30th of January 2022

To our stakeholders,

I am very happy to confirm that Planet Holding Ltd. reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption. In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.

Regards,

Gianni Savio
CEO Planet Smart City

Planet respects and supports human rights principles as defined by the principles of the Universal Declaration of Human Right s (UDHR), the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work (“ILO Declaration”), and the United Nations Global Compact. We will work to ensure that we do not violate these human rights principles through our business operations and activities. Should employees witness any violations of the human rights principles or the law in any way, they are actively encouraged and are required by company policy to report it immediately.

The Company undertakes to offer equal opportunities and fair treatment to all employees, without discrimination of race, religion, political opinion, trade union activities, country of origin, gender, age, physical health status and anything else inherent to the person already provided for and protected by law. Administrators, managers, and employees undertake actions to implement absolute equality of rights and to promote every possible and permitted initiative aimed at accessing equal opportunities for all Planet workers.

Management and employee demographics broken down by diversity factors (cumulative of all office employees combined)

Age distribution

• Baby Boomers 7%
• Generation X 29%
• Generation Y 56%
• Generation Z 8%

Gender distribution

• Male 82%
• Female 18%

Employees in Italy

Planet Italy divides its employee contractual agreements into two types based on experience and specialisation. They are as follows:

• 15% of employees currently working at Planet Italy are under a form of apprenticeship contract called “Apprendistato”. This contract is for employees under the age of 30 and lasts for a period of 3 years. During this period, employees can choose to learn and specialise in a particular role. Until now, all employees who started under this contract have successfully remained at Planet and wished to convert their contracts
into full permanent contracts.

• The remaining 85% of employees are hired on full time permanent contracts.

Working environment during COVID-19

• Planet Italy immediately addressed the pandemic and the need to keep employees safe through flexible and/or remote working capacities to keep employees connected through collaboration tools and virtual environments.

• During lockdown, employees in Italy were operating remotely on a full-time basis from March until May in 2020.
• From June 2021, employees were encouraged and given the option to work on a hybrid and in office basis.
• From July 2021, the office returned to work on a rota basis filling 60% of employees in the provided working spaces.

Gender diversification and growth

• Female employees represent 46% of the workforce.

Employees in India

• 86% of employees currently working at Planet India are permanent staff.

Working environment during COVID-19

• Guidelines on flexible working are in place and other measures have been implemented to protect employees during the pandemic.
• Employees were remotely operating full time during the intense lockdown in India during 2021. We had extended this remote working approach following the lockdown and supported employees to obtain vaccination. Only fully vaccinated employees have opted for partial
return to the workplace via a hybrid model of working.

Gender diversification and the growth

• Female employees represent 19% of the workforce.

Employees in Brazil

• 83% of employees currently working at Planet Brazil are permanent staff. The remaining are hired as project-based consultants.
• Planet Brazil is vocal about and promotes the equal rights of the LGBTQIA community and actively hires and promotes LGBTQIA employees as part of its diversity and inclusion programme. Planet Brazil also leads on several partnerships and programmes with local NGOs to raise
inclusion of the LGBTQIA community in Brazilian society.

Working environment during COVID-19

• Guidelines for flexible working are in place and other measures have been implemented to protect employees.
• Office based employees worked from home and manual work employees were given time off for two weeks due to the pandemic.
• In 2020, office-based employees had their employment contracts paused for two months following special government legislation put in
place to avoid job loss and dismissals. During 2021, employees returned to work as normal with the following local legislation guidelines for safety measures at construction sites:

o Distancing measures put in place to reduce risk of transmission (i.e split shifts and lunch hours to avoid crowding) o Hand sanitizers were purchased and distributed
around all workplace areas.
o Use of face masks following local legislation.
o Increase in cleaning and disinfecting protocols in the workplace.

Gender diversification and the growth

• Female employees currently represent 44% of the workforce.

