Quality policy

At CT, we provide innovative and technological solutions that make our customers more effective and competitive. In doing so, we aim to deliver a consistent, and high quality standard of service.

Our Quality Management System is the key to maintaining, and bettering our standard of service. Improvement comes from a constant review of our day-to-day activities. This is why everyone in the organization is an important part of Quality at CT, and why suppliers are encouraged to contribute too. We aim not just to meet, but also to surpass ISO 9001, and EN 9100 requirements.

​The following management principles and behaviors guide our Quality Policy:

• Achieve quality, and cost objectives within established timelines in projects.
• Build win-win relationships with customers and suppliers.
• Cultivate a motivating company environment that makes employees happy, and helps them work at their best.
• Actively manage risks, and proactively identify and adopt best preventive practices.
• Pursue continual improvement, and foster innovation.
• Provide trainings designed to develop employee capabilities, and encourage creativity, accountability and engagement.
• Maintain a clear and comprehensive understanding of customer, legal, and regulatory requirements.
• Observe and fulfill the product safety requirements set by our customers, legislation and regulations.
  

The market expects a continually improving service. At CT, we drive consistently to deliver a product that exceeds our customers´ expectations, and our own.

Our Quality Management System outlines the policies, organization, procedures, and management committees tasked with achieving our target quality standards.

Our Head of Quality is responsible for monitoring all quality systems, and reports on their deployment, status and performance to the General Manager periodically. The Quality & Operations committee defines Overall Company Quality objectives, which are monitored by the management board.

As the highest Quality representative for The CT Engineering Group, CT authorizes Julien Brunet as our Head of Quality, to ensure the achievement of our quality objectives.

Environment policy

The CT Engineering Group, dedicated to engineering projects, prioritizes quality and environmental responsibility as essential for its service provision. We commit to environmental protection and aim to exceed customer expectations while minimizing environmental impact. This strategy enhances our market position and distinguishes us from competitors. We believe sustainability and environmental responsibility are fundamental requirements that influence our operations. Recognizing our impact on greenhouse gas emissions, we’re committed to reducing our carbon footprint and addressing climate change through the following principles.

Applicability: This policy applies to all sites within the CT Engineering Group. Every site is expected to follow the guidelines and principles outlined in this policy.

Our environmental policy outlines our objectives and commitments in the areas of energy consumption, greenhouse gas reduction, waste management and recycling, and the promotion of sustainable consumption through environmental consulting services to help our customers design and promote their eco-friendly products:

Energy Consumption: the objective is to minimize the environmental impact by increasing the use of renewable energy sources, both through higher consumption and on-site generation, while also transitioning the vehicle fleet to zero-emissions vehicles, thus reducing energy consumption and contributing to environmental sustainability.
Targets:
1. Our main target is to increase our consumption of renewable electricity by 80% by 2030 and 100% by 2040
2. To further our commitment to renewable energy, we aim to boost our renewable electricity generation by 10% by 2025 and by 15% by 2030.
3. By 2030, we plan to electrify 40% of our vehicle fleet and reach 100% zero-emission vehicles by 2040.

Greenhouse Gas Emissions Reduction: The objective is to develop and implement plans to reduce greenhouse gas emissions, including setting challenging reduction targets, and tracking progress regularly. Additionally, the goal is to prioritize the use of renewable energy sources, energy-efficient technologies, and sustainable transportation options, while also collaborating with suppliers and clients to reduce the indirect environmental impact of operations.

We are proud to be engaged in the Science Based Targets initiative (SBTi), which provides companies with a clear pathway to set science-based emissions reduction targets that are in line with the goals of the Paris Agreement. At CT, we have set science-based targets to reduce our greenhouse gas emissions in line with the latest climate science. We will regularly report our progress towards meeting these targets through the Climate Disclosure Program (CDP), a global platform for companies to report their environmental impacts and progress towards sustainability goals.
Targets:
1. The short-term objective is to reduce absolute scope 1, 2 and 3 GHG emissions 42% by 2030 from a 2022 base year.
2. The long-term objective is to reduce absolute scope 1, 2 and 3 GHG emissions 90% by 2050 from a 2022 base year (Net-Zero).
To upload the latest CDP report: click here.

