Company Policies

Objective

Space in Africa Consulting Limited (“SIA”) strives to create and maintain a work environment in which people are treated with dignity, decency and respect. The environment of the company should be characterized by mutual trust and the absence of intimidation, oppression and exploitation. SIA will not tolerate unlawful discrimination or harassment of any kind. Through enforcement of this policy and by education of employees, SIA will seek to prevent, correct and discipline behaviour that violates this policy.

All employees, regardless of their positions, are covered by and are expected to comply with this policy and to take appropriate measures to ensure that prohibited conduct does not occur. Appropriate disciplinary action will be taken against any employee who violates this policy. Based on the seriousness of the offense, disciplinary action may include verbal or written reprimand, suspension, or termination of employment.

Managers and supervisors who knowingly allow or tolerate discrimination, harassment or retaliation, including the failure to immediately report such misconduct to human resources (HR), are in violation of this policy and subject to discipline.

Prohibited Conduct

SIA, in compliance with all applicable anti-discrimination and harassment laws and regulations, enforces this policy in accordance with the following definitions and guidelines:

Discrimination

It is a violation of this policy to discriminate when providing employment opportunities, benefits or privileges; to create discriminatory work conditions; or to use discriminatory evaluative standards in employment if the basis of that discriminatory treatment is, in whole or in part, the person’s race (including hairstyle/texture), color, national origin, age, religion, disability status, sex, sexual orientation, gender identity or expression, genetic information or marital status.

Discrimination in violation of this policy will be subject to disciplinary measures up to and including termination.

Harassment

SIA prohibits harassment of any kind, including sexual harassment, and will take appropriate and immediate action in response to complaints or knowledge of violations of this policy. For purposes of this policy, harassment is any verbal, psychological or physical conduct designed to threaten, intimidate or coerce an employee, co-worker, or any person working for or on behalf of SIA.

The following examples of harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

• Verbal harassment includes comments that are offensive or unwelcome regarding a person’s national origin, race, color, religion, age, sex, sexual orientation, pregnancy, appearance, disability, gender identity or expression, marital status or other protected status, including epithets, slurs and negative stereotyping.

• Nonverbal harassment includes distribution, display or discussion of any written or graphic material that ridicules, denigrates, insults, belittles or shows hostility, aversion or disrespect toward an individual or group because of national origin, race, color, religion, age, gender, sexual orientation, pregnancy, appearance, disability, sexual identity, marital status or other protected status.

Sexual harassment

Sexual harassment is prohibited under this policy. Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when submission to or rejection of such conduct is used as the basis for employment decisions or such conduct has the purpose or effect of creating an intimidating, hostile or offensive working environment.

Sexual harassment occurs when unsolicited and unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature:

• is made explicitly or implicitly a term or condition of employment.

• is used as a basis for an employment decision.

• Unreasonably interferes with an employee’s work performance or creates an intimidating, hostile or otherwise offensive environment.

Sexual harassment may take different forms. The following examples of sexual harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

• Verbal sexual harassment includes innuendoes, suggestive comments, jokes of a sexual nature, sexual propositions, lewd remarks and threats; requests for any type of sexual favor (this includes repeated, unwelcome requests for dates); and verbal abuse or “kidding” that is oriented toward a prohibitive form of harassment, including that which is sexual in nature and unwelcome.

• Nonverbal sexual harassment includes the distribution, display or discussion of any written or graphic material, including calendars, posters and cartoons that are sexually suggestive or show hostility toward an individual or group because of sex; suggestive or insulting sounds; leering; staring; whistling; obscene gestures; content in letters, notes, facsimiles, e-mails, photos, text messages, tweets and Internet postings; or other forms of communication that are sexual in nature and offensive.

• Physical sexual harassment includes unwelcome, unwanted physical contact, including touching, tickling, pinching, patting, brushing up against, hugging, cornering, kissing, fondling, and forced sexual intercourse or assault.

Courteous, mutually respectful, pleasant, noncoercive interactions between employees that are appropriate in the workplace and acceptable to and welcomed by both parties are not considered to be harassment, including sexual harassment.

Consensual Romantic or Sexual Relationships

SIA strongly discourages romantic or sexual relationships between a manager or other supervisory employee and an employee who reports directly or indirectly to that person, because such relationships tend to create compromising conflicts of interest or the appearance of such conflicts. In addition, such a relationship may give rise to the perception by others that there is favoritism or bias in employment decisions affecting the staff employee. Moreover, given the uneven balance of power within such relationships, consent by the staff member is suspect and may be viewed by others, or at a later date by the staff member, as having been given as the result of coercion or intimidation. The atmosphere created by such appearances of bias, favoritism, intimidation, coercion or exploitation undermines the spirit of trust and mutual respect that is essential to a healthy work environment. If there is such a relationship, the parties need to be aware that one or both may have to take necessary actions that will ensure that trust and mutual respect at the office is not breached.

If any employee of SIA enters into a consensual relationship that is romantic or sexual in nature with an employee who reports directly or indirectly to that employee, or if one of the parties is in a supervisory capacity in the same department in which the other party works, the parties must notify the HR director or other appropriate corporate officer. Because of potential issues regarding quid pro quo harassment, SIA has made reporting mandatory.

Once the relationship is made known to SIA, the company will review the situation with human resources in light of all the facts (reporting relationship between the parties, effect on co-workers, job titles of the parties, etc.) and will determine whether one or both parties need to be moved to another job. If it is determined that one party must be moved, and there are jobs in other departments available for both, the parties may decide who will be the one to apply for a new position. If the parties cannot amicably come to a decision, or the party is not chosen for the position to which he or she applied, the HR director and senior management will decide which party will be moved. That decision will be based on which move will be least disruptive to the organization as a whole. If no other jobs are available for either party, the parties will be given the option of terminating their relationship or resigning.

Retaliation

No hardship, loss, benefit or penalty may be imposed on an employee in response to:

• Filing or responding to a bona fide complaint of discrimination or harassment.

• Appearing as a witness in the investigation of a complaint.

• Serving as an investigator of a complaint.

Lodging a bona fide complaint will in no way be used against the employee or have an adverse impact on the individual’s employment status. However, filing groundless or malicious complaints is an abuse of this policy and will be treated as a violation.

Any person who is found to have violated this aspect of the policy will be subject to discipline up to and including termination of employment.

Confidentiality

All complaints and investigations are treated confidentially to the extent possible, and information is disclosed strictly on a need-to-know basis. The identity of the complainant is usually revealed to the parties involved during the investigation, and the HR director will take adequate steps to ensure that the complainant is protected from retaliation during and after the investigation. All information pertaining to a complaint or investigation under this policy will be maintained in secure files within the HR department.

Complaint procedure

SIA has established the following procedure for lodging a complaint of harassment, discrimination or retaliation. The company will treat all aspects of the procedure confidentially to the extent reasonably possible.

1. Complaints should be submitted as soon as possible after an incident has occurred, preferably in writing. The HR director may assist the complainant in completing a written statement or, in the event an employee refuses to provide information in writing, the HR director will dictate the verbal complaint.

2. Upon receiving a complaint or being advised by a supervisor or manager that violation of this policy may be occurring, the HR director will notify senior management and review the complaint with the company’s legal counsel.

3. The HR director will initiate an investigation to determine whether there is a reasonable basis for believing that the alleged violation of this policy occurred.

4. If necessary, the complainant and the respondent will be separated during the course of the investigation, either through internal transfer or administrative leave.

5. During the investigation, the HR director, together with legal counsel or other management employees, will interview the complainant, the respondent and any witnesses to determine whether the alleged conduct occurred.

6. Upon conclusion of an investigation, the HR director or other person conducting the investigation will submit a written report of his or her findings to the company. If it is determined that a violation of this policy has occurred, the HR director will recommend appropriate disciplinary action. The appropriate action will depend on the following factors:

   • the severity, frequency and pervasiveness of the conduct;

   • prior complaints made by the complainant;

   • prior complaints made against the respondent; and

   • the quality of the evidence (e.g., firsthand knowledge, credible corroboration).

7. If the investigation is inconclusive or if it is determined that there has been no violation of policy, but potentially problematic conduct may have occurred, the HR director may recommend appropriate preventive action.

8. Senior management will review the investigative report and any statements submitted by the complainant or respondent, discuss results of the investigation with the HR director and other management staff as appropriate, and decide what action, if any, will be taken.

9. Once a final decision is made by senior management, the HR director will meet with the complainant and the respondent separately and notify them of the findings of the investigation. If disciplinary action is to be taken, the respondent will be informed of the nature of the discipline and how it will be executed.

Alternative legal remedies

Nothing in this policy may prevent the complainant or the respondent from pursuing formal legal remedies or resolutions through local, state or federal agencies or the courts.

Last updated: 21st November, 2025

Purpose Of This Policy

Space in Africa Consulting Limited, including its subsidiaries and other affiliates (together, “SIA”) is committed to operating in an ethical manner and in compliance with applicable legal and regulatory requirements. Even the appearance of a conflict can be damaging to the reputation of SIA. All decisions by employees covered by this policy (described below) must be made solely in the best interests of SIA.

SIA recognizes that situations may on occasion arise where an employee’s private interests conflict with or appear to conflict with his or her obligations to SIA or the interests of SIA. This policy is intended to educate employees about situations that generate the potential for Conflicts of Interest; to clarify expectations about disclosing interests and activities that might result in Conflicts of Interest; and to identify means to manage, reduce, or eliminate such Conflicts of Interest.

Principles

• Transparency of interests to build trust in decision-making – SIA promotes evidence-based and transparent decision-making across the organization. The transparency of private interests of employees covered by this policy contributes to building trust in decision-making.

• Disclosure – In some cases, actual, potential or perceived conflicts of interest may be inevitable, but such conflicts of interest are not inherently problematic if they are appropriately mitigated. It is paramount that employees fully disclose their private interests, as well as actual, potential or perceived conflicts of interest, as defined in this Policy, to ensure conflict of interest risks are appropriately mitigated.