In line with our overarching values and mission to better the lives of our communities, we also take in to consideration the wellbeing of our residents.
Planet’s people centric activities are a powerful force for social good. Measurement of community wellbeing and cohesion is notoriously challenging. We have therefore identified ten key wellbeing indicators:

-Community Governance
-Community Autonomy
-Community Vitality
-Gender Equality
-Social Diversity
-Participatory Activation
-Platform Engagement
-Service Co-Creation Rate
-Employability Skills Rate
-Family Expenses Reduction

Through our work with the European Federation for Living we are developing tools to measure the success of our social programmes, which will be fully integrated into our ESG/GRESB roadmap.

Our measurement action is continuously ongoing, and we are defining a structured framework to be included in our GRESB roadmap. Below we present some anecdotal evidence from one of our Brazilian projects, Smart City Laguna, up to Year End 2021:

- 16.858 people were involved in integration, entertainment and education activities promoted by Planet.
- 13.288 people participated in cultural and sporting activities to create development possibilities for the community.
- 105 classes and programmes were developed to encourage learning, entrepreneurship and other actions that promote income generation and economic
development for residents of the region.
- 30.965 people were positively impacted by online and offline social inclusion activities by Planet

Planet complies with all applicable labour standards and laws including those which relate to minimum wage, standard working hours, minimum working age, and holidays, throughout the world. Staff are hired with a formal employment contract in the ways provided for by current legislation and in a language of which they have a fluent understanding. No irregular or “undeclared work” position is ever allowed.

Upon establishment of the employment relationship, each employee receives adequate information relating to the regulatory and remuneration contents of the relationship so that acceptance of the assignment is based on full knowledge of their rights and the company’s responsibility to them.

Planet and its partners are continuously reviewing and improving internal policies and rules, preventing the presence of forced labour or bonded labour. Planet implements specific anti-labour exploitation educational notices and programmes in all work sites and develops specific Code of Conduct contracts with suppliers and partners alike with rules and obligations implemented to prevent such a scenario from occurring. Planet does not engage in oppressive or unfair child labour practices or knowingly engage a supplier or agent, or enter a joint venture with an organisation, that uses oppressive or unfair child labour practices.

Planet enforces a zero-tolerance approach to modern slavery, and we are committed to enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business, in any of our supply chains, in with any vendors we hire to perform services. Modern slavery is a crime and a violation of fundamental human rights. It can take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking. Planet is committed to ensuring compliance with all applicable modern slavery laws, including the UK’s Modern Slavery Act 2015.

Management and employee demographics broken down by diversity factors (cumulative of all office employees combined)

Age distribution

• Baby Boomers 7%
• Generation X 29%
• Generation Y 56%
• Generation Z 8%

Gender distribution

• Male 82%
• Female 18%

Planet has issued an Ethical Code of Conduct, a Supplier Code of Conduct and the General Purchasing Conditions, which are annex to all contracts and subcontracts as a mandatory rule with which to comply. The company requires all construction contracts to include obligations to comply with minimum wage standards with our contractors and suppliers

Planet has developed an internal health and safety strategy and manual which is shared with partners as a guideline for ensuring a safe approach to site activities. The company provides safety kits and toolboxes on a regular basis to existing workers to address and encourage the adoption of a safety-first culture across the company. We are also in the process of developing a worker health and safety access app for construction workers and other employees to access safety rules and working methodologies for each site activity.

During the early design stage, Planet carefully evaluates how to minimise and reduce excavation and earth movement activities. The use and reuse of local materials is favoured over importing materials wherever possible. This fundamental policy minimises waste production and reduces the energy consumption for material transportation. Moreover, by standardising construction activities at scale, we optimise both our use of materials and consumption of energy.

All our developments are connected to existing infrastructural grids or are in the process of constructing wastewater treatment plans. To avoid the risk of uncontrolled wastewater effusion during the construction phase, our projects expect to construct temporary local wastewater treatment plants. In addition, all our developments are staffed with storm water collection volumes.

The company ensures emergency procedures are in place to prevent and address accidents affecting the environment and human health and minimises the use and ensure safe handling and storage of chemicals and other dangerous substances.

Across all projects, we avoid environmental damage via regular maintenance of production processes and environmental protection system (air pollution control, waste, water treatment systems, etc.).

In 2021 Planet defined a roadmap for the compliance with ESG criteria. In 2022 Planet will commence the implementation starting with a gap analysis towards GