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Sustainable Procurement & Supplier Code of Conduct

Purpose and Scope

This Sustainable Procurement & Supplier Code of Conduct sets out the principles and expectations applied by Wellbeing Places REIG Limited (the "Company") to its procurement activities and supplier relationships.

As a real estate investment group, we recognise that our greatest environmental and social impacts occur within our supply chain specifically during the construction, refurbishment, and day-to-day management of our assets. The purpose of this policy is to manage these risks, with a particular focus on embodied carbon and Scope 3 greenhouse gas emissions, while maintaining commercially realistic requirements.

This policy applies to all suppliers, including:

  • Architects, planning consultants, and letting agents.
  • Those engaged in development, cladding remediation, or fit-out works.
  • Cleaning, security, and maintenance providers.
  • Direct energy and water procurement for managed assets.

Policy Objectives

The objectives of this policy are to:

  • Manage and reduce material Scope 3 emissions, specifically focusing on embodied carbon in building materials and tenant energy use.
  • Align procurement with the Company's Net Zero Carbon pathway and the UK's wider statutory targets.
  • Encourage the reuse of materials and the reduction of construction and demolition waste.
  • Promote fair pay (including the UK Living Wage) and safe working conditions across all construction sites and managed properties.

Core Procurement Principles

The Company applies the following principles to its real estate procurement:

  • Lifecycle Costing: Evaluating the long-term environmental and financial cost of materials and systems, rather than just the initial capital expenditure.
  • Proportionality: Requirements for a local maintenance contractor will differ from those of a Tier 1 principal contractor.
  • Transparency: Clear communication of sustainability KPIs during the tender process.
  • Risk-Based Approach: Prioritising high-impact categories such as steel, cement, and HVAC systems.

Environmental & Net Zero Expectations

Suppliers are expected, where relevant, to:

  • Provide Environmental Product Declarations (EPDs) for major construction materials.
  • Specify and install high-efficiency plant and equipment (e.g., heat pumps, LED lighting).
  • Adhere to "Zero Waste to Landfill" targets for development sites and managed assets.
  • Comply with UK Building Regulations, MEES (Minimum Energy Efficiency Standards), and planning requirements.

Ethical, Social and Legal Standards

Given the high-risk nature of the UK construction and FM sectors, suppliers must:

  • Actively mitigate risks of forced labour in high-risk material supply chains (e.g., natural stone, solar panels).
  • Maintain rigorous safety standards on-site, in compliance with CDM 2015 regulations.
  • Strictly prohibit bribery or unethical behaviour in planning applications or land acquisitions.
  • Support the use of local labour and diverse-owned businesses where possible.

Monitoring and Engagement

Onboarding: New contractors must confirm compliance with this Code and provide evidence of relevant certifications (e.g., ISO 14001, CHAS, or BREEAM Associate status).

Audits: We reserve the right to conduct site visits or request audits of major development projects.

Engagement: We prefer to work with suppliers to rectify non-compliance, but persistent failure to meet environmental or ethical standards will result in removal from our "Approved Supplier List".

Responsibilities

  • Board of Directors: Overall oversight of sustainable procurement principles.
  • Senior Management: Implementation of this Policy and integration into procurement practices.
  • Suppliers: Compliance with this Policy and cooperation with reasonable requests.