• Accountability – It is important that employees ensure that their decisions are unaffected by bias or irrelevant considerations, such as considerations in relation to private interests. They should demonstrate that they have taken all reasonable steps to observe relevant standards and good practices of impartiality, procedural fairness and transparency applicable to their roles and functions.

• Consultation and advice – It is not possible to list all situations that may constitute a conflict of interest. Effective mitigation implies consultation among all relevant actors, and SIA will consider how to best encourage such consultation as appropriate.

Scope Of This Policy

This policy applies to all employees of SIA. to any circumstance that may constitute a Conflict of Interest, regardless of whether it is specifically described in this policy. For example, while personal interests of employees are defined to include those of the person and his or her Immediate Family Members, there also may be situations where the interests of other persons, such as a close friend or other family member, create a Conflict of Interest.

Policy

Employees should seek to avoid Conflicts of Interest. A “Conflict of Interest” is any circumstance in which an employee’s personal, professional, financial, or other interests may potentially or actually diverge from, or may be reasonably perceived as potentially or actually diverging from, his or her obligations to SIA and the interests of SIA. It includes indirect conflicts, such as benefits provided to an Immediate Family Member of an employee.

An employee:

• must promptly disclose any Conflict of Interest and should anticipate the possibility of a Conflict of Interest whenever possible so that the possible Conflict of Interest can be reviewed prior to occurrence; and

• where relevant, cooperate with any plan adopted by SIA to manage, reduce, or eliminate the Conflict of Interest. Where an employee is not initially aware of the Conflict of Interest but becomes aware of it at a later time, the individual should disclose the Conflict of Interest promptly upon learning of it.

Types of Conflicts of Interest

The following is not a comprehensive list of the types of Conflicts of Interest that may arise but provides examples of some common types:

Business Arrangements

Participating, directly or indirectly, in the selection, approval, facilitation, or administration of any business arrangement involving SIA and an Immediate Family Member of an employee or an enterprise in which the employee or Immediate Family Member holds, directly or indirectly, more than a de minimis ownership or other financial interest or has an employment, management, or fiduciary role (such as serving as an officer or director).

Competing with SIA

Engaging, directly or indirectly, in activities that are in competition with SIA or appropriating or diverting business opportunities of SIA. This includes:

• holding, directly or indirectly, an ownership or other financial interest (other than a de minimis interest) or having an employment, management, or fiduciary role (such as serving as an officer or director) in an enterprise that is a competitor of SIA, or seeking to advance the interests of such enterprise to SIA; and

• appropriating or diverting a business or financial opportunity that an employee knows or should know SIA is pursuing or is considering pursuing or reasonably might be interested in pursuing if it were aware of the opportunity.

Gifts

This includes:

• Accepting any gift or favour, even of nominal value, that is illegal under applicable law or prohibited under other applicable SIA policies; or

• accepting a gift or favour of more than nominal value (including entertainment) or a loan (other than an arm’s length loan made in the ordinary course of business from a banking or other financial institution), even where not illegal under applicable law or prohibited under other applicable SIA policies, from any person or entity seeking a benefit from SIA (e.g., seeking to do business or continuing to do business with SIA) if the offer or acceptance of the gift, favour, or loan could reasonably be viewed as intended to influence SIA to act favourably toward the person or entity. Where it is impracticable for the employee (or his or her Immediate Family Member) to decline a gift that would otherwise constitute a Conflict of Interest under this policy, and where it is neither illegal nor unethical for SIA itself to accept the gift, the individual may accept the gift on behalf of SIA with the permission of his or her supervisor and then transfer it to SIA.

Improper Use of SIA Resources

Unauthorized use of SIA resources, including the services of employees, for personal purposes. For example, while an employee may make de minimis use of SIA computers and telephone devices for personal purposes provided, however, that he or she reimburses SIA if there are additional charges to SIA from such use (e.g., a charge for an international phone call).

Confidential Information

Obtaining, using, or disclosing SIA Confidential Information for direct or indirect personal interest, profit, or advantage; obtaining or using SIA Confidential Information for a purpose that may be detrimental to SIA; or disclosing SIA Confidential Information to a person or entity that is not authorized by SIA to receive it.

Procedures for Implementation

Disclosing Conflicts of Interest

Employees have a duty to disclose on an ongoing basis any current, proposed, or pending situations that may constitute a Conflict of Interest and should disclose the material facts relating to any Conflict of Interest as soon as the existence of a possible Conflict of Interest is known.

An employee must disclose a Conflict of Interest to his or her supervisor. Any employee or supervisor who has questions about this policy or its application may seek guidance from the HR.

Managing Conflicts of Interest

Once a Conflict of Interest is disclosed, the relevant SIA administrator will determine the next steps with respect to the Conflict of Interest. SIA may determine that the Conflict of Interest should be managed, reduced, or eliminated, or SIA may proceed without a management plan. Any management plan will depend upon the facts and circumstances of the specific matter.

Enforcement

Violations of this policy are subject to disciplinary action, up to and including termination of the employee’s association with SIA, in accordance with the SIA disciplinary policies and procedures applicable to the individual. This policy will not be enforced to the extent it is inconsistent with applicable law.