Waste Management and Recycling: The objective is to minimize pollution by reducing waste generated during our activities through the promotion of reuse and recycling whenever feasible, and optimize the efficient use of raw materials and energy.
Targets:
1. The aim is to purchase 95% recycled paper for all uses by 2025.
2. By 2030, the aim is to put in place an effective and sustainable waste sorting system at all company sites to optimise resource recovery, which includes recycling, the correct disposal of the various waste streams.

Environmental consulting services: Providing efficient engineering solutions tailored to the needs of our customers and stakeholders, using environmentally friendly and economically viable technologies, taking into account both the internal and external context of the organization.
Targets:
1. Our goal is to grow our portfolio of “green” technologies in the upcoming years. When we mention “green,” it is in line with the criteria set out in the EU Sustainable Finance Taxonomy. In the near term, we aim to raise the portion of our revenue derived from green projects, which align with the six environmental objectives outlined in the EU Taxonomy regulations, including Climate Change Mitigation, Climate Change Adaptation, Pollution Prevention and Control. This increase should reach 20% by 2030.
2. The long-term objective is to reach 80% of our revenue derived from green projects by 2040.

Education and awareness: Promoting training and awareness to raise awareness and responsibility among all personnel regarding environmental protection.
Targets:
1. Starting in 2025, it is mandatory for 95% of newly onboarded CT employees to receive training regarding the environmental policy and its impact on their day-today work

Adaptation: We will assess and manage the risks posed by environmental protection and climate change to our operations, assets, and supply chain. We will develop and implement strategies to adapt to the physical and economic impacts of climate change, including extreme weather events, changes in precipitation patterns, and shifts in market demand, ensuring the long term resilience of our business.

Applicable laws and regulations: This policy will be implemented with a commitment to adhere to the specific local environmental laws and regulations at each site within the group.

Environmental system based on ISO 14001: The CT Engineering group implements an environmental management system based on the UNE-EN-ISO 14001 standard in our headquarters, which facilitates well-done work and continuous improvement of the service in an environmentally respectful manner. The scope of this certification is “Engineering Services for Product Innovation, Development and life cycle Support”.

Accountabilities: The annual Environmental Committee, composed of the Country Managers and the Environmental Manager, is accountable for the company’s environmental policy, ensuring its adherence and continuous improvement. Simultaneously, the Environmental Manager takes on the daily responsibilities of animating the environmental system, overseeing compliance, monitoring and reporting, and engaging stakeholders in the company’s environmental efforts, while staying updated on relevant regulations. This dual approach ensures a holistic and effective approach to environmental sustainability within the organization.

Review mechanism: This policy is reviewed annually in October to assess its effectiveness and relevance, taking into account changes in regulations and best practices. Any necessary updates are made to ensure it remains aligned with our commitment to environmental sustainability.

At the CT Engineering Group, we believe that environmental stewardship is essential for the well-being of our planet and future generations. We are dedicated to upholding this policy to the highest standards and continuously improving our environmental performance.

This policy is communicated to all our internal stakeholders and is published on our intranet and website.

July the 10th, 2024

Health & Safety Policy

The CT Engineering Group, dedicated to engineering projects, recognizes the paramount importance of the health and safety of our employees, contractors, visitors, and the communities in which we operate. We are committed to providing a safe and healthy work environment and promoting a culture of safety throughout our organization. This commitment ensures the well being of our people, enhances our reputation, and fosters a productive and thriving workplace.

Applicability: This policy applies to all sites and activities within the CT Engineering Group.
Every site is expected to adhere to the guidelines and principles outlined in this policy.

Our Health & Safety Policy outlines our objectives and commitments in the following key areas:

• Incidents and Accidents Reduction: We are dedicated to proactively managing and reducing workplace incidents and accidents to ensure the safety and well-being of our employees.
  Targets:
  1.  Reduction of 30% in occupational safety incident rate by 2030.
  2.  From 2024, the aim is to have NO work-related accidents with leave.
• Hazard Identification and Risk Management: We are dedicated to identifying workplace hazards, assessing risks, and implementing appropriate control measures to eliminate or minimize potential harm.
  Targets:
  1.  More than 90% of the CT employees must be covered by a health & safety risk assessment.
• Incident Reporting and Investigation: We prioritize the reporting and investigation of all occupational incidents to prevent reoccurrence and continuously improve safety.
  Targets:
  1.  Communicate the incident and accident reporting process at least once a year.
• Emergency Preparedness: We are dedicated to being prepared for emergencies and ensuring the safety and well-being of our employees during unforeseen events.
• Education and awareness: Promoting training and awareness to raise awareness and responsibility among all personnel regarding safe work practices.
  Targets:
  1.  Starting in 2025, it is mandatory for 95% of newly onboarded CT employees to receive training regarding the health & safety policy and its impact on their day-to-day work

