees and boost work engagement.

Fair working conditions (appropriate wage, benefits, vacation)

At CTP, we follow all applicable rules and regulations valid across all countries of operation on working hours (including overtime), resting hours, vacation, sick leave, parental leave, or any other applicable leave.

As our Supplier, you are expected to provide your workers with a fair wage according to their job position and professional qualification, including benefits according to an employment contract and wage agreement, that comply with at least the minimum determined by applicable laws and regulations. You are also required to respect their right to rest, take vacation, sick leave, or parental leave, as determined by law.

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