PURPOSE

At Wanaka Partners, our mission is to create healthy urban ecosystems by decarbonising and futureproofing the built environment, while actively contributing to vibrant, inclusive communities through placemaking. This Supplier Code of Conduct ("Code") seeks to extend our values and ambitions across our supply chain. It outlines the minimum expectations we place on our suppliers and service providers, while fostering long-term, transparent partnerships grounded in shared commitments to sustainability, integrity, and social responsibility.

Its purpose is to:

• Clarify the minimum standards we expect suppliers and service providers to meet and to promote within their own supply chains
• Support collaborative, transparent, and long-term relationships that help accelerate the shift to sustainable, net-zero, and inclusive business practices
• Explain what suppliers and service providers can expect from Wanaka Partners in return

Adherence to this Code is a prerequisite for becoming or remaining a preferred supplier to Wanaka Partners.

SCOPE & APPLICABILITY

This Code applies to all suppliers including contractors, consultants, service providers, and landlords engaged by any of the companies in Wanaka Partners’ group (namely Wanaka Fund Management, Wanaka Real Estate Management, Wanaka Capital Solutions, Wanaka Partners, and Wanaka Services).

Wanaka Partners’ group also seeks to implement this Code for all suppliers of the funds and assets under its management where possible (noting that this is the decision of the investor / client / landlord).

Where local laws or contract terms impose higher standards, the stricter requirement applies.

EXPECTATIONS FOR SUPPLIERS AND SERVICE PROVIDERS

Our expectations are grounded in international frameworks such as the UN Global Compact, ILO Conventions, and OECD Guidelines for Multinational Enterprises. They are also closely aligned with our sustainability strategy, which is built on four pillars: Net Zero Carbon, Futureproofing, Placemaking, and Good Governance. Suppliers are expected to uphold these standards in the course of their operations with and on behalf of Wanaka Partners.

• Legal and ethical compliance

Suppliers are expected to operate in full compliance with all applicable laws, regulations, and required permits. They should maintain accurate and transparent records to demonstrate such compliance and be prepared to share relevant documentation upon request.

• Human rights, labour and social standards

We expect suppliers to respect internationally recognised human rights and ensure that their operations are free from child labour, forced or compulsory labour, and human trafficking. Working conditions must comply with legal standards related to wages, benefits, working hours, and freedom of association. A workplace culture that promotes dignity, inclusion, and respect, free from harassment, intimidation, or discrimination, is fundamental.

• Environmental responsibility

Suppliers should make every effort to actively monitor, manage, and seek to reduce their environmental footprint, particularly greenhouse gas emissions, in alignment with the goals of the Paris Agreement. We encourage a commitment to circularity through reuse of materials, reduction of waste, and preference for low-embodied-carbon solutions. Operational efficiency regarding energy and water use is expected, alongside a responsible approach to refrigerants, chemicals, and waste management. Suppliers are also expected to contribute to the protection and restoration of biodiversity, integrating nature-based solutions where feasible.

• Diversity, Equity & Inclusion (DEI)

Suppliers are encouraged to cultivate an inclusive working environment that values diversity and equal opportunity. Recruitment, development, and advancement should be based on merit and free from bias related to gender, race, ethnicity, religion, age, disability, or any other protected attribute. We also value efforts to involve underrepresented groups across the supplier's own value chain.

• Health, safety and wellbeing

A safe and healthy work environment must be provided for all employees. Ideally, suppliers should align with recognised standards. This includes systematically identifying and mitigating workplace hazards, offering appropriate training, and promoting both physical and mental wellbeing.

• Fair business practices

All forms of corruption, bribery, fraud, extortion, and money laundering are strictly prohibited. Suppliers must conduct their business with integrity and comply with relevant competition and antitrust laws to ensure fair market behaviour.

Suppliers shall avoid conflicts of interest and shall inform Wanaka Partners of any situation which might appear to be a conflict of interest between them and Wanaka Partners. Conflict of interest is referring to a direct or indirect conflict of a financial or other nature.

• Data privacy and confidentiality

Suppliers are expected to protect personal data and any confidential information shared in the context of their work with Wanaka Partners. This includes full compliance with GDPR and other applicable data protection laws. Any breach affecting Wanaka Partners or our stakeholders must be reported without undue delay.

• Continuous improvement

We expect suppliers to adopt systems for tracking and improving performance on environmental, social, and governance (ESG) topics. This includes maintaining supply chain transparency and being prepared to disclose relevant ESG metrics upon request. Mechanisms should also be in place for employees and third parties to raise concerns safely, including through anonymous channels, without risk of retaliation.

OUR COMMITMENT TO SUPPLIERS

In return, Wanaka Partners is committed to building partnerships based on mutual respect, transparency, and long-term value creation. We pledge to:

• Treat suppliers fairly, including during procurement processes (where applicable) and through timely, accurate payments
• Collaborate for impact by sharing knowledge, supporting innovation & improvement initiatives, and acknowledging strong performance
• Communicate clearly by setting expectations, providing constructive feedback, and listening to your input
• Uphold consistent standards by holding ourselves to the same ethical, social, and environmental values we expect from our suppliers
• Respect your data by handling supplier information with confidentiality and in accordance with applicable laws

IMPLEMENTATION & MONITORING

This Code is included as part of the contract or agreement for all new suppliers, who are expected to confirm their understanding. Wanaka Partners may carry out monitoring activities as appropriate, which could include requesting documentation, conducting site visits or audits, or asking suppliers to report specific indicators (e.g. emissions, safety incidents, DEI statistics). Where areas for improvement are identified, we expect suppliers to take appropriate corrective actions. Where feasible, Wanaka Partners may support these efforts through guidance or capacity-building. In cases of serious or repeated breaches, Wanaka Partners reserves the right to suspend or terminate the business relationship. This Code will be reviewed at regular intervals, at least every three years, to ensure it remains aligned with legal developments and our evolving sustainability objectives.

SPEAKING UP

Wanaka Partners encourages openness and accountability. Any supplier, employee, or stakeholder who becomes aware of a potential violation of this Code is encouraged to report it in good faith. Reports can be made via our dedicated ethics and compliance channel: compliance@wanakapartners.com. Wanaka Partners commits to handling all reports seriously and to protecting the confidentiality and safety of those who raise concerns.

ACKNOWLEDGEMENT

By accepting a purchase order, contract, or framework agreement from Wanaka Partners, suppliers acknowledge this Code and commit to aligning their operations and supply chain practices accordingly.