Applicable laws and regulations: This policy will be implemented with a commitment to adhere to the specific local health and safety laws and regulations at each site within the group

Health & Safety system based on ISO 45001: The CT Engineering group implements a health & safety management system based on the UNE-EN-ISO 45001 standard in relevant sites, ensuring the well-being of our employees and the safety of our work environment. The scope of this certification is “Engineering Services for Product Innovation, Development and life cycle Support”.

Accountabilities: The annual Health and Safety Committee, composed of the General Manager, the Country Managers, the COO and the Health and Safety Manager, is responsible for overseeing the company’s health and safety policy, ensuring its adherence, and promoting continuous improvement. The Health and Safety Manager will oversee the daily responsibilities of maintaining a safe work environment, compliance, and engagement of all stakeholders in our health and safety efforts.

Review mechanism: This policy is reviewed annually in October to assess its effectiveness and relevance, taking into account changes in regulations and best practices. Any necessary updates are made to ensure it remains aligned with our commitment to health and safety.

At the CT Engineering Group, we believe that the health and safety of our people is a fundamental priority. We are committed to upholding this policy to the highest standards and continuously improving our health and safety performance.

This policy is communicated to all our internal stakeholders and is published on our intranet and website.

October the 19th, 2023

Labor & Human Rights Policy

The CT Engineering Group, dedicated to engineering projects, is committed to upholding labor
and human rights as fundamental principles within its operations. We recognize the importance
of ensuring fair and ethical treatment of our employees, fostering diversity, equity, and inclusion,
and eradicating child and forced labor.

Applicability: This policy applies to all sites within the CT Engineering Group. Every site is
expected to adhere to the guidelines and principles outlined in this policy.

This policy outlines our objectives and commitments in key areas related to labor and human
rights:

Diversity, Discrimination & Harassment: The CT Engineering Group is committed to creating
a diverse, equitable, and inclusive workplace and to the principle that every individual should
have access to equal treatment and opportunities, irrespective of personal characteristics
unrelated to their skills, performance, or qualifications. CT prohibits any form of discrimination,
harassment, or intimidation based on factors such as age, origin, skin color, disability or
impairment, nationality, race, religion, gender, sexual orientation or preference, gender identity,
appearance, political affiliations, marital status, or any other characteristic protected by law. CT
expects its employees, in all circumstances and locations, to maintain an environment free from
discrimination, harassment, intimidation, or retaliation. CT is a politically neutral space: we
deeply respect the political freedom of thought of all individuals working within the company,
and therefore, we refrain from expressing political comments or opinions on internal forums and
communication networks.
Targets:
1. The goal is to reach 50% of employees trained on discrimination and harassment
by 2028.

Child and Forced Labor: The CT Engineering Group unequivocally condemns child and forced
labor, as well as human trafficking.
Targets:
1. To maintain a zero-tolerance policy towards child labor and forced labor, as well as
human trafficking, ensuring compliance with international labor standards.
2. To establish an agreement with our suppliers and partners to enforce this zerotolerance policy. The objective is to ensure that 100% of our engineering suppliers have the relevant clause approved within our supplier framework contract by 2026.

Whistleblowing channel Reporting and Investigation: The CT Engineering group undertakes
to investigate and settle any report received through the Compliance Officer. We ensure the
confidentiality of the information contained in the report and expressly prohibit any form of
retaliation against the whistleblower.
Targets:
1. The Compliance Officer must inform the whistleblower of receipt of the report within
a maximum of 3 working days.

Working Conditions: The CT Engineering Group is dedicated to providing fair and conducive
working conditions to its employees. At CT we understand flexible working hours as a
mechanism of mutual benefit: company-employee. Flexibility allows the employee to better
reconcile and attend to personal commitments. For the company, it is a way to better adapt to
the needs of its clients and improve its performance, while at the same time contributing to
creating a better working environment. Part of the employee voice is giving people the
opportunity to express their concerns or ideas for potential improvement. At CT, there are
multiple processes to fuel continuous improvement: lessons learned, audits, innovation
proposals… but sometimes these feedback don’t fit into any of CT’s processes. A dedicated
process is therefore available for employees to propose any type of concern and feedback
related to working conditions.
Targets:
1. A working environment survey is sent every year. The objective, included in the
incentives of the managers, is to reach 90% in the last question of the survey: “I
definitely recommend to work in The CT Engineering Group to a friend of mine?”

Social Dialogue: We are committed to cultivating organised and constructive interactions with
employee representatives and trade unions, with the aim of facilitating fair and cooperative
decision-making. We actively seek to engage with and show consideration for employee
representatives, and are committed to supporting the creation of trade unions where employees
express a desire to do so, in compliance with applicable labour regulations. All employees have
the right to join trade unions, works councils or other collective bargaining groups.
Targets:
1. From 2025, the aim is to reach 95% of employees covered by formally-elected
employee representatives (work councils).

Career Management & Training: At CT, we’re committed to helping our employees build their
careers and continuously improve. We make sure everyone knows their job, responsibilities,
and what’s expected of them. As you progress, your technical career advances through Personal
Skill List (PSL) and the opportunity to take on different roles, all evaluated annually. We don’t tie
your salary to preset criteria but to your contributions and the depth of your role development,
while encouraging professional growth without requiring a move into management. We provide
opportunities for internal mobility, allowing you to explore new roles and challenges within the
company. Our aim is to support your career development and provide fair and equitable
compensation, emphasizing learning and growth. The Annual Evaluation Interview (AEI) is the
cornerstone of this policy: the AEI primary goals are to provide performance feedback, identify
training needs, create a clear training plan with specific goals and assess technical contributions.
Targets:
1. From 2023, 90% of employees who meet specific criteria (those with more than one
year’s seniority in CT and who remain employed) must complete an AEI.

Education and awareness: Promoting training to raise awareness and responsibility among all
personnel regarding labor and human rights practices.
Targets:
1. Starting in 2026, it is mandatory for 95% of newly onboarded CT employees to
receive training regarding the labor & human rights policy and its impact on their
day-to-day work.

Applicable laws and regulations: This policy will be implemented with a commitment to adhere
to the specific local labor & human rights laws and regulations at each site within the group.

Accountabilities: The annual Labor & Human Rights Committee, composed of the General
Manager, the COO and the Head of People & Culture, is responsible for overseeing the
company’s labor & human rights policy, ensuring its adherence, and promoting continuous
improvement. The Head of People & Culture will oversee the daily responsibilities of maintaining
a work environment that upholds labor and human rights, ensures compliance, and fosters
engagement of all stakeholders in our efforts to protect and promote these rights.

Review mechanism: This policy is reviewed annually in October to assess its effectiveness and
relevance, taking into account changes in laws and best practices. Any necessary updates are
made to ensure it remains aligned with our commitment to labor and human rights.

At The CT Engineering Group, we believe that respecting and upholding labor and human rights
is essential for the well-being of our employees and the sustainable growth of our organization.
We are dedicated to adhering to this policy to the highest standards and continuously improving
our practices.

This policy is communicated to all our internal stakeholders and is published on our intranet and
website.

December the 12th, 2024

Information Security Policy

The CT Engineering Group is committed to maintaining the highest standards of information security to ensure the confidentiality, integrity, and availability of information. This policy outlines the principles, guidelines, and rules that govern the protection of information and information systems against various threats. It is imperative that all employees understand and adhere to these principles to safeguard CT’s data and contribute to the company’s success.

Applicability: This policy applies to all sites within the CT Engineering Group. Every site is expected to adhere to the guidelines and principles outlined in this policy.

CT is continuously managing, exchanging and processing internal and external information of its customers and suppliers. Keeping in mind the values of the company, this policy outlines our objectives and commitments in key areas related to information security:

Engineering Enthusiasts: Embrace technology and innovation securely by adhering to established information security protocols in the development and delivery of creative solutions.

