To whom does this Code apply?

• This Code of Conduct (“Code”) is applicable to all suppliers and tenants who provide goods or services to Mileway and its subsidiaries. Mileway’s direct suppliers and tenants must ensure that any sub-contractors, agents or third parties engaged by them in support of Mileway’s business also comply with this Code.

What does this Code do?

• This Code supports the commitment of Mileway to upholding the highest ethical and professional standards in their business dealings and relationships with suppliers and tenants wherever they operate.
• Mileway is committed to working with suppliers and tenants who are aligned to these same values.
• This Code formalises the standards expected of any supplier or tenant doing business with Mileway. We recognise that suppliers and tenants operate in different cultural and legal environments and this Code outlines the core requirements, principles and practices that suppliers and tenants are expected to adhere to.
• The Code is intended as a minimum standard. Mileway strongly encourages suppliers and tenants to exceed the requirements and to promote best practice and improvement throughout their own supply chain and to comply with all legal obligations on them wherever they operate.

What must you do?

• Mileway expects its suppliers and tenants to act in full compliance with applicable laws, including in particular those relating to human rights, data protection, health and safety and bribery and corruption.
• Mileway suppliers and tenants must comply with the provisions of this Code. They must seek to uphold the highest ethical and professional standards in their business dealings and relationships with Mileway.
• Suppliers and tenants must notify Mileway immediately if they become aware of any breach or potential breach of this Code.
• In the event of a supplier or tenant breaching this Code they must promptly implement corrective action wherever possible and ensure Mileway is updated in respect of any such breach and subsequent corrective measures.

1. Ethical Business Practices

Mileway suppliers and tenants must have in place systems and procedures that are designed to assist them in upholding high standards of integrity, honesty and ethics in all their activities.

1.1. Bribery and corruption

1.1.1. Mileway takes a zero-tolerance approach to bribery and corruption and we expect our suppliers and tenants to adopt the same approach. Mileway suppliers and tenants must never offer, promise, give, request, agree to receive or accept a bribe in connection with Mileway business.

1.1.2. Mileway recognises that gifts and hospitality can build goodwill and help foster positive business relationships. However, any gift or hospitality received or given in connection with Mileway business should always be reasonable in terms of value and frequency.

1.1.3. Suppliers and tenants must not provide any gift or hospitality where it might improperly influence Mileway personnel or any third party’s decision in relation in any aspect of their work with Mileway.

1.2. Competition

1.2.1. Competition law regulates the behaviour of businesses in order to promote competition for the ultimate benefit of consumers (e.g. in the form of lower prices, better products, increased innovation, etc.).

1.2.2. Mileway is committed to ensuring that it and its personnel do not, directly or indirectly, break or seek to evade the competition laws or regulations of any country in or through which it does or seeks to do business. Mileway expects its suppliers and tenants to adopt the same approach.

1.2.3. Suppliers and tenants must not share with Mileway personnel any non-public information they have about our competitors or any information about their engagement, if any, with our competitors.

1.3. Fraud, Tax Evasion and Money Laundering

1.3.1. Suppliers and tenants must not engage or assist in any activity whatsoever relating to fraud, tax evasion or money laundering in connection with Mileway business.

1.3.2. Whilst the definition of fraud may vary across countries, its fundamental element is of deception and dishonesty. Any attempt to deliberately deceive someone in order to gain any kind of material advantage can amount to fraud. Suppliers and tenants must never knowingly seek to engage in any fraudulent activity.

1.3.3. Prohibited activities include:

• stealing from the company, a customer or any third party;
• any kind of misappropriation of property;
• any kind of misreporting of time or costs;
• inflation of invoices; and
• engaging or assisting money laundering.

1.3.4 With regards to tax evasion or the facilitation of tax evasion by others, Mileway maintains a robust standard of prevention. Suppliers and tenants will be expected to adhere to these same standards. Please refer to the Mileway Anti-Facilitation of Tax Evasion Policy for further details.

2. Fair Treatment and Equal Opportunity

2.1. Diversity, equality and inclusion

2.1.1. Mileway is committed to diversity, equality, and inclusion.

2.1.2. Employment – including recruitment, payment, benefits, promotion, training, termination and retirement – must be based on ability and merit, not on personal characteristics. Mileway does not tolerate discrimination or bias and we expect our suppliers and tenants to share these values.

2.1.3. Suppliers and tenants must provide equal employment opportunity to all regardless of ethnicity, gender identity, sexual orientation, religion, nationality, age, disability or any other characteristic.

2.2. Harassment and bullying

2.2.1. Every member of Mileway personnel has the right to freedom from harassment and bullying. Mileway is committed to promoting a work environment that is free from discrimination, harassment, intimidation or other forms of bullying and we expect our suppliers and tenants to adopt the same approach.

2.2.2. Harassment (both overt and subtle) is a form of misconduct that is demeaning to another person. Mileway is strictly opposed to any form of bullying and harassment and expects our suppliers and tenants to reject harassment or bullying in all its forms.

