Supplier and Sub-Contractor Code of Conduct Common Procurement Standards and Guidelines for the Rail Baltica Project April, 2017 RB RAIL AS, www.railbaltica.org

Introduction Suppliers and sub-contractors are evaluated beyond the basis of economic criteria and basic procurement regulations alone. We, the responsible for the implementation of the Rail Baltica project, also look closely at labour practices, health and safety, environmental protection, taxation and full compliance with human rights as well as ethical conduct, anti-discrimination and anti-corruption policies. Our Supplier and Sub-Contractor Code of Conduct captures the principles we expect every potential supplier to uphold. All suppliers and sub-contractors of the Rail Baltica project are subject to this Code of Conduct, and procurement contracts will be awarded to tenderers that comply with these best market practices. 1. Labour We expect our suppliers to ensure equality of opportunity and treatment to every employee, without discrimination, including discrimination of race, colour, sex, religion, political opinion, national extraction or social origin. Suppliers and sub-contractors must allow their workers the freedom of association, to organize themselves and to bargain collectively. We will only employ people of working age under their own free will. There will be no forced or compulsory labour, in any form, including child labour, no employment of children below the age of 15 or the minimum age for employment according to applicable laws, and persons under the age of 18 will not perform any hazardous work. Wages are to be paid in a legal fashion, at regular intervals no longer than one month, in full and directly to the worker. It is important for suppliers and sub- contractors to keep record of each payment. Any deductions from wages will be declared at the time of each payment. The wages, hours of work and working conditions provided should be among the best conditions for similar work prevailing locally. Health and safety are a key concern during the execution of this project. Every element of the work environment should be safe and without risk to the health of the worker, and in accordance with internationally recognized health and safety management principles, practices and laws. This includes safe use of chemical, physical and biological substances and proper protective equipment and work clothing.

Upholding human rights is simply the right thing to do Upholding human rights is simply the right thing to do. We expect our suppliers and sub-contractors to support and respect international human rights. It is necessary to cultivate an environment where employees treat each other with dignity and respect, without any threat of harassment, abuse or inhumane treatment. . 2. Environment Rail is one of the most efficient and environmentally friendly ways to move goods and transport people. We recognize the important responsibility to reduce the environmental impact of transportation by offering sustainable solutions now and in the future. Environmental. We are committed to taking measures to minimize our impact. This means preventative measures, following environmental policy and complying with existing regulations regarding protection of the environment. We encourage our suppliers and sub-contractors to consider the lifecycle of their environmentally friendly technologies. Chemical and Hazardous Materials, Air Emissions, Waste. Our goal is to improve the environment we are in, and improve regions in which we work. When using chemical and hazardous waste, be sure to identify and manage their safe handling, movement, storage, recycling or reuse, and disposal. Any wastewater or solid waste should be controlled and treated before disposal, as should any harmful air emissions of corrosives, particulates, any ozone depleting chemicals or combustion by-products. Minimize waste and maximize recycling. The best way to minimize environmental impact is to minimize waste and maximize recycling. Waste can be reduced by modifying production, substituting materials, by conservation and by re-using materials. It is important to consider the impact of your actions, and remember the long-term shared goals of the project. 3

3. Ethical conduct Ethical conduct is essential for sustainable business and we treat ethics as an integral part of our activities. We expect high ethical standards of everyone who acts on our behalf, and we encourage suppliers and sub-contractors, and everyone we work with, to expect the same high standards from their partners. Corruption We have zero tolerance for bribery and corruption in any form, including fraud, bribery and extortion in the conduct of business. Suppliers and sub-contractors will not request, receive, or accept any improper advantage during procurement. We will comply with all applicable laws and take active steps to ensure there is no corruption during the implementation of the Rail Baltica project. Conflict of Interest Having a conflict of interest negatively affects the transparency of the project. No supplier will take part in any decision where there is an actual or perceived conflict of interest. A conflict of interest can include working on a procurement procedure together with the Beneficiaries or Implementing Bodies of the Rail Baltica project, or if a supplier or sub-contractor has any interest in the business that are not the same as the best interests of the project, or if the sub-contractor has economic ties with the supplier or special interest in their business. Gifts, Hospitality Beneficiaries and Implementing Bodies have a zero-tolerance policy toward accepting gifts and hospitality. This means no offers of tickets to cultural or similar events, invitations to meals, housing, recreational trips, transportation or objects paid for by the supplier or sub-contractor. We expect that our suppliers will not offer any one of our related employees new employment or a sales opportunity in order to facilitate the supplier’s business. Post-employment restrictions Suppliers and sub-contractors should not offer Beneficiaries’ or Implementing Bodies’ staff any employment for during and two years after the end of their work on the Rail Baltica project. Selection of business partners and own suppliers Our suppliers and subcontractors should adopt and promote the key principles of this project to their partners. We absolutely do not tolerate any form of bribery, fraud, misappropriation, terrorism or evading payment of taxes in the partners of our supplier and sub-contractors. All partners should be thoroughly checked for violations of insolvency, bribery, or any infringement of competition rights, a horizontal cartel agreement or tax debts.

Monitoring and enforcement If any illegal activity will be noticed (bribery, corruption, cartels), the implementing bodies of the Rail Baltica project will notify the authorities without hesitation, and cooperate with them to resolve the situation and protect Rail Baltica project investments. Any person, who wishes to share information about suspicions of illegal activity, even if it proves to be unfounded, should do so immediately, and they will remain anonymous. The implementers of the Rail Baltica project will adhere to all applicable laws and regulations, internal policies and procedures, and international agreements. RB Rail is the central coordinator of the CEF financing flow and the mediator between INEA and Beneficiaries. As the coordinator, it is responsible for information exchange, dispersing INEA payments to Beneficiaries and monitoring interim and pre-financing payments. RB Rail has the right to withhold financing payments in the case of ineligible costs. RB Rail prepares and submits the Action Status Report to INEA containing the proposals from the Beneficiaries. Suppliers can expect to have audits and visits as part of consistent monitoring and enforcement, and are expected to be completely cooperative. RB Rail reserves the right to perform audits at any time. 5

Supplier and Sub-Contractor Code of Conduct © RB RAIL AS