We Walk the Talk: Fulfill information security commitments consistently, ensuring that promises made regarding the security of data and information systems are upheld.

Moving Forward Together: Foster a teamwork environment that prioritizes integrity, actively listening to and empathizing with customers to exceed their expectations in information security.

Challenge Seekers: Encourage a culture of continuous improvement in information security, viewing challenges as opportunities for growth and excellence.

Policy Objectives

Customer-Centric Information Security: Implement and maintain an Information Security Management System (ISMS) to ensure the confidentiality (data managed by CT are accessible by authorized users only), integrity (data being accessed or read has neither been tampered with, nor been altered or damaged through a system error), and availability (data accessible when needed, ability to respond to emergency situations restoring the operation of critical services in the shortest time possible) of information.

Compliance and Regulations: Adhere to all applicable regulations, laws, and customer requirements related to information security.

Continuous Improvement: Embrace the principles of continuous improvement by regularly reviewing and updating information security measures.

Training and Awareness: Promote awareness and provide training in information security to all employees to enhance their understanding and adherence to security protocols.

Whistleblowing channel Reporting and Investigation: The CT Engineering group undertakes to investigate and settle any report received through the Compliance Officer. We ensure the confidentiality of the information contained in the report and expressly prohibit any form of retaliation against the whistleblower.

Employee Responsibility: All employees are responsible for
– Protecting information and information systems according to the principles outlined in this policy.
– Reporting any security incidents promptly.
– Carrying out the annual information security awareness.
Employees are strictly prohibited from using or installing any illegal software on any device, including personal computers, when accessing CT email accounts. Violation of this policy may
result in disciplinary action, up to and including termination of employment.

Annual Information Security Awareness: To ensure that all employees are equipped with the knowledge and skills required for effective information security practices, it is mandatory for every employee to complete the annual information security awareness. This training will serve
as an acknowledgment of their commitment to upholding the principles and guidelines outlined in this policy.

Information Security system based on ISO 27001: CT implements an information security management system based on the UNE-ISO 27001 standard in our headquarters. The scope of this certification is “The Information Systems that support the activities of engineering services for structures & systems for design, product support and manufacturing engineering”. Policies, procedures, and technical instructions are published on the intranet, along with a dedicated blog.
Users have access to the “Regulation of Use and Behavior Regarding Information Systems” document, which provides easily understandable guidelines and policies for end users.

Accountabilities: The annual Information Security Committee, composed of the General Manager, the COO and the Head of ITC&S, is responsible for overseeing the company’s
information security policy, ensuring its adherence, and promoting continuous improvement. The Head of ITC&S is empowered to oversee the daily responsibilities of maintaining a work environment that upholds information security, ensures compliance, and fosters engagement of all stakeholders in our efforts to protect the information data.

Review mechanism: This policy is reviewed annually in October to assess its effectiveness and relevance, taking into account changes in laws, customers’ requirements and best practices.

Any necessary updates are made to ensure it remains aligned with our commitment to information security.
The security of information is a collective responsibility. By adhering to this Information Security Policy, CT aims to create a secure environment that supports the company’s values and ensures the continuity and quality of our services.
This policy is communicated to all our internal stakeholders and is published on our intranet and website.

December the 5 th, 2023

Vicente Egea.
General Manager.

Business Ethics Policy

At the CT Engineering group, we are committed to maintaining the highest standards of ethics and integrity in all aspects of our business. Our values serve as the foundation for our actions and guide us in fostering a culture of trust, innovation, and customer satisfaction. The following
Business Ethics Policy outlines our principles and standards of behavior, ensuring a shared
commitment to ethical conduct among our employees and stakeholders.

Applicability: This policy applies to all sites within the CT Engineering Group. Every site is
expected to adhere to the guidelines and principles outlined in this policy.

Our commitment to excellence goes beyond engineering: it is ingrained in our values that shape the foundation of our organization. As Engineering Enthusiasts, we thrive on delivering innovative solutions to technological challenges. We are not merely providers of engineering services; we are a community of professionals who embrace challenges, uphold integrity, and work collaboratively to exceed customer expectations.

The link between our core values and the business ethics behaviors outlined in our policy is vital. Each provision in the code is a manifestation of our commitment to the principles that define us. Let’s explore how our values align with the specific policy provisions, creating a cohesive framework that guides our conduct and ensures ethical excellence.

Engineering Enthusiasts: Our dedication to delivering creative solutions and addressing
technological challenges sets the tone for professionalism and expertise. This policy aligns with
the expectation that all employees conduct themselves with the highest level of skill and commitment in their roles, ensuring the quality and innovation that our clients expect.

We walk the talk: Trust and consistency are the cornerstones of the CT Engineering group.
This provision directly aligns with our value of fulfilling commitments and delivering on promises. By emphasizing the importance of actions aligning with words, we ensure that our employees are trustworthy partners, fostering enduring relationships with customers, colleagues, and stakeholders.

Moving Forward Together: Our values extend beyond technology to include integrity and teamwork. This policy emphasizes the collaborative environment we strive to create. By actively listening to customer needs and empathizing with their challenges, employees contribute to a culture of teamwork that goes hand in hand with our commitment to integrity.

Challenge Seekers: Curiosity and a commitment to excellence drive our engineers to view
barriers as opportunities for growth. This policy encourages employees to embrace challenges,
contribute to CT’s growth, and constantly seek ways to improve and innovate. The provision
aligns with our value of being challenge seekers, demonstrating that we see ethical challenges
as opportunities for growth and improvement.

In essence, the business ethics policy is not merely a set of rules; it is a reflection of who we are
as a company. It amplifies our values, ensuring that every action taken by our employees resonates with the principles that define the CT Engineering Group. By integrating these values into our ethical standards, we create a workplace where integrity, professionalism, and innovation thrive, setting us apart in the engineering services industry.

Policy Provisions

Principles and Values
The CT Engineering Group upholds the following principles and values in all business activities:
– Integrity: Act with honesty, transparency, and accountability.
– Innovation: Foster a culture of continuous improvement and creative problem-solving.
– Customer-Centric: Prioritize customer needs and satisfaction.
– Teamwork: Collaborate effectively, valuing diverse perspectives.
– Excellence: Strive for the highest standards of performance and quality.

Ethical Standards

In alignment with our values, employees must adhere to the highest ethical standards, with specific attention to:

Corruption

Risk Related to Business:
Corruption poses a significant risk to the CT Engineering group’s reputation, legal standing, and business operations. In the engineering services industry, corruption may manifest as bribery, kickbacks, or unethical influence in procurement processes. Engaging in corrupt practices not only tarnishes our image but also jeopardizes our ability to secure contracts and maintain client trust.

Expected Behaviors:
Employees are expected to refrain from offering, soliciting, or accepting bribes, kickbacks, or
any other form of corrupt inducement. All business transactions and interactions must be conducted with transparency, integrity, and in compliance with applicable anti-corruption laws. Employees should report any instances of corruption promptly and cooperate fully in related
investigations.

Expected Managerial Behaviors:
Managers play a crucial role in setting the tone for ethical conduct within the organization. In addition to adhering to the expectations placed on employees, managers are expected to:
– Lead by Example: Demonstrate a commitment to transparency and integrity in all business
dealings.
– Promote a Culture of Integrity: Foster a work environment where ethical behavior is not just expected but actively promoted and celebrated.
– Provide Guidance: Offer guidance to employees on navigating ethical challenges and
addressing potential corrupt practices.
– Prompt Action: If instances of corruption are observed or reported, managers should take
immediate and appropriate action, escalating concerns to higher levels if necessary.

Money Laundering

Risk Related to Business:
The engineering services industry involves financial transactions, and the risk of money laundering arises when illicit funds are integrated into legitimate financial systems. Money
laundering not only exposes the CT Engineering group to legal consequences but also threatens
the stability of the financial sector and may lead to severe reputational damage.

Expected Behaviors:
Employees must be vigilant in recognizing and reporting any suspicious financial activities.
Compliance with anti-money laundering laws and regulations is mandatory. All financial transactions must be accurately documented, and employees should report any concerns
related to money laundering promptly. The CT Engineering group is committed to cooperating
with authorities to prevent and combat money laundering.

