Purpose

The Code sets the framework for NeoLiv Group suppliers to conduct business in a compliant manner and promote sound practices for environmental, social, health and safety management.

Applicability

This Policy has been approved and adopted by the Board of Directors and is applicable to the Manager and NeoLiv Group. All the associated suppliers shall comply with the Code.

Defination

“Applicable Law” means any statute, law, regulation, ordinance, rule, judgement, order, decree, bye-law, approval of any Governmental Agency, directive, guideline, policy, requirement or other government restriction or any similar form of decision of or determination by, or any interpretation having the force of law of any of the foregoing Governmental Agency having jurisdiction, applicable to any Party, in force from time to time.

“NeoLiv Group / NeoLiv” The NeoLiv Group shall collectively mean all the entities associated with NeoLiv Capital Advisory, including NeoLiv Real Estate, Inliv Real Estate Fund, all the asset SPVs, including SPVs that shall form part of NCA in future

“Stakeholder/s” shall mean individuals or groups of individuals, who have interests or abilities to influence outcomes of business activities across operations, supply chain and business partnerships, as well as those who are directly or indirectly impacted or affected by business activities of the Entity.

“Supplier/s” shall mean suppliers/service providers/ vendors/ traders / agents / contractors engaged for the purpose of development and maintenance of the assets in the portfolio of NeoLiv Group.

Code Principles

Legal Compliance

NeoLiv Group’s Suppliers shall comply with applicable laws, codes or regulations of the countries, states, and localities in which they operate. This includes, but is not limited to, laws and regulations relating to environmental, occupational health and safety, and labor practices.

Health and Safety

NeoLiv Group’s suppliers shall provide their employees with a safe and healthy working environment in order to prevent accidents and injuries arising out of, linked with, or occurring in the course of work or as a result of the operations of the Suppliers. Suppliers shall, among other things, do the following:

• Provide occupational health and safety training to their employees
• Have a system in place for injury and illness reporting
• Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled
• Make available medical treatment and/or compensation as per applicable laws to injured/ill workers arising as a result of working for the Supplier
• Worker exposure to chemical, biological, and physical agents is to be identified, evaluated and controlled. When hazards cannot be adequately controlled by engineering and administrative means, workers are to be provided with appropriate personal protective equipment.
• Machine safeguarding and other protective measures to prevent injuries/illnesses to workers
• Workers shall be provided clean and safe facilities including clean toilet facilities, access to potable water and sanitary food preparation and storage facilities.
• Worker dormitories provided by the Suppliers shall be clean, safe, and provide emergency egress, adequate heat and ventilation and reasonable personal space.

Labor and Human Rights

NeoLiv Group expects its Suppliers to adopt sound labour practices and treat their workers fairly in accordance with local laws and regulations. In addition, Suppliers must comply with the following standards:

• Freely Chosen Employment : Suppliers shall not use any forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise.
• No Child Labor : Suppliers shall comply with local minimum working age laws and requirements and not employ child labor.
• Minimum Wages: Suppliers shall provide wages for regular and overtime work and benefits that at least meet legal requirements.
• Working Hours: Suppliers shall not require workers to work more than the maximum hours of daily labor required legally.
• No Harsh, Inhumane Treatment or Abuse: Suppliers shall treat each employee with dignity and respect. In no event shall Supplier’s workers be subject to threats of violence, physical punishment, confinement, or other form of physical, sexual, psychological, or verbal harassment or abuse.
• No Discrimination: Suppliers shall not discriminate in its employment practices based on race, color, religion, sex, age, physical disability, national origin, creed, or any other basis prohibited by law.
• Freedom of Association: Suppliers shall recognize and respect the rights of its workers to join or to refrain from joining associations of their own choosing and the right to collective bargaining in accordance with local labor laws and established practices.

Environment

Protecting the environment and contributing to sustainable development is of great importance to NeoLiv Group. Suppliers shall actively strive to increase the positive and limit the negative impact of their operations and supply chain on the environment and society. Suppliers shall comply with applicable environmental laws and regulations. Such compliance shall include, among other things, the following:

• Comply all laws pertaining to sustainability, pollution, environment protection etc. as applicable. Also, obtain and maintain environmental permits and timely filing of required reports.
• Proper handling and disposition of hazardous materials
• Monitoring, controlling, and treating discharges generated from operations
• Suppliers are encouraged to adopt resource-efficient practices to optimize processes, conserve natural resources, and manage greenhouse gas emissions, contributing to a reduced environmental footprint.
• Suppliers are expected to take proactive initiatives on an ongoing basis to promote environmental responsibility and explore environmentally friendly and energy-efficient processes and technologies.
• Efforts should be made to prevent pollution and manage waste—whether hazardous, non-hazardous, industrial, solid, liquid, or gaseous—while aligning with prevailing regulations and best practices.
• Business activities should be conducted in an environmentally responsible manner, considering the entity's guidelines and applicable environmental policies.
• Suppliers are encouraged to support biodiversity conservation and take measures to avoid deforestation in their business operations.