The Project  is a Category B project in accordance with IFC’s Policy on Environmental and Social Sustainability. Key E&S risks and impacts associated with the Project include: effectiveness of E&S management systems and the Company’s capacity to undertake its operations in a manner that is consistent with IFC Performance Standards; adherence to core labor standards and the effective implementation of the environmental, occupational health and safety (OHS) management plans during construction; stakeholder engagement and external grievance mechanism.        

 Policy, Management System and Management Programs:

CTP has well established and ISO 14001 certified E&S management systems (ESMS) in the countries with largest portfolio (Czech Republic, Romania and Slovakia). Operational procedures and practices applied in Poland and Bulgaria follow group-wide approach to ESMS, as described in ESRS disclosed under the Bond Project (https://disclosures.ifc.org/project-detail/ESRS/44887/ctp-bond).

The Company’s buildings design standard, which is used in all countries of operations, provides technical specifications on materials and technologies, as well as structural, engineering features (electricity, heating, fire prevention, sanitary premises and etc.), and are based on energy efficiency and eco-friendly requirements. CTP launched systematic application of “BREEAM New construction” standard for all its new developments group-wide, which brings in good practice requirements for green building design and construction management practices, addressing environmental, health and safety (E&S) risks during construction, responsible sourcing, stakeholder engagement.

CTP applies its E&S requirements to suppliers, construction contractors and negotiate application of sustainable practices with its tenants by signing a “green lease clause”, specifying sustainable rules for a property use (energy efficiency, reduction of water consumption, waste generation and other).

Assessment of E&S Impacts and Risks

E&S risks assessment is driven by the national law requirements, corporate-wide practices and requirements of BREEAM standard for new construction. E&S risks assessment records and results as required by BREEAM standard are verified by an external auditor, as a part of certification. Environmental impacts assessment (EIA) is conducted in accordance with the national legislation, which is aligned with EU Directives in Poland and Bulgaria.

E&S due diligence is conducted prior to acquisition of any land plot or standing property. Prior to purchase of any land plot an environmental site assessment (Phase II) is conducted with sampling of soil and groundwater to assess contamination and confirm compliance with applicable E&S standards. In addition, any building approved for acquisition shall have a reasonable potential for BREEAM certification after completion of retrofitting, if needed.

As a part of its due diligence process, CTP will screen development projects to ensure that projects which might have significant environmental and social risks and impacts, such as land acquisition, biodiversity, legacy labor issues, legacy pollution issues etc., will not be supported under this project.

Organizational Capacity and Competency

The Group’s Head of ESG Management is responsible for overall implementation of ESG targets and key performance indicators (KPIs), sustainability reporting and performance of sustainability initiatives across CTP’s countries of operation.  Group-wide ESG KPIs are developed and rolled out for implementation and assigned to the relevant staff in country offices.

Inhouse teams are responsible for design, procurement, construction and property management and the relevant requirements are incorporated throughout the operational process to ensure properties are in compliance with national E&S laws and the BREEAM standard. Construction works are conducted by qualified construction contractors and supervised by the company’s Project Manager, Site Manager and independent OHS Engineer. Property managers are responsible for day-to-day property management and communication with tenants. In Poland and Bulgaria CTP plans to hire more staff to manage new developments. Onboarding and training programs for the new hirers is in place.

Monitoring & Reporting:

The Company has processes and established reporting lines to collect, analyze and report data and E&S related information. Operational reports during the construction period are submitted on a regular basis, which includes an E&S performance. In case of any incidents/ accidents the responsible Project Manager is notified immediately.

In 2022, CTP has developed an ESG Reporting Manual and tools for routine collection of ESG-related data for sustainability reporting purposes. Currently it includes data on environmental performance (greenhouse gases (GHG), energy efficiency, biodiversity etc.) and social (human resources, stakeholders/ corporate social responsibility activities). CTP plans to expand and systemize data to be collected on health, safety, which will cover EHS performance of contractors’, and this initiative is planned for completion in 2024. In 2023 CTP intend to implement requirements for contractors concerning systemized disclosure of EHS data.

