\n
Labor & Human Rights Policy<\/h3>\n
<\/p>\n
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.<\/p>\n
Applicability:<\/strong>\u00a0<\/span>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.<\/p>\nThis policy outlines our\u00a0<\/span>objectives and commitments<\/strong>\u00a0<\/span>in key areas related to labor and human rights:<\/p>\nDiversity, Discrimination & Harassment:<\/strong>\u00a0<\/span>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:<\/strong>
1. The goal is to reach 50% of employees trained on discrimination and harassment
by 2030.<\/p>\nChild and Forced Labor:<\/strong>\u00a0<\/span>The CT Engineering Group unequivocally condemns child and forced
labor, as well as human trafficking.
Targets:<\/strong>
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 zero tolerance policy. The objective is to ensure that 100% of our engineering suppliers have the relevant clause approved within our supplier framework contract by 2026.<\/p>\nWhistleblowing channel Reporting and Investigation:<\/strong>\u00a0<\/span>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:<\/strong>
1. The Compliance Officer must inform the whistleblower of receipt of the report within
a maximum of 3 working days.<\/p>\nWorking Conditions:<\/strong>\u00a0<\/span>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\u2026 but sometimes these feedback don\u2019t fit into any of CT\u2019s processes. A dedicated
process is therefore available for employees to propose any type of concern and feedback
related to working conditions.
Targets:<\/strong>
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: \u201cI definitely recommend to work in The CT Engineering Group to a friend of mine?\u201d<\/p>\nSocial Dialogue:<\/strong>\u00a0<\/span>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:<\/strong>
1. From 2023, the aim is to reach 90% of employees covered by formally-elected
employee representatives (work councils).<\/p>\nCareer Management & Training:<\/strong>\u00a0<\/span>At CT, we\u2019re committed to helping our employees build their careers and continuously improve. We make sure everyone knows their job, responsibilities,
and what\u2019s 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\u2019t 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:<\/strong>
1. From 2023, 90% of employees who meet specific criteria (those with more than one
year\u2019s seniority in CT and who remain employed) must complete an AEI.<\/p>\nEducation and awareness:<\/strong>\u00a0<\/span>Promoting training to raise awareness and responsibility among all personnel regarding labor and human rights practices.
Targets:<\/strong>
1. Starting in 2025, 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.<\/p>\nApplicable laws and regulations:<\/strong>\u00a0<\/span>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.<\/p>\nAccountabilities:<\/strong>\u00a0<\/span>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\u2019s 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.<\/p>\nReview mechanism:<\/strong>\u00a0<\/span>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.<\/p>\nAt 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.<\/p>\n
This policy is communicated to all our internal stakeholders and is published on our intranet and
website.<\/p>\n
November the 11th, 2023<\/p>\n
<\/p>\n<\/div>\n
\n
Information Security Policy<\/h3>\n
<\/p>\n
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\u2019s data and contribute to the company\u2019s success.<\/p>\n
Applicability:<\/strong>\u00a0<\/span>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.<\/p>\nCT 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:<\/p>\n
Engineering Enthusiasts:<\/strong>\u00a0<\/span>Embrace technology and innovation securely by adhering to established information security protocols in the development and delivery of creative solutions.<\/p>\nWe Walk the Talk:<\/strong>\u00a0<\/span>Fulfill information security commitments consistently, ensuring that promises made regarding the security of data and information systems are upheld.<\/p>\nMoving Forward Together:<\/strong>\u00a0<\/span>Foster a teamwork environment that prioritizes integrity, actively listening to and empathizing with customers to exceed their expectations in information security.<\/p>\nChallenge Seekers:<\/strong>\u00a0<\/span>Encourage a culture of continuous improvement in information security, viewing challenges as opportunities for growth and excellence.<\/p>\nPolicy Objectives<\/strong><\/p>\nCustomer-Centric Information Security:<\/strong>\u00a0<\/span>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.<\/p>\nCompliance and Regulations:<\/strong>\u00a0<\/span>Adhere to all applicable regulations, laws, and customer requirements related to information security.<\/p>\nContinuous Improvement:<\/strong>\u00a0<\/span>Embrace the principles of continuous improvement by regularly reviewing and updating information security measures.<\/p>\nTraining and Awareness:<\/strong>\u00a0<\/span>Promote awareness and provide training in information security to all employees to enhance their understanding and adherence to security protocols.<\/p>\nWhistleblowing channel Reporting and Investigation:<\/strong>\u00a0<\/span>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.<\/p>\nEmployee Responsibility:<\/strong>\u00a0<\/span>All employees are responsible for
\u2013 Protecting information and information systems according to the principles outlined in this policy.