Expected Managerial Behaviors:
Managers have a responsibility to ensure the financial integrity of the organization. Their expected behaviors include:
– Financial Oversight: Exercise diligence in financial oversight to prevent and detect any suspicious financial activities within their teams.
– Educate and Train: Provide training and resources to help employees understand and comply with anti-money laundering regulations.
– Review Processes: Regularly review financial processes and documentation to identify
and rectify any potential vulnerabilities to money laundering.
– Report and Cooperate: Managers should promptly report any concerns related to money
laundering and cooperate fully with authorities in investigations.

Fraud

Risk Related to Business:
Fraudulent activities, such as misrepresentation of data, embezzlement, or false billing, can
have severe financial implications for the CT Engineering group. Fraud undermines the trust of
clients, partners, and stakeholders, leading to legal actions and potential loss of business opportunities.

Expected Behaviors:
Employees are expected to conduct their duties with honesty and accuracy. Any suspicion or
evidence of fraudulent activities must be reported immediately. All financial reporting, project
documentation, and communication must be truthful and adhere to the highest standards of professional conduct. A culture of accountability and transparency is essential to prevent and detect fraud within the organization.

Expected Managerial Behaviors:
Managers are instrumental in establishing a culture of accountability and transparency to prevent and detect fraud. Their expected behaviors include:
– Set Clear Expectations: Clearly communicate expectations for honest and accurate reporting to their teams.
– Create a Transparent Culture: Foster transparency within the team, encouraging open
communication about potential concerns related to fraud.
– Regular Audits: Conduct regular audits and reviews to ensure that financial reporting,
project documentation, and communication adhere to the highest standards.
– Address Issues Promptly: If fraudulent activities are suspected or identified, managers should take immediate action, involving relevant stakeholders and authorities as needed.

Conflict of Interest

Risk Related to Business:
In the engineering services sector, conflicts of interest may arise when personal interests of
employees interfere with their professional duties. This could lead to biased decision-making,
compromised project outcomes, and damage to the organization’s reputation.

Expected Behaviors:
Employees are required to disclose any potential or actual conflicts of interest promptly. This
includes situations where personal, familial, or financial interests could influence professional judgment. The CT Engineering group acknowledges that conflicts may arise, and the key is to manage and mitigate them appropriately. Transparency and proactive disclosure help maintain trust among clients, colleagues, and stakeholders. Employees should avoid situations that could compromise their objectivity and decision-making processes.

Expected Managerial Behaviors:
Managers play a key role in mitigating conflicts of interest within their teams. Their expected
behaviors include:
– Promote Disclosure: Encourage and ensure that team members disclose any potential conflicts of interest promptly.
– Provide Guidance: Offer guidance on managing conflicts of interest, helping employees
navigate situations that could compromise professional judgment.
– Monitor and Mitigate: Actively monitor for conflicts of interest within the team and take
steps to mitigate potential issues.
– Lead by Example: Demonstrate proactive disclosure and management of conflicts,
setting a standard for ethical behavior within the managerial ranks.

Whistleblowing channel
Reporting and Investigation: The CT Engineering group undertakes to investigate and settle any report received through the Compliance Officer. We ensure the confidentiality of the information contained in the report and expressly prohibit any form of retaliation against the whistleblower.

Employee Involvement and Awareness
To ensure the effective enforcement of this Business Ethics Code of Conduct, we encourage employee involvement and require the following:

Business Ethics Policy Awareness: To ensure that all employees are equipped with the knowledge and skills required for effective business ethics practices, it is mandatory for every employee to complete the business ethics policy awareness. This training will serve as an acknowledgment confirming their understanding and commitment to compliance.

Accountabilities: The annual Operations Committee, composed of the General Manager, the COO and the Country managers, are responsible for overseeing the company’s business ethics
policy, ensuring its adherence, and promoting continuous improvement. The COO is
empowered to oversee the daily responsibilities of maintaining a work environment that upholds
ethical standards, ensures compliance, and fosters engagement of all stakeholders in our efforts to banish unethical behavior.

Review mechanism: This policy is reviewed annually in October to assess its effectiveness and relevance, taking into account changes in laws, customers’ requirements and best practices.
Any necessary updates are made to ensure it remains aligned with our commitment to business
ethical behavior.

By adhering to these principles and values, the CT Engineering group aims to not only regulate
ethical risks but also demonstrate our dedication to operating in the public’s interest. Together, we uphold the highest standards of ethics, contributing to the success and reputation of the CT Engineering Group. We seek to mitigate the risks associated with corruption, money laundering,
fraud, and conflicts of interest, fostering a culture of integrity, transparency, and accountability
among its workforce.