Last updated: 21st November, 2025

About this policy

At Space in Africa Consulting Limited (“SIA”, “we” or “our”), Environmental, Social, and Governance issues are interconnected and integral to our business operations. Through ESG, we aim to unify these core objectives, showcasing the positive impact our business has on the world. Building upon our initial commitment to corporate social responsibility, we strive to operate on a significantly broader and more measurable scale.

This policy will steer our ongoing ESG initiatives, covering reporting, disclosures (both material and non-material), business practices, policies, procedures, investments, board activities, stakeholder engagement, and investor relations.

This policy is not intended to restrict or alter our existing commitments, either legally or ethically.

Purpose of this Policy

The purpose of this policy is to provide information about ESG (Environmental, Social and Governance factors) and to encourage the business to understand ESG better.

2.2. This policy has been agreed upon and adopted for implementation by the Board of Directors.

2.3 This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.

Who is Responsible for this Policy?

The Board of Directors has overall responsibility for the effective operation of this policy. They have delegated responsibility for overseeing its implementation to the Chief Executive Officer. Suggestions for change should be reported to the HR or the Legal and Compliance Department.

All Managers and Supervisors have day-to-day responsibility for this policy and you should refer any questions about this policy to them in the first instance.

This policy is reviewed annually by the Board of Directors on the recommendation of the HR and Legal and Compliance Department. Changes may be made at any time as regulatory guidance develops.

Our ESG Commitment

We strive to build sustainable, equitable, healthy, and diverse communities through a combination of innovative business practises and exemplary environmental, social and governance (ESG) performance. This commitment informs every aspect of our business, including how we design and build new projects, operate our company, collaborate with stakeholders and report progress.

This ESG Policy sets out our approach to sustainability matters. At the heart of the Policy is a corporate culture that has sustainability at the core of all our business operations and values.

Our Statement on Climate Change and the Environment

We are committed to driving down our energy and carbon impacts, as we believe that climate change is one of the greatest risks to our world. Our sustainability program is committed to environmentally sustainable initiatives that deliver near-term efficiency, value, and health for our business, our people, and the wider community.

We encourage our customers to reduce their impact on the environment by recommending the use of more sustainable materials. We actively promote a paper-free office. We regularly support our clients to avoid printing and we will make all endeavours to be a digital-first business.

We seek to comply with current environmental legislation and work to minimise the impact of our activities on the environment.

We support all national and international recommendations on climate-related disclosure and engage with our stakeholders and encourage enhanced disclosure on climate change, biodiversity, and the SDGs.

Our Statement on Social Responsibility

Our focus is to deepen relationships with our key stakeholders by investing in our employees and partnering with our customers, communities, investors and suppliers.

We are committed to engage with our employees to provide a challenging, dynamic, inclusive and diverse work environment that supports their professional development, as well as promoting a good work-life balance that prioritizes their overall health and wellness.

We will support initiatives that benefit the environment, human welfare and education. This includes skills training that advance workforce talent pipelines for our customers and economic development in the communities in which we operate.

We will engage suppliers, customers and employees around safety, health, and wellness.

We will preserve and promote the protection of human rights and welfare within our own business activities, as well as those of our supply chain, in accordance with local and international human right frameworks and all internal policies.

Our Statement on Ethical Governance

Our focus is to promote strong oversight, transparency and risk management at all levels of our organisation, ensuring the resilience and long-term preservation of value for our business.

We will maintain strong corporate governance practices through exemplary board stewardship, management accountability, and proactive risk management.

We will mitigate risk exposure and build the resilience of our business to climate change, earthquakes and other catastrophic events through smart design and sighting.

We are committed to high ethical standards through a strong Code of Ethics and Business Conduct, ongoing ethics training, and executive leadership that promotes a culture of integrity.

We cultivate strong stakeholder relationships through transparency, open communications, and responding to stakeholder input.

We establish clear and effective governance for ESG, set goals and establish accountability. This is set through our ESG committee and reported to our board.

Our Business and ESG

ESG is about assessing that net positive impact in the world, and taking concerted, defined and measurable action to improve it. Our value rests in our employees, our communities, and the wider world. Therefore, ESG forms a fundamental part of how our business lives our values in the real world.

The ethical and practical values that make up the different parts of ESG have always been at the heart of what we as a company stand for. With the growth of ESG and the increased awareness of these factors among our key stakeholders, we have a better opportunity to tell the story of how our business makes a positive impact in the world.

The drive to assess a broader range of factors in a holistic manner, from environmental and climate change considerations to the social issues and how we invest in our people, to the structure of our business and always reaching for better governance, means we can tell our story better. We welcome opportunities to highlight the positive impact we have on the world.

Our Duty to the Wider World

As a business, we also have a duty to our people, our customers, and the wider world. ESG gives us an opportunity to bring those impacts together. We value investing in our people as we value protecting our environment and being a good corporate citizen.

Fostering openness, sustainability, and respect are our key objectives. We value everyone and strive to work as one team. Our view on ESG is that it is a continuous process of aligning our operations and controls with our values as a company.

Our commitment to improve our social and environmental performance demonstrates a strong, well-informed management attitude and a values-led culture that is both alert and responsive to the challenges and opportunities of doing business responsibly and sustainably.