CTP conducts regularly internal / external audits and environmental monitoring, where required by the national legislation.

Emergency Preparedness and Response

The Company’s properties are designed and constructed in compliance with local legislation requirements and standards on safety and emergency preparedness and equipped with automated detection and alarm systems (leak prevention and detection, fire alarm and suppression etc.), which allow to monitor building’s performance and prevent emergency situations. Emergency preparedness and evacuation plans (EPRP) are developed for each property and tenants are responsible for emergency staff training and conduction of evacuation and fire drills. EPRP for construction period are prepared by contractors as a part of EHS package of documentation developed prior to commencement of construction works. 

 Human Resources Policies and Procedures, Working Conditions

As of February 2023, CTP had 72 employees in Poland (51% female and 49% male) and in Bulgaria, 20 employees (55% male and 45 % female) with further plans to gradually expand its teams in both countries.

In both countries CTP applies group level documents, such as Code of Conduct, HR policies and procedures, addressing diversity, equal opportunities and non-discrimination; harassment and gender-based violence prevention and response, non-tolerance to any form of child labor or forced labor, ethical behavior. All employees have written labor contracts with specified terms and conditions of employment related to working hours, annual leave, wages and benefits.

Occupational Health and Safety

OHS risks from CTP’s own operations are limited. Both offices in Poland and Bulgaria outsource H&S engineer to maintain compliance with OHS national requirements and conduct regular OHS training. No health and safety incidents or accidents with its employees were reported by CTP, although there were cases of lost time injuries with contractor workforce in Bulgaria, which were investigated accordingly, and corrective actions developed and implemented. CTP tracks OHS performance of its contractors and plans further enhance collection and analyses of such information under its sustainability reporting initiative. 

EHS performance of construction contractors is reviewed by procurement departments during contractors’ tendering, although the scope of review varies from country to country. CTP will unify the approach by formalizing its existing practices at a group-level EHS requirements for selection and tendering of construction contractors and construction contractors management plan, which will be applied by its subsidiaries (ESAP #1).

Health, safety, and environment (HSE) obligations are included into the legal agreements with contractors, such as having their own HSE engineers onsite, proper staff training and equipping with personal protective equipment in accordance with the type of performed works. Construction contractors prior to mobilization prepare SOPs and ESMPs, which address OHS measures and include job hazard risk analysis, safety work statements, H&S management plans, emergency response plans and first aid. Adequate personal protective equipment, onboarding and on the job trainings are provided to all the employees and contractors, commensurate with the job risk. Supervision of construction contractors is conducted regularly by Site Managers, OHS engineer hired by CTP and an independent OHS Advisor.

Grievance mechanism

A grievance mechanism for employees and third-party workers is established for reporting of any concerns and complaints related to misconduct, health & safety, security and environment issues, as well as any kind of discrimination and harassment. Different communication channels are in place, such as e-mail, phone hotline, post address and external independent channel via Faceup application (https:/www.report.faceup.com/en/). Information about grievance mechanism is available in the Code of conduct, whistleblowing policy and anti-harassment policy.

Third Party Workers

The Company works with reputable international and local construction contractors with solid track records and adequate environmental, health and safety (EHS) management systems for the execution of works.

CTP does not tolerate any form of discrimination, violation of workers’ rights and illegal employment. These corporate values are specified in the Code of Conduct for suppliers, which is applied to third-party workers and contractors. There is no workers’ accommodation provided on the construction sites and all workers, including workforce of construction contractors, are hired locally.

Supply chain

CTP has developed a Code of Conduct for suppliers, specifying E&S and sustainable requirements for service providers and suppliers. Due to forced labor allegations in the solar PV industry, CTP conducts due diligence of solar PV suppliers focused on human rights and forced labor risks, suppliers need to confirm solar PVs are produced without forced labor use in their supply chain and legally required to maintain this practice.

 CTP develops green properties and has strong goals on minimization of greenhouse gases. The GHG emissions from the company’s operations (Scope 1 and 2) in 2022 in Poland in Bulgaria was 657.4 tons CO2eq, that is well below 25,000 tons CO2eq/year. In addition, CTP owns forested are, which removes from atmosphere more than corporate CO2 emissions. The Company continues exploring further opportunities to improve energy efficiency in its building, generate on-site renewable energy and promote the circularity of the buildings and parks, including responsible sourcing.

Alongside with new developments, CTP invests in retrofitting its standing buildings (LED lighting, HVAC upgrade, BMS) to achieve higher level of green certification.

CTP’s properties are connected either to municipal utilities (electricity, water, sewerage system) or have own on-site wastewater treatment facilities as per the respective permitting requirements. Monitoring of resource consumption and quality of wastewater treatment is regularly conducted by CTP. Tenants are responsible for holding all the environmental permits and authorizations related to their own operations, including holding of contracts with licensed companies for waste recycling, treatment and disposal, if needed.

CTP is working on increasing the sorting of recyclable wastes in order to reduce waste going to landfills. The disposal of waste generated during retrofits/construction of properties is managed by the contractors in line with the CTP guidelines and as required by BREEAM. CTP monitors and will disclose waste generation and disposal quantities via sustainability report. 

 Structural safety. Bulgaria is situated in an area of seismic activity and the national regulations cover seismic risks in respect of the design and execution of construction works. The Company strictly adheres design and construction standards for seismic risks prevention during the new developments, that is confirmed by a construction permit issued by the state authorities.

Life & Fire Safety.  CTP follows NFPA standard requirements for fire safety measures across all facilities. Fire safety measures include ESFR (Early Suppression, Fast Response) ceiling sprinkler protection, smoke detection system, fire alarms in all areas, façade panels with 120 minutes of fire resistance, evacuation exits and emergency lighting.

Security Services.  CTP via tendering process hires licensed unarmed security services, and the security staff is properly trained.

The Company’s key stakeholders’ groups include investors, governmental authorities, tenants, local communities, employees, media, industry peers. Stakeholder engagement practices are incorporated into the corporate practices to ensure compliance with national legislation and BREEAM new construction standard and generally include:

• Public consultations conducted by City halls during the land plot master-planning;
• Public hearing / consultations as a part of EIA process;
• Engagement and notification of local communities, which might be affected during construction period;
• Ongoing engagement with employees, municipal and governmental authorities;
• Daily and ongoing engagement with tenants on their needs, concerns and plans, ESG related events, like tree planting, sports activities, educational programs;
• CSR activities with local communities to support any social initiatives and etc.

?TP regularly discloses information on its operations via annual reporting (https://www.ctp.eu/company/corporate-downloads/), social media, as well as by direct communication with various groups of stakeholders.  CTP has prepared its first Sustainability Report for 2022, which will be disclosed in Q1 2023. As a listed company, CTP has to disclose regularly information as per requirements of Euronext stock exchange in Amsterdam and EU Directive on corporate sustainability reporting.

The Company’s facilities are typically located outside of cities and generally remote from residential areas. In line with local legal and BREEAM standard  requirements any neighboring communities are notified prior to any construction activities and provided with contact details for any concerns/ queries. In addition, contacts details are placed at the entrance to any construction site and available at CTP website. In addition, the Company will establish a formal grievance /communication mechanism for external stakeholders, which will allow them to obtain any ESG related queries from interested stakeholders (ESAP #2).

 Poland: Bogi Gabrovic - +48 601 967 686, bogi.gabrovic@ctp.eu

Bulgaria: Daniela Boytcheva - +359 884 65 22 38, daniela.boytcheva@ctp.eu