Purpose

The purpose of this Policy is to define the general principles and provide a basis for Civinity group’s business culture and practices as well as approach to corporate responsibility when it comes to Environmental, Social and Governance (ESG) areas.

Scope

The Policy applies to and covers Civinity group’s business activities in all countries where Civinity group operates. All the employees of Civinity group, and non-permanent staff working on behalf of the Group, are subject to this Policy. This Policy also applies to all partners, clients and other stakeholders who have a relationship with the company.

Definitions

Employee shall mean a person who has an employment relationship with the Civinity group, including Managers, Top Executives, Members of Management Boards.

ESG shall mean environmental, social and governance areas.

Policy shall mean Civinity group’s ESG Policy; this document.

The Parent Company shall mean Civinity, AB (legal entity code 302247881).

Group shall mean the Parent Company and its subsidiaries (including lower-tier subsidiaries), also subsidiaries with head offices located in foreign countries wherein it directly and/or indirectly holds a majority of the voting rights or it may directly or indirectly exercise a dominant influence.

Sustainability Strategy shall mean specific goals and a prioritised set of actions agreed in regards to the implementation of environmental, social and governance areas that are material to the Civinity Group.

Sustainable Development Goals shall mean the agreement reached by all United Nations members in 2015 on a common agenda for global development by 2030. It is based on the 17 Sustainable Development Goals, which include the pursuit of peace, welfare and the broad prosperity of humankind and the planet now and in the future, as well as promoting partnerships to achieve these goals.

The European Green Deal shall mean a roadmap for action presented by the European Commission on 11 December 2019, aiming to make Europe the first climate-neutral continent by 2050, boosting the economy, improving human health and the quality of life, caring for nature and leaving no one behind.

Paris Agreement shall mean an agreement between states to strengthen the global response to the threats posed by climate change. The aim is to limit the increase in the average temperature of the earth to 2 °C compared to the pre-industrial level and to continue to aim to limit the increase of the average earth temperature to no higher than 1.5 °C.

Principles for Sustainability

Civinity group defines its sustainability impact by focusing on the key four strategic areas:

• Climate action. Reducing the amount of energy required to provide products and services while also reducing the amount of greenhouse gases generated by the company’s activities.
• Care for employees. Creating a safe and comfortable working environment, providing various development opportunities and organising work and processes to ensure employee satisfaction and well-being. Ensuring fair remuneration, employee empowerment and retention.
• Service quality & efficiency. Providing services in an innovative, efficient, resources-saving manner and striving for high-quality and continuous improvement of services to provide greater benefit for customers.
• Good governance practices. Taking action to prevent corruption and bribery, and protect personal data of clients, employees, and partners. Incorporating ESG aspects into corporate governance practices.

Through its strategic activities, Civinity group also seeks to make a positive contribution to the UN’s Sustainable Development Goals, focusing on goals:

3 – Good health and well-being

7 – Affordable and clean energy

8 – Decent work and economic growth

9 – Industry, innovation and infrastructure

10 – Reduced Inequalities

13 – Climate action

16 – Peace, justice and strong institutions

The organisation commits to protecting the environment, people and society, through responsible management of its operations, by complying with environmental and social obligations, and by working proactively on the topics covered in this document.

1. Environmental

Civinity group contributes to the implementation of the European Green Deal and the Paris Agreement, with a commitment to reduce net CO2 emissions to zero by 2050.

1.1 Efficient energy use

Reducing the amount of energy required to provide products and services is the main objective in this area.

• We buy energy from green sources for office maintenance.
• We use LED energy saving systems for office lighting.

1.2 Carbon footprint

When it comes to mitigating actions against climate change, monitoring carbon emissions is key. For Civinity group this means reducing the amount of greenhouse gases generated by the company’s activities.

• We seek to monitor our own carbon footprint by calculating greenhouse gas emissions (Scope 1 & 2) according to GHG Protocol.
• We are determined to achieve net zero GHG emissions throughout the entire value chain by 2050.
• We are a proud member of Tech Zero UK proving our commitment to moving towards net zero.
  
  

2. Social

Below is an overview of Civinity group’s position regarding the social aspects of the organisation. Our aim is to create a safe and comfortable working environment for the employees. We aim to provide various development opportunities and organise work and other processes in a manner that ensures employee satisfaction and well-being. While caring for our people, we ensure strict compliance with applicable laws, regulations and standards and apply fair remuneration principles to ensure employee retention.

2.1 Good working conditions & well-being

Creating a safe and comfortable working environment is one of the main priorities for Civinity group. Moreover, the company also focuses on organising work and processes to ensure employee satisfaction and well-being.

• We provide personalised benefit packages to our employees. This includes but is not limited to health insurance, mental health apps/consultations, additional training budget, etc.

2.2 Training & development opportunities

One of the main goals at Civinity group is to provide opportunities to all employees to constantly develop their skills. We do this by implementing the following:

• Providing job training to all employees. Individual, corporate and specialised trainings are available depending on the career path and job needs.
  
  

2.3 Health & safety

Our objective is to ensure employee safety, follow regulations and procedures to prevent accidents or injuries in the workplaces and public environments. We therefore adhere to the following principles:

• We provide adequate control of the health and safety risks arising from our work activities to our employees.
• We continuously put measures in place to make sure accidents do not reoccur.
• Our processes ensure employees are trained in accordance with the latest regulations to

meet the health & safety standards.