ESG and Our Reputation

ESG is fundamental to our reputation as a business. Reputation is built through frequent and repeated interactions with stakeholders. When those interactions are positive, our business, and our reputation, can thrive. In an uncertain economic climate, positive reputation is one of the key drivers to long term success.

We want all our stakeholders, from customers to investors to our people, to be proud to be a part of our business. Part of that pride is understanding how our business makes a positive contribution to the world.

• Environmental – Environmental sustainability is an ethical and commercial imperative. Managing our carbon footprint goes hand in hand with the strategic necessity to operate efficiently. Our commitment to tackling climate change at a corporate level is fundamental to our strategic objectives.

• Social – Our people make up our business. Intellectual capital is core to our clients, our business model and our long-term sustainability as a business. We aim to foster an environment that values and nurtures unique talents and contributions from every individual within a culture of inclusivity. While we have progress to make, we are committed to cultivating and empowering change by building an inclusive workplace where all talents can thrive.

• Governance – Good governance is foundational to our business, and all aspects of ESG. We cannot thrive without paying attention to our compliance obligations. Our business seeks to go beyond the concept of ‘box-ticking’ and embed compliance into the heart of our business.

Our Responsibility to Our Customers

We have an obligation to our customers to offer them the best service. Customers are at the heart of our business, and without these partnerships our business wouldn’t exist. Part of that commitment to customers is about responding to their needs, hearing their concerns and committing ourselves to customer satisfaction.

The best customers are those who see us as partners in their own enterprise. In turn, those customers reward us with their continued business, and building and maintaining our world-class reputation.

ESG priorities are drawn not only from investor concerns but customer needs. Customers are asking how we are improving the world around us. How are we protecting our shared natural heritage, investing in our communities and being good corporate citizens? It is imperative on us as a business that all of our interactions with customers are reflective of who they expect us to be. And that is a partner in their own enterprise. A company they are proud to work with and recommend.

That is why it is important for you to understand ESG, its impact and what it means for our company. We want you to feel proud of being part of our business and the positive impact we have on the world, so that our customers will feel the same.

Your Role to Play in ESG

As a member of our business, you have a vital responsibility to ensure our organisation thrives. When it comes to ESG, this means understanding your role in each area of ESG. You can start to do this by familiarising yourself with the concept of ESG, such as through this course, and also our strategic objectives around ESG. You should know:

• Our strategic ESG goals

• How we plan to achieve them and over what time

• Your individual and team contribution to those goals

• How to discuss our ESG goals with customers and third parties

• Where to report potential concerns or actions which go against our policy

On an individual level, you have an important role to play in meeting our ESG objectives. Here’s how:

• Environmental – We all have a role to play in reducing carbon emissions and getting to net zero. While as a business we are setting organisation-level targets, consider the choices you make and the environmental impact. For instance:

  • When travelling, are there more environmentally friendly options to take?

  • Can some meetings be done remotely instead of travelling?

  • Think before you print

  • Does the office have recycling and energy saving measures?

• Social – Building a diverse and inclusive workforce where everyone feels valued is everyone’s responsibility. Understanding your role in bringing people together is critical to our success as a business. From hiring the best talent to encouraging all staff to thrive, we want a workplace where people proactively work to be the best. You can help by:

  • Challenging and reporting discriminatory or offensive behaviour

  • Understanding diversity and inclusion policies

  • Being an active ally for groups often underrepresented

  • Leading by example in your work

• Governance – Good governance goes beyond having the right policies and procedures in place. It’s about embedding compliance in your day-to-day work. From completing training on time to actively understanding how regulations affect your work, good governance starts from the individual acting ethically. Take governance to heart by:

  • Be a compliance champion in your team,

  • Refer to policies and procedures instead of shortcuts,

  • Be aware of red flags for compliance failures and risks in your area of work; and

  • Don’t be afraid to call out poor behaviour or report failures.

ESG and Our Value Chain

Our business does not operate in isolation; almost no company does. Value is created through collaboration and partnerships. Similarly, risks can come from not anticipating problems, gatekeeping, and hiding critical information. Traditional risks in supply chains were generally about quality, cost effectiveness and reliability. But seen through an ESG lens, the holistic nature of the third parties, from how they source raw materials to how they treat workers and comply with accepted standards are just as vital.

A workforce health and safety incident, labour dispute or allegation of corruption can have serious impacts on stakeholders up and down the value chain. The value chain matters, and it is connected. Customers are increasingly voting with their feet and putting pressure on companies to act with ethical decisions in mind.

Ethical procurement gets to the heart of the value chain. When we consider the entire value chain, from raw material supplier to end use customer, we can better understand the needs and impacts of our business’s decisions within those relationships. Ethical procurement within the context of ESG means paying attention to the carbon impacts of a supplier, and the labour practises of an end-user.

Considering these impacts doesn’t always mean refusing to work with someone in the value chain where there are concerns. Sometimes suppliers are limited, and customers have every right to access our services. It’s about understanding the risks within each relationship and taking concerted action to reduce those risks.

