Cromwell European REIT - Annual Report 2021

standards audit and corruption risk assessment as part of the ERM process Modern Slavery Statement As a part of the Sponsor group, the Manager has adopted the Modern Slavery Statement which is in line with significant global regulatory changes affecting CEREIT, the Manager and the Sponsor’s operations such as the U.K. Modern Slavery Act 2015 and Australia Modern Slavery Act 2018 which established additional reporting requirements for large organisations to respond to the risk of modern slavery in their operations and supply chains. The Sponsor has published a Anti-Slavery and Human Trafficking Statement that is publicly available on the Sponsor’s website https://www.cromwellpropertygroup.co.uk/__ data/assets/pdf_file/0026/27458/Anti-Slavery-and- Human-Trafficking-Statement.pdf and covers CEREIT’s European property management operations and the Manager’s operations. Supplier Code of Conduct A Supplier Code of Conduct which sets out CEREIT’s and the Manager’s expectations of suppliers to comply with relevant laws, including but not limited to those governing consumer protection, environment, social, anti-competition, human rights, modern slavery and health, safety and welfare laws, is also in place. Service providers assessed to have higher risks in their supply chain in their approach to modern slavery are generally required to sign a Supplier Code of Conduct which includes a modern slavery commitment prior to engagement or renewal. Whistle-Blowing Policy A whistle-blowing policy which is published on CEREIT’s website at https://www.cromwelleuropeanreit.com.sg/ assets/whistle-blower-policy/whistle-blower-statement and other procedures are put in place to provide well defined, accessible and trusted channels by which a person or entity, including but not limited to employees, applicants for employment, contract workers, vendors, purchasers, contractors or the general public may make a report either anonymously or otherwise, of suspected fraud, corruption, dishonest practices or other improprieties in the workplace. The objectives of the whistle-blowing policy are to encourage the reporting of such matters so that employees or external parties making any reports in good faith will be able to do so with the confidence that they will be treated fairly and be protected from reprisal and to set out the processes for the independent investigation of any reported incidents and appropriate follow up action. To the extent possible under the law, the Manager is committed to maintaining procedures for the confidential submission of reports and protection of the identity of the whistle-blower. Investigations of such reports will be handled on a confidential basis to the extent permissible or deemed appropriate under the law and involve persons who need to be involved in order to properly carry out the investigations and will, on a best-efforts basis, be carried out in a timely manner. In order to facilitate and encourage the reporting of such matters, the whistle-blowing policy, together with the dedicated whistle-blowing communication channels (email and postal address) are available on CEREIT’s website and intranet and is easily accessible by all including third parties. To ensure that the whistle-blowing policy can be adopted and understood by all parties, the Manager has translated the key elements of the whistle-blowing policy into working languages of the countries in which it operates in. The Manager has engaged KPMG to provide an independent platform for employees as well as external parties such as customers, suppliers, contractors and applicants for employment, to raise concerns in good faith about any perceived irregularity or misconduct, without fear of reprisal. Concerns about illegal, unprofessional, fraudulent or other unethical behaviour may be referred to the independently managed ethics email at CEREITwhistleblower@kpmg.com.sg . Following a review of the complaint or concern, the Chair of the ARC, where appropriate, will take steps to ensure that matters are appropriately investigated and keep the Board apprised, and if warranted, will request that the Board and Management implement corrective measures. CROMWELL EUROPEAN REIT 183 ANNUAL REPORT 2021