Urban Logistics REIT PLC – Supply Chain Code of Conduct

This document details the supply chain code of conduct (“the Code”) of Urban Logistics REIT PLC (“the Company”), outlining the expectations the Company holds of individuals and organisations providing services to the Company. The code covers key issues and the standards the Company expects suppliers to meet.

The Company is committed to acting with integrity and fairness at all times and expects this approach to be reflected throughout our supply chain. This Code seeks to lay the groundwork for a collaborative approach to key social issues with our suppliers to rout out unfair, unethical and oppressive practices, and the Company expects these standards to be incorporated not only within our supplier's organisations but throughout their supply chains.

The Company welcomes discussion with our suppliers or the public on any of these essential topics and invites you to direct any queries to info@urbanlogisticsreit.com.

Modern Slavery & Child Labour

The Company is committed to a zero-tolerance approach to modern slavery. Any form of exploitation, slavery or human trafficking is unacceptable in any form. All suppliers are expected to:

  • Have policies and procedures in place to minimise the risk of modern slavery, forced or compulsory labour.
  • Comply with minimum age laws and not employ individuals below the legal working age.
  • Prohibit the use of forced & child labour, both directly and indirectly, through their supply chains.
  • Provide details of their modern slavery policies upon request.

More details on the Company’s approach to modern slavery can be found in our modern slavery policy.

Anti-discrimination

The Company seeks to encourage equality, diversity, and inclusion in our workforce and to eliminate unlawful discrimination throughout the supply chain.

All suppliers are expected to:

  • Actively prohibit discriminatory behaviour based on race, gender, religion, age, disability, or any other legally protected status.
  • Hold policies and procedures to actively identify harassment and discrimination and appropriately deal with such instances.
  • Actively promote diversity and inclusion amongst their workforces and the workforces of their supply chain.
  • Comply with all relevant legislation, including but not limited to the Equality Act 2010.

Further details on the Company’s anti-discrimination approach can be found in our equality, diversity and inclusion policy.

Freedom of Association

All suppliers must respect employees’ rights to associate, join unions, or bargain collectively without retaliation.

Fair Pay & Working Hours

The Company seeks to ensure, where possible, that all workers are paid a fair wage indicative of their knowledge, experience and skill, with attention paid to the cost of living in their geographic areas. Whilst the Company does not have direct employees, all employees of our investment advisor, of whom we hold significant influence, are paid fairly and above the minimum living wage.

It is expected that suppliers should treat their workers in a similar manner, paying at least the UK Living Wage, as adjusted from time-to-time.

All suppliers are expected to comply with any relevant legislation relating to working hours and to meet at least the requirements of fair pay disclosed above when considering operatives participating in overtime.

Health and Safety

The Company is committed to ensuring a safe and healthy work environment, both internally and throughout the supply chain. All suppliers are expected to:

  • Comply with applicable health and safety laws and regulations.
  • Proactively identify and mitigate workplace hazards.
  • Provide any training, equipment and emergency response measures as required to protect employees and the public from harm.
  • Develop Safe Systems of Work where applicable for activities involving a risk to health and safety and continuously monitor and assess the work environment for new and developing risks.

Environmental Responsibility

Where possible, suppliers are expected to minimise their environmental impact through:

  • Compliance with occupational and health and safety regulations.
  • Managing waste, water and energy efficiently.
  • Actively avoiding and prohibiting harmful environmental practices and promoting sustainable resource use.

The Company seeks to collaborate with suppliers on initiatives to reduce the environmental impact of our operations.

Anti-Financial Crime

The Company is committed to prevent the facilitation of financial crime, including but not limited to fraud, tax-evasion, bribery & corruption.

At a minimum, suppliers are required to have policies in place to support the following:

  • The identification and prevention of fraudulent activity internally and throughout their respective supply chains.
  • The identification and prevention of bribery and corruption internally and throughout their respective supply chains.
  • The identification and prevention of tax evasion internally and throughout their respective supply chains.
  • Providing a safe environment and process for those seeking to make a protected closure under the Public Interest Disclosure Act 1998 and other relevant legislation.

Suppliers must notify the Company if they do not have policies in place to support the above.

Monitoring and auditing of the supply chain

All new suppliers will be required to provide information to evidence their compliance with the above policies and, where this hasn’t been possible, to explain reasons for non-compliance. Instances of non-compliance will be considered on a case-by-case basis and may impact the supplier's suitability for appointment.

The Company will also carry out a review of our key service providers on an annual basis to ensure alignment with this code throughout our supply chain.

Our review will involve collecting data from the online marketing material of our service providers, followed by direct outreach to any suppliers where we have been unable to identify their approaches to the above or where inadequacies have been identified.

In addition to ensuring compliance with the Code, during the annual review, all key service providers will be subject to a controversy assessment involving searching available sources of information relating to potentially controversial actions or omissions by the supplier or its employees. Where controversial activity has been identified, the supplier will be contacted directly to comment; the controversial activity and any feedback provided may impact the supplier’s suitability for appointment.