2.4 Fair remuneration

Civinity group’s objective is to ensure fair pay to all employees and partners, and additional incentives based on achieved results. We adhere to the following principles:

• We guarantee equal pay for equal work with no discrimination on the grounds of race, age, role, gender, colour, religion, country of origin or disability.
• We comply with all the local rules and regulations for all the remuneration related matters.
  
  

2.5 Involving, empowering employees

We care to involve employees in the decision-making processes, ensure the possibility to make independent decisions and give them the freedom to act on them. To ensure that:

• We regularly interview our employees on their workplace satisfaction and put strategic goals in place to improve them.
• We ensure our employees are able and are encouraged to support our sustainability commitments and get involved where they want to.
• We run an internal ambassadorship program, which allows employees to engage in the internal activities and share their thoughts on internal organisational processes.
• We encourage autonomous decision making processes.
  
  

2.6 Employee retention & recruitment

Our long term goal is to prevent employee turnover, attract the right fit candidates, and invest in future talent.

• We strive to be a first-class employer who recognizes the potential of each individual employee and manager and develops their skills and competences through regular training.
• We regularly work on employee turnover reduction plans.
• We collaborate with local schools and universities to nurture talent.
  
  

3. Economic

Below is an overview of Civinity’ groups position regarding our economic sustainability. Our aim is a sustainable and balanced business development through improving service efficiency, and ensuring competitive advantage by providing high quality services.

3.1 Service efficiency

Civinity group’s main objective in this area is to provide services in an innovative, efficient and resources-saving manner.

• We strive to ensure resource (energy, labour, time) efficiency and sustainability across all operations.
• We continuously search for and implement digital solutions to improve efficiency.
• We invest into companies and solutions that reduce our footprint and improve our sustainability performance.
  
  

3.2 Competitive advantage (service quality)

High-quality and continuous improvement of services to provide greater benefit for customers is one of Civinity group’s strategic priorities.

• We strive to maintain reliable high standards of quality in accordance with the requirements of our customers.
• We attach great importance to customer satisfaction and strive for clear and effective communication with customers.
• We create added value for our customers through offering innovative services which help to improve energy efficiency and sustainability of our clients.
• We aim to be responsible members of communities in which we operate and strive for open and honest community engagement, where collaboration, social inclusion and listening are essential.
  
  

4. Governance

While developing its business, Civinity group ensures sustainability through compliance with applicable laws, regulations and standards, and protection of the personal data of our clients, employees and partners.

4.1 Compliance & anti-corruption

While developing its business, Civinity group strives to adhere to all the relevant laws, guidelines, norms, and regulations. The company implements a zero-tolerance approach to bribery and corruption.

• We ensure strict compliance with applicable laws, regulations, standards and requirements of our internal and external stakeholders.
• We provide support to employees and maintain open dialogue regarding understanding and meeting the Civinity group’s ethical values.
• We do not tolerate any forms of corruption irrespective of the form or degree of their occurrence.
• We do everything in our power to prevent bribery and corruption in the relationships with our suppliers, subcontractors, and other business partners.

4.2 Data protection

Protection and security of the personal data of its customers and employees, and the business data of its clients and third parties, is of great importance to Civinity group.

• We protect personal and business data through strict internal safeguards and policies.
• We ensure compliance to EU General Data Protection Regulation (GDPR).
  
  

5. Implementation measures for ESG principles

5.1 Implementation measures

Pursuant to the principles of this Policy, the material topics for environmental, social and governance areas shall be identified, ESG goals shall be established, and objectives shall be formulated, which, in their own right, shall be integrated into general business plans of the Civinity group. Results shall be monitored periodically, and processes shall be audited by assessing the performance in accordance with internal and external standards.

Civinity group undertakes to regularly review the environmental, social and economic impact and the priorities of its sustainability activities (materiality assessment), taking into account the expectations of stakeholders and the latest available scientific information.

5.2 Responsible officers

Anonymous reports on potential ESG Policy violations can be submitted by email esg@civinity.com.

Civinity group shall implement all measures to protect persons notifying violations of the Policy against any negative consequences: the e-mail address referred to above shall only be accessed by designated officer, who shall assume the obligation to not disclose the identity of notifying persons to any employees or other third parties.

All notices about possible violations of the Policy must be appropriately examined by persons appointed by Civinity, AB.

6. Final provisions

• The Policy shall be approved and amended by the decision of the Management Board of Civinity group.
• Civinity, AB designated officer shall be responsible for annually reviewing and, where needed, updating the Policy.
• Each Civinity group employee shall be responsible for following the ESG principles set out in the Civinity group’s Sustainability Strategy.
• Civinity, AB designated officers’ shall be responsible for implementation and control of this Policy’s measures.
• All Group employees must be introduced to the Policy and each one of them must apply the principles of this Policy in their work.
• The Policy shall be made publicly available on the websites of the Civinity group companies.
• The Policy shall apply to the extent it is not in conflict with EU laws and/or other enforced legal acts of the Republic of Lithuania.