For example, if there are concerns about a supplier’s labour practises, we can ensure clauses are inserted into contracts to maintain an adequate standard of employment for those working for the supplier. This can help actively change labour practises, as opposed to simply refusing to work with a supplier. Or when working with a logistics provider, we might ask for emissions reporting so we can then offset the carbon used.

How to Procure Ethically

• Risk assessments: Undertake risk assessment of the value chain in order to identify key vulnerabilities based on supplier and customer needs.

• Real-time tracking: Real-time tracking and traceability over suppliers and movements of goods and services.

• Screening, risk-ranking & monitoring: ESG due diligence on suppliers to evaluate and rank them based on their ESG profile and track record, and monitoring for ESG breaches.

• Investigations: Investigate ESG incidents that take place in the value chain, have remediation plans ready and manage financial and reputational damage.

• Incident response management: Build robust internal governance frameworks to respond to ESG issues in the value chain.

Our ESG Committee

Our ESG committee sits directly beneath our board in terms of seniority. The purpose of the committee is to gather and review data from broad parts of the business, then filter and summarise it upwards to the board. The ESG committee is responsible for writing the ESG pages inside the annual report, and producing all information regarding ESG disclosures.

The aim of the committee is to establish a unified view of ESG, increasing understanding of all three aspects, environmental, social and governance, and to promote robust standards of corporate governance that integrate all these aspects for non-listed real estate vehicles. This will help the industry more effectively integrate ESG factors into the real estate investment decision-making process.

The key objectives of the committee are to:

• Emphasise the importance of environmental measures, sustainability goals and performance, at all levels of the business,

• Provide best practice on the structure, policies and regulations that impact the business,

• Increase understanding and awareness of corporate governance and social aspects that impact the industry.

• Implement and promote common and workable standards of corporate governance for the business.

Monitoring and Enforcement

We seek to proactively prevent and mitigate instances of non-compliance with this ESG policy.

Any breaches or concerns, including ethical concerns or potential breaches in our commitment to high ethical standards should be reported as soon as possible through our whistleblowing channels.

Progress on this policy is reported to the Board on a regular basis. Active participation and engagement at all levels of the business is of great importance to ensure ownership of ESG by all staff. At minimum, we endeavour to maintain compliance with legislative requirements.

Last updated: 21st November, 2025

Health and safety policy statement

This policy sets out how Space in Africa Consulting Limited (“SIA”) and its employees will manage its health and safety obligation and rights with the aim of ensuring a safe and productive workplace not just for itself but also for third parties in or around its facilities.

SIA recognises and accepts its health and safety duties for providing a safe and healthy working environment (as far as is reasonably practicable) for all its workers (paid or volunteer) and other visitors to its premises

SIA is committed to providing a safe and healthy workplace, safe working methods, and the provision of safe equipment. Workplace health and safety is considered by management to be an integral and vital part of the successful performance of any job.

We will manage health and safety by:

• Controlling the health and safety risks at work.

• Involving employees on health and safety issues that affect them.

• Making sure that where employees work, and any equipment they use, is safe.

• Making sure that dangerous substances are stored and used safely.

• Ensuring that only approved and accredited employees and/or third parties are working on sensitive work sites with the appropriate work gears.

• Making sure employees, especially new employees, have relevant information and training on health and safety.

• Making sure employees can do their jobs and are properly trained.

• Trying to stop accidents and work-related health problems.

• Regularly checking that working conditions are safe and healthy.

• Regularly reviewing this policy and making changes if necessary.

Risk Management

SIA uses the concept of risk assessment as a fundamental part of its approach to safety management. The organisation is committed to identifying the risks brought about by its activities followed by implementation of control measures to reduce risks to a level that is as low as reasonably practicable.

Risks connected with work activities are assessed by:

• identifying the groups of staff;

• identifying the main activities they perform;

• listing the significant hazards associated with those tasks; and

• selecting the most appropriate control measure to minimise the hazard.

Risk assessments must be carried out in conjunction with the staff performing the task and Line Managers where appropriate. Control measures must be implemented and these may include, in a limited number of cases, formal safe systems of work.

Reporting, Investigation and Responsibilities

SIA’s policy is to use preventative measures to stop accidents occurring. On the occasion of accidents, incidents, near misses (a “near miss” is an event which under slightly different circumstances could have resulted in an accident) and occupational ill-health, the circumstances are to be reported and investigated promptly. When the underlying causes have been identified action is to be taken to prevent recurrence.

SIA is committed to:

• Integrating workplace health and safety into all aspects of its operations;

• Identifying hazards, assessing risk and implementing control strategies to minimise risk of injury to people and property;

• Ensuring that relevant health and safety laws that apply to working conditions and the work environment are observed and enforced;

• Developing and implementing safe systems of work;

• Providing adequate safety information, training and supervision;

• Designing, purchasing, installing and maintaining a safe site and machinery;

• Ensuring that the workplace under their control is safe and without undue risks to health;

• Ensuring that the behaviour of all persons in the workplace is safe and without undue risks to health;

• Attempting to remedy all problems relating to workplace health and safety;

• Consulting with workers and other parties to address safety issues and improve decision making on workplace health and safety matters; and

• Supporting and assisting workers in effective injury management and rehabilitation.

