Responsible behaviour

Ethics and transparency

At Carmila, doing our job well as a commercial real estate player also means exercising our responsibilities with high standards, discernment, and a sense of the common good. The professionalism of each individual and the quality of our conduct are central to the trust we build with our tenant brands, our partners, our shareholders, and the communities where we operate.

Our ethical principles formalize the framework within which we conduct our business. They contribute to spreading and fostering a culture of trust, integrity and transparency within the company.

These principles help each employee reflect on the appropriate attitude to adopt, particularly when faced with sensitive situations. They are championed by Carmila's General Management, disseminated to all employees, and integrated into the onboarding process for new hires.

This framework, which every employee must know and respect, is part of internationally recognized commitments: the Universal Declaration of Human Rights, the fundamental conventions of the International Labour Organization (ILO), the OECD guidelines, the United Nations Global Compact and other international standards on human rights, the fight against corruption and social responsibility.

Carmila's main ethical principles are as follows:

• respect diversity and promote equal opportunities;
• contribute to a safe, healthy and inclusive work environment;
• prioritize social dialogue and consultation;
• reject all forms of harassment and discrimination;
• select and deal with suppliers and service providers with objectivity, loyalty and transparency;
• develop responsible and balanced relationships with our tenant brands and our business partners;
• respect our contractual commitments and deadlines towards all our stakeholders;
• to refrain from any collusion, anti-competitive practice or unfair maneuver;
• ensuring the safety of people and property on our sites;
• to protect the company's resources, data and assets;
• to ensure the confidentiality of sensitive or personal information;
• preserve the environment in the management and transformation of our shopping centers;
• to be honest, individually and collectively, in all our decisions;
• produce reliable, accurate and verifiable reporting;
• avoid conflicts of interest and report them when they occur;
• reject all forms of corruption, fraud, influence peddling or money laundering.

Carmila provides a professional alert system that allows employees, suppliers, service providers, and other stakeholders to confidentially report situations or behaviors that violate our ethical principles. This system, operated by a trusted third party, guarantees the confidentiality of communications, data protection, and the absence of retaliation against those who report in good faith.

Fight against corruption

Carmila applies a zero-tolerance policy towards any form of corruption, fraud, or influence peddling. Integrity in business is a fundamental aspect of our model and is essential to the trust placed in us by our tenant brands, investors, service providers, and all our partners.

Carmila's employees and partners are made aware of these issues through our code of conduct and ethical principles, which establish a clear framework: every employee must know them, respect them, and integrate them into their daily decisions. This framework notably reiterates the major commitments stemming from key international texts (human rights, International Labour Organization standards, the fight against corruption, etc.).

Carmila's ethical principles are integrated into our supplier commitment charters. Our suppliers and service providers thus contractually commit to adopting fair, transparent, and compliant business practices.

To ensure compliance with these principles, Carmila has implemented:

• an ethics governance structure attached to the General Management
• an anti-corruption compliance system (internal policies, procedures, ...);
• targeted training and awareness-raising actions (gifts and invitations, conflicts of interest, relations with authorities, etc.).

A professional alert system also allows employees, suppliers, and other partners to confidentially report any suspicious situation or behavior that violates our principles (suspected corruption, fraud, undeclared conflict of interest, etc.). This system, managed by a trusted third party, guarantees:

• the confidentiality of the information transmitted,
• the protection of the identity of whistleblowers,
• the absence of reprisals against people who report in good faith.

Carmila's anti-corruption prevention and control system is part of the overall internal control system and is regularly reviewed and evaluated, particularly in the context of internal audit work.