3. Modern Slavery, Human Trafficking & Human Rights

Mileway adopts a zero-tolerance approach to modern slavery or human trafficking in our supply chains or in any part of our business.

3.1. Forced and child labour

3.1.1. Suppliers and tenants must not use and must have a zero tolerance for any form of human trafficking or child, forced or compulsory labour.

3.1.2. Suppliers and tenants must also have in place adequate procedures to ensure that they are not directly or indirectly, through their supply chain, involved in any modern slavery or human trafficking.

3.1.3. Suppliers and tenants must comply with the local laws regarding the minimum age for workers and any other applicable child labour laws.

3.1.4. Suppliers and tenants must report immediately to Mileway if they discover any modern slavery or human trafficking issue within their own supply chain.

3.2. Wages and benefits

3.2.1. Suppliers and tenants must comply with any local laws relating to working hours, wages and overtime pay.

3.2.2. Workers engaged by suppliers and tenants need to be paid at least the minimum legal wages, or wages that comply with local industry standards. In addition to regular hours, workers must be paid for any overtime at legally required rates or, in those countries where such laws do not exist, at least equal to their regular hourly payment rate.

3.2.3. All overtime must be voluntarily undertaken.

3.3. Freedom of movement and association

3.3.1. Workers’ freedom of movement must not be unreasonably restricted, nor should workers be physically confined to the workplace or related premises. Suppliers and tenants must not use any coercive means to restrict their workers or Mileway personnel.

3.3.2. Mileway recognises the importance of open communication and engagement between Mileway personnel and management and expects its suppliers and tenants to do the same. Mileway suppliers and tenants must respect the rights of workers to associate with and openly discuss their working conditions with management, without fear of harassment or intimidation.

4. Data Protection

4.1. Mileway recognises its duty to respect personal information, ensure it is protected and handled correctly and only used for the purposes for which it is provided.

4.2. Suppliers and tenants must also ensure that all personal information is controlled and stored in accordance with applicable laws and regulations.

4.3. Mileway expects its suppliers and tenants to manage personal information in accordance with the General Data Protection Regulation 2016/679 and Mileway’s Data Protection Policy.

5. Environment and Sustainability

5.1. Mileway is committed to understanding and mitigating its impact on the environment and expects its suppliers and tenants to do the same.

5.2. Suppliers and tenants must comply with all applicable laws, rules and regulations in connection with the environment and seek to operate in a manner which maximises sustainability of resources and limits, to the extent possible, their impact on the natural world, particularly with respect to water, greenhouse gas, energy, hazardous chemicals, air quality and waste. Further, we expect our suppliers and tenants to incorporate environmentally responsible practices into all of their activities that relate to their business with us.

5.3. Suppliers and tenants shall provide copies of any environmental management, sustainability, and ESG policies to Mileway where possible.

5.4. Mileway may request environmental data related to supplier operations carried out on behalf of Mileway.

6. Health & Safety

6.1. Mileway is committed to ensuring a safe, hazard-free environment for its workers and all those on its premises and to complying with all applicable health and safety laws and regulations. We expect our suppliers and tenants to adopt the same approach.

6.2. Suppliers and tenants must ensure they have in place risk-based health and safety policies and procedures in place in relation to all aspects of their work and that appropriate training, monitoring and auditing is in place in order to ensure compliance with those policies and procedures. In doing so, suppliers and tenants must comply with all national laws, regulations and best practices concerning health and safety in the workplace, as well as providing all required and appropriate workers compensation coverage in the event of injury or fatality.

6.3. Suppliers and tenants must provide Mileway with a list of any injuries of deaths that have occurred in the course of, or incidental to, its business in the past 5 years prior to commencing work for Mileway. Suppliers and tenants must also provide such additional information as may reasonably be required by Mileway to ascertain the safe working practices of its suppliers and tenants.

6.4. Mileway may request safety data and records related to supplier operations carried out on behalf of Mileway.

7. Monitoring and Breach Of This Code

7.1. Mileway will support its suppliers and tenants in seeking to comply with the requirements of this Code of Conduct.

7.2. Suppliers and tenants will allow Mileway access to their facilities on an announced or unannounced basis in order to allow Mileway to conduct as assessment of the supplier’s compliance with this Code. Suppliers and tenants will cooperate with such inspections/assessments and provide all reasonably requested documentary or other evidence of their compliance.

7.3. In the event of material breach by a supplier of the requirements set out herein, in the event that such breach is not rectified within the earlier of 30 days of the supplier or Mileway becoming aware, it shall amount to a material breach of the agreement between the parties and Mileway reserves the right to terminate the agreement or relationship with that supplier, where such termination is allowed under the applicable law.

8. Asking Questions and Raising Concerns

8.1. If you have any questions or wish to raise any concerns regarding the contents of this Code, please contact your usual Mileway contact or the Mileway Legal Department.