All employees and contractors have the responsibility to:

• Adhere to safe work practices, instructions and rules;

• Immediately report any unsafe work condition or equipment to the Company;

• Not misuse, damage, refuse to use, or interfere with anything provided in the interest of workplace health and safety;

• Perform all work duties in a manner which ensures individual health and safety and that of all other people in the workplace;

• Encourage fellow employees to create and maintain a safe and healthy work environment; and

• Co-operate with all other employees to enable the health and safety responsibilities of all employees be achieved.

• Co-operate with authorised personnel who are responsible for health and safety.

• Use safety equipment when it is necessary.

• Take care of their own health and safety.

• Report health and safety concerns to the authorised personel as stated in this policy.

The overall responsibility for health and safety belongs to the Managing Director.

The daily responsibility for managing this policy is given to an employee designated as the Health and Safety officer for SIA.

Controlling the health and safety risks at work

The Health and Safety Officer responsible for implementing this Policy has the responsibility to do regular health and safety risk assessments.

The results of the risk assessment will be given to Managing Director and/or Head of Operations and will be included with this policy.

The Managing Director and the Head of Operations should agree any action needed to manage the risks that have been found.

The Health and Safety Officer will carry out the agreed action points.

The Managing Director and the Head of Operations will check that the actions taken have reduced the risks.

Risk Assessments shall be carried out every 6 (six) months, or when there is a change to the way SIA works.

Communication And Consultation

SIA recognises that employee consultation and participation in our safety system is vital and improves decision– making about health and safety matters in the workplace. Consultation is also included in the process of risk assessments and the development of our safe work practices.

Employees shall be actively involved in the workplace safety system. Suggestions for change and improvements to policies, procedures or safe work practices are encouraged, through reporting to management. Meetings to consult and inform employees on safety issues shall be conducted through staff meetings, as regularly as is necessary.

Employees shall be made aware of safety issues relating to their jobs on a regular basis. The manner of doing so will vary depending upon the type of information to be conveyed.

We expect our employees to be committed to working with management in order to effectively manage health and safety on the job. Employees are encouraged to contribute to decisions that may affect their health and safety in the workplace, through contact with management and staff meetings.

The management shall work in conjunction with employees to review and update this, and other policies and procedures.

Workplace Injuries—Rehabilitation And Return To Work

SIA is proactive in its approach to injury management and places strong emphasis on the safe, timely and sustainable return to work program for injured or ill workers.

We are committed to:

• Prompt injury notification;

• Communication and consultation with all parties to develop an appropriate return to work program;

• Accountability and responsibility for injury management being clearly understood;

• Provision of suitable meaningful activities during the return-to-work process; and

• Dispute resolution as required.

SIA will ensure the following positive approach in meeting these objectives, including:

• Early reporting of injuries;

• Appropriate and timely medical intervention and return to work planning;

• Provision of suitable resources and productive duties for the injured worker;

• Positive support and encouragement during the rehabilitation process; and

• Review of incidents and accidents to seek preventive measures and continuous improvement.

SIA shall work in conjunction with employees to review and update this policy, and other policies and procedures relating to work health and safety as regularly as is necessary.

Checking work conditions are safe and healthy

To ensure the safety of employees at the workplace and that this health and safety policy is being followed SIA will regularly carry out inspections, investigate accidents and near misses, collect reports, meet with representatives.

The designated Health and Safety officer is responsible for investigating accidents at work.

The Health and Safety officer is responsible for investigating work-related causes of absence.

The Health and Safety officer is responsible for acting on the results of the investigation to stop the same problem happening again.

Fire and evacuation

The Health and Safety officer is responsible for making sure that the fire risk assessment is done, and any action points are carried out.

Escape routes, Alarms, Fire extinguishers are checked and maintained by the Health and Safety officer every 3 (three) months.

Emergency evacuation will be tested every 6 months.

The evacuation procedure is:

If the alarm sounds

• Evacuate the building immediately by the nearest exit;

• Ensure any visitors leave the building;

• Do not put yourself at risk;

• Assemble in front of the building; and

• Do not re-enter the building for any reason until the Fire Officer or fire brigade confirm that it is safe to do so.

If you discover a fire

• Raise an alarm.

• Evacuate the building immediately as above.

Third Party Contractors

• Where appropriate, third party contractors will be required to submit a copy of their safety documentation i.e. Health & Safety Policy, liability insurance and risk assessments/method statements prior to commencing work so that SIA can ensure appropriate consideration has been given to safety;

• Third party contractors will be supplied with a copy of SIA’s Health and Safety Policy and will be expected to abide by the policy unless a variation has been explicitly agreed; and

• All contractors undertaking work within SIA’s offices will be provided with information on local Health and Safety arrangements where appropriate and will only commence work with the approval of the Office/Facilities Manage.

Premises Security

• appropriate security measures will be in place at SIA and these will be actively SIAed and reviewed to ensure the safety of workers, visitors and equipment. All visitors will be signed in at Reception;

• Arrangements will be made for the provision of sufficient key holders and suitable training and information will be provided.

We hereby request that every staff, volunteers, member and visitors respect this Policy, a copy of which will be available on demand.

Last updated: 21st November, 2025

Introduction

In addition to the Space in Africa Consulting Limited’s (“SIA”) comprehensive data protection and data handling policy, this document establishes the framework of SIA’s Information Security Policy (“Policy”) which illustrates its commitment to protect the Confidentiality, Integrity, and Availability of the data and information of SIA stakeholders in the course of business.

Purpose

The purpose of SIA’s Information Security Policy is to describe the actions and behaviors required to ensure that due care is taken to avoid inappropriate risks to SIA, its employees, its business partners, and stakeholders.

Scope

SIA Information Security Policy applies equally to any individual, entity, or process that interacts with SIA’s Information Resource.

Definitions

This Information Security Policy reflects the definitions below:

• Confidentiality means ensuring that information is accessible only to those persons that are authorized to have access

• Integrity means protecting the accuracy and completeness of information and the methods that are used to process and manage it

• Availability includes ensuring that information assets such as information, systems, facilities, networks, and computers are accessible and usable when needed by an authorized person

• Data Protection Officer includes any staff of SIA appointed by the management to supervise the administration and enforcement of this policy

Policy

The Information Security Program:

SIA maintains and communicates an Information Security Program consisting of topic-specific policies, standards, procedures and guidelines that:

• serve to protect the Confidentiality, Integrity, and Availability of the Information Resources maintained within the organization using administrative, physical and technical controls;

• provide value to the way SIA conduct business and support institutional objectives;

• comply with all regulatory and legal requirements, including the Cyber Crime Act, Nigeria Data Protection Act, Nigeria Data Protection Regulation and the Freedom of Information Act.

The Information security program is reviewed not less than annually or upon significant changes to the information security environment.

Functional Information Responsibilities

The Executive Management shall be responsible for:

• evaluating and accessing information risk on behalf of SIA;

• identifying information security responsibilities and goals and integrating them into relevant processes;

• supporting the consistent implementation of information security policies and standards;

• supporting security through clear direction and demonstrated commitment of appropriate resources;

• promoting awareness of information security best practices through the regular dissemination of materials provided by the Data Protection Officer or his representative;

• implementing the process for determining information classification and categorization, based on industry-recommended practices, organization directives, and legal and regulatory requirements, to determine the appropriate levels of protection for that information;

• implementing the process for information asset identification, handling, use, transmission, and disposal based on information classification and categorization;

• determining who will be assigned and serve as information owners while maintaining ultimate responsibility for the confidentiality, integrity, and availability of the data;

• participating in the response to security incidents;

• complying with notification requirements in the event of a breach of private information;

• adhering to specific legal and regulatory requirements related to information security; and

• communicating requirements of this policy and the associated standards, including the consequences of non-compliance, to the workforce and third parties, and addressing adherence in third party agreements.

The Data Protection Officer shall be responsible for:

• maintaining familiarity with business functions and requirements;

• assessing compliance with information security policies and legal and regulatory information security requirements;

• evaluating and understanding information security risks and how to appropriately manage those risks;

• representing and assuring security architecture considerations are addressed;

• advising on security issues related to procurement of products and services;

• escalating security concerns that are not being adequately addressed according to the applicable reporting and escalation procedures;

• disseminating threat information to appropriate parties;

• participating in the response to potential security incidents; and

• participating in the development of enterprise policies and standards that considers SIA’s needs; and promoting information security awareness.

Information Classification and Handling

• All information, which is created, acquired or used in support of business activities, must only be used for its intended business purpose;

• all information assets must have an information owner established within the lines of business;

• information must be properly managed from its creation, through authorized use, to proper disposal;

• all information must be classified on an ongoing basis based on its confidentiality, integrity and availability characteristics;

• if SIA is unable to determine the confidentiality classification of information, the information must have a high confidentiality classification and, therefore, is subject to high confidentiality controls.

• merging of information which creates a new information asset or situations that create the potential for merging (e.g., backup tape with multiple files) must be evaluated to determine if a new classification of the merged data is warranted;

• all reproductions of information in its entirety must carry the same confidentiality classification as the original;

• a written or electronic inventory of all information assets must be maintained;

• content made available to the general public must be reviewed by the Data Protection Officer to ensure adherence to the company’s disclosure policies and standards;

• non-public information disclosed to any third party must be confirmed by the Data Protection Officer as appropriate, in accordance with processing principles, is on a need-to-know basis, necessary and on the same degree of data protection measures provided by SIA.

Enforcement

This policy shall take effect upon publication which may be amended at any time. Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment, and related civil or criminal penalties.

Last updated: 21st November, 2025

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

At Space in Africa Consultancy Limited (“SIA”), we have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

Responsibility for the Policy

The HR and/or Legal Department has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that we, and those working for us, comply with it.

The Supervisors and Line Managers have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.

Compliance with the Policy

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager OR the HR OR Legal & Compliance Departments as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or the supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager, HR, Compliance or report it in accordance with our Whistleblowing Policy as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your manager or HR or Compliance.

We encourage openness and will support anyone who raises concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.

Communication and Awareness of Policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, service providers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Last updated: 21st November, 2025