Cromwell European REIT - Annual Report 2021

The Manager conducts compulsory training on subjects such as bullying and sexual and racial harassment. All employees also undertake diversity and subconscious bias awareness training. The Manager has established a D&I committee which meets quarterly to organise and implement programmes to encourage awareness. The Manager undertakes an annual employee’s engagement survey, conducted independently through Culture Amp, which is benchmarked against the Sponsor’s larger employee cohort and real estate industry standards. In FY 2021, the Manager’s employees registered an average of 89/100 score on the employee engagement survey, well above the standard of 65. The equality score was 83/100 while the work environment score was recorded as 92/100. Further results will be released in the FY 2021 Sustainability Report in late May 2022. Bribery and Corruption Prevention Policy The Manager adopts a strong stance against bribery and corruption. In addition to clear guidelines and procedures for the giving and receipt of corporate gifts and concessionary offers, all employees of the Manager are expected to uphold the Manager’s core values and not to engage in any corrupt or unethical practices. The Manager has adopted the Anti-Bribery and Anti- Corruption Policy which sets out the responsibilities of CEREIT and the Manager and of each employee in observing and upholding the Manager’s ‘zero tolerance’ position against all forms of corruption, bribery and extortion, and provides information and guidance to employees on how to recognise, address, resolve, avoid and prevent instances of corruption, bribery and extortion, including the Manager’s stance against facilitation payments and kickbacks which may arise in the course of their work. In FY 2021, to the best of its knowledge, the Manager (i) is in full compliance with all relevant modern slavery legislation, (ii) zero significant monetary fines or non- monetary sanctions incurred for non-compliance with environmental laws and regulations, (iii) zero non- compliance with laws and regulations in the social and economic area, (iv) zero fines for non-compliance concerning product and service information labelling and (v) zero incidents of non-compliance concerning health and safety impacts of products and services, (vi) zero incidents of reported corruption, (vii) zero legal actions for anticompetitive behaviour and anti-trust of monopoly practices. The Manager reported no lost days or deaths due to work injuries. Further details of its ESG review will be released in the Annual Sustainability Report. In addition to the Anti-Bribery and Anti-Corruption Policy, the Manager has adopted a series of measures to prevent corruption and unethical behaviour. These include: (a) outlining the responsibilities of all employees to uphold anti-corruption and anti-bribery principles; (b) informing and guiding employees on how to pre-emptively identify and avoid instances of corruption; (c) implementing policies such as the Supplier Code of Conduct that outline standards of conduct expected suppliers and agents acting on behalf of the Manager; and (d) implementing zero tolerances for breaches and gateway thresholds for STI/LTI incentives requiring complying with the Manager’s code of conduct and ethical behaviour standards. In 2021, all of the Manager’s employees received mandatory communication and training on anti-bribery and anti-corruption policies and procedures. As an entity of the Sponsor, the Manager adopts and adheres to the Sponsor’s key policies which aims to establish and reinforce the highest standards of integrity and ethical business practices and all the Manager’s employees are expected to adhere and stand guided by these policies. The Manager’s Anti-Bribery and Anti-Corruption Policy extends to its business dealings with associated persons who are third parties that represent or who perform services on behalf of CEREIT and the Manager also known as associated persons Where there is a greater level of bribery or corruption risk attached to any particular area of business or when working with an associated person, due diligence checks and processes are in place to adequately address and mitigate the risk(s). This includes ethical CORPORATE GOVERNANCE FOCUS ON STRENGTHS PIVOT TO LOGISTICS 182