\u2013 Reporting any security incidents promptly.
\u2013 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.<\/p>\nAnnual Information Security Awareness:<\/strong>\u00a0<\/span>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\u00a0<\/span>acknowledgment of their commitment to upholding the principles and guidelines outlined in this policy.<\/strong><\/p>\nInformation 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 \u201cThe Information Systems that support the activities of engineering services for structures & systems for design, product support and manufacturing engineering\u201d. Policies, procedures, and technical instructions are published on the intranet, along with a dedicated blog.
Users have access to the \u201cRegulation of Use and Behavior Regarding Information Systems\u201d document, which provides easily understandable guidelines and policies for end users.<\/p>\n
Accountabilities:<\/strong>\u00a0<\/span>The annual Information Security Committee, composed of the General Manager, the COO and the Head of ITC&S, is responsible for overseeing the company\u2019s
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.<\/p>\nReview mechanism:<\/strong>\u00a0<\/span>This policy is reviewed annually in October to assess its effectiveness and relevance, taking into account changes in laws, customers\u2019 requirements and best practices.<\/p>\nAny 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\u2019s 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.<\/p>\n
December the 5 th, 2023<\/p>\n
Vicente Egea.
General Manager.<\/p>\n
<\/p>\n<\/div>\n
\n
Business Ethics Policy<\/h3>\n
<\/p>\n
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.<\/p>\n
Applicability:<\/strong>\u00a0<\/span>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.<\/p>\nOur 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.<\/p>\n
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\u2019s explore how our values align with the specific policy provisions, creating a cohesive framework that guides our conduct and ensures ethical excellence.<\/p>\n
Engineering Enthusiasts:<\/strong>\u00a0<\/span>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.<\/p>\nWe walk the talk:<\/strong>\u00a0<\/span>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.<\/p>\nMoving Forward Together:<\/strong>\u00a0<\/span>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.<\/p>\nChallenge Seekers:<\/strong>\u00a0<\/span>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\u2019s 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.<\/p>\nIn 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.<\/p>\n
Policy Provisions
<\/strong>
Principles and Values<\/strong>
The CT Engineering Group upholds the following principles and values in all business activities:<\/strong>
\u2013 Integrity: Act with honesty, transparency, and accountability.
\u2013 Innovation: Foster a culture of continuous improvement and creative problem-solving.
\u2013 Customer-Centric: Prioritize customer needs and satisfaction.
\u2013 Teamwork: Collaborate effectively, valuing diverse perspectives.
\u2013 Excellence: Strive for the highest standards of performance and quality.<\/p>\nEthical Standards
<\/strong>
In alignment with our values, employees must adhere to the highest ethical standards, with specific attention to:<\/p>\nCorruption<\/p>\n
Risk Related to Business:
Corruption poses a significant risk to the CT Engineering group\u2019s 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.
<\/strong>Expected Behaviors:
<\/strong>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.<\/p>\nExpected 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:
\u2013 Lead by Example: Demonstrate a commitment to transparency and integrity in all business
dealings.
\u2013 Promote a Culture of Integrity: Foster a work environment where ethical behavior is not just expected but actively promoted and celebrated.
\u2013 Provide Guidance: Offer guidance to employees on navigating ethical challenges and
addressing potential corrupt practices.
\u2013 Prompt Action: If instances of corruption are observed or reported, managers should take
immediate and appropriate action, escalating concerns to higher levels if necessary.<\/p>\n
Money Laundering
<\/strong>
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.<\/p>\nExpected 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.<\/p>\n
Expected Managerial Behaviors:
Managers have a responsibility to ensure the financial integrity of the organization. Their expected behaviors include:
\u2013 Financial Oversight: Exercise diligence in financial oversight to prevent and detect any suspicious financial activities within their teams.
\u2013 Educate and Train: Provide training and resources to help employees understand and comply with anti-money laundering regulations.
\u2013 Review Processes: Regularly review financial processes and documentation to identify
and rectify any potential vulnerabilities to money laundering.
\u2013 Report and Cooperate: Managers should promptly report any concerns related to money
laundering and cooperate fully with authorities in investigations.<\/p>\n
Fraud
<\/strong>
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.<\/p>\nExpected 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.<\/p>\n
Expected Managerial Behaviors:
Managers are instrumental in establishing a culture of accountability and transparency to prevent and detect fraud. Their expected behaviors include:
\u2013 Set Clear Expectations: Clearly communicate expectations for honest and accurate reporting to their teams.
\u2013 Create a Transparent Culture: Foster transparency within the team, encouraging open
communication about potential concerns related to fraud.
\u2013 Regular Audits: Conduct regular audits and reviews to ensure that financial reporting,
project documentation, and communication adhere to the highest standards.
\u2013 Address Issues Promptly: If fraudulent activities are suspected or identified, managers should take immediate action, involving relevant stakeholders and authorities as needed.<\/p>\n
Conflict of Interest
<\/strong>
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\u2019s reputation.<\/p>\nExpected 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.<\/p>\n
Expected Managerial Behaviors:
Managers play a key role in mitigating conflicts of interest within their teams. Their expected
behaviors include:
\u2013 Promote Disclosure: Encourage and ensure that team members disclose any potential conflicts of interest promptly.
\u2013 Provide Guidance: Offer guidance on managing conflicts of interest, helping employees
navigate situations that could compromise professional judgment.
\u2013 Monitor and Mitigate: Actively monitor for conflicts of interest within the team and take
steps to mitigate potential issues.
\u2013 Lead by Example: Demonstrate proactive disclosure and management of conflicts,
setting a standard for ethical behavior within the managerial ranks.<\/p>\n
Whistleblowing channel
Reporting and Investigation:<\/strong>\u00a0<\/span>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.<\/p>\nEmployee Involvement and Awareness<\/strong>
To ensure the effective enforcement of this Business Ethics Code of Conduct, we encourage employee involvement and require the following:<\/p>\nBusiness Ethics Policy Awareness:<\/strong>\u00a0<\/span>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.<\/p>\nAccountabilities:<\/strong>\u00a0<\/span>The annual Operations Committee, composed of the General Manager, the COO and the Country managers, are responsible for overseeing the company\u2019s 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.<\/p>\nReview mechanism:<\/strong>\u00a0<\/span>This policy is reviewed annually in October to assess its effectiveness and relevance, taking into account changes in laws, customers\u2019 requirements and best practices.
Any necessary updates are made to ensure it remains aligned with our commitment to business
ethical behavior.<\/p>\nBy 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\u2019s 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.<\/p>\n
This policy is communicated to all our internal stakeholders and is published on our intranet and
website.<\/p>\n
<\/p>\n<\/div>\n
\n
Sustainable Procurement Policy<\/h3>\n
<\/p>\n
The CT Engineering Group, committed to excellence in engineering projects, recognizes the integral role of sustainable procurement in promoting environmental and social responsibility.<\/p>\n
Applicability:<\/strong>\u00a0<\/span>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.<\/p>\nThis policy outlines our\u00a0<\/span>commitment<\/strong>\u00a0<\/span>to ethical sourcing, environmental stewardship, and social responsibility in our procurement practices:<\/p>\nEnvironmental\u00a0 Sustainability:<\/strong>\u00a0<\/span>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\u00a0<\/span>sustainable procurement guideline<\/strong>\u00a0<\/span>(ETI-EN2-02) provides criteria to promote sustainable and responsible management of company\u2019s purchasing and consumption. These criteria cover the need for the purchase, the manufacture, origin and components of the product, and the supplier\u2019s commitment to the environment.<\/p>\nSocial Responsibility:<\/strong>\u00a0<\/span>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.<\/p>\nTraining for Buyers \u2013 Environmental and Social Awareness:<\/strong>\u00a0<\/span>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:<\/strong>
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.<\/p>\nSupplier Engagement through a Supplier Code of Conduct:<\/strong>
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