This policy is communicated to all our internal stakeholders and is published on our intranet and
website.

Sustainable Procurement Policy

The CT Engineering Group, committed to excellence in engineering projects, recognizes the integral role of sustainable procurement in promoting environmental and social responsibility.

Applicability: This policy applies to all sites within the CT Engineering Group. Every site is
expected to follow the guidelines and principles outlined in this policy.

This policy outlines our commitment to ethical sourcing, environmental stewardship, and social responsibility in our procurement practices:

Environmental  Sustainability: We prioritize the procurement of products and services that demonstrate a commitment to environmental sustainability throughout their lifecycle, including responsible sourcing of raw materials, energy-efficient production, and environmentally conscious disposal. Our procurement decisions will favor suppliers who utilize renewable energy sources and adhere to sustainable energy practices in their manufacturing processes. Our sustainable procurement guideline (ETI-EN2-02) provides criteria to promote sustainable and responsible management of company’s purchasing and consumption. These criteria cover the need for the purchase, the manufacture, origin and components of the product, and the supplier’s commitment to the environment.

Social Responsibility: We are committed to engaging suppliers who uphold fair labor practices,
ensuring safe working conditions, fair wages, and compliance with human rights standards. We
encourage supplier diversity and inclusion, aiming to support businesses owned by underrepresented groups and fostering a diverse and inclusive supply chain.

Training for Buyers – Environmental and Social Awareness: All buyers within The CT Engineering Group will undergo training to raise awareness regarding environmental and social
responsibility in procurement activities. Training will include guidelines on ethical procurement
practices, emphasizing the importance of sustainable sourcing, fair labor practices, and
responsible business conduct.
Targets:
1. Starting in 2026, it is mandatory for 95% of CT employees whose roles involve them in the purchasing process to receive training on sustainable procurement and its impact on their day-to-day work.

Supplier Engagement through a Supplier Code of Conduct: All type 1 and 2(1) suppliers are required to adhere to The CT Engineering Group’s Supplier Code of Conduct, outlining environmental, social, and ethical standards that align with our commitment to sustainability. Our supplier code of conduct covers the compliance with laws, the labor & human rights(Diversity, Discrimination & Harassment, Child and Forced Labor, Working Conditions, Social
Dialogue and Career Management & Training), the business ethics (Corruption, Money Laundering, Fraud, Conflict of Interest, Information Security), the health & safety (Safe work environment, Incidents and Accidents Reduction, Hazard Identification and Risk Management, Incident Reporting and Investigation, Emergency Preparedness), the environment (Energy Consumption, Greenhouse Gas Emissions Reduction, Waste Management and Recycling), the need of a whistleblowing channel, the need of associated training.
Targets:
1. From 2026, 95% of CT type 1 and 2(1) suppliers must have signed the supplier code
of conduct.
(1) Engineering suppliers and suppliers under non-disclosure agreement.

Engineering Suppliers Engagement through Framework Contracts: We engage engineering suppliers through the establishment of framework contracts that include specific sustainability criteria. These criteria will outline expectations for environmental performance, ethical practices, and social responsibility.
Targets:
1. From 2026, 95% of CT engineering suppliers (type 1) must have signed the CT
framework contracts that include specific sustainability criteria.

Applicable laws and regulations: This policy will be implemented with a commitment to adhere to the specific local environmental laws and regulations at each site within the group.

Accountabilities: The annual Operations Committee, composed of the General Manager, the COO and the Country managers, are responsible for overseeing the company’s sustainable procurement policy, ensuring its adherence, and promoting continuous improvement. The COO is empowered to oversee the daily responsibilities of maintaining a work environment that upholds sustainable procurement practices, ensures compliance, and fosters engagement of all purchasing stakeholders.

Review mechanism: This policy is reviewed annually in October to assess its effectiveness and relevance, taking into account changes in regulations and best practices. Any necessary updates are made to ensure it remains aligned with our commitment to sustainable procurement.

At The CT Engineering Group, we view sustainable procurement as a crucial aspect of our responsibility to the environment and society.

This policy is communicated to all our internal stakeholders and is published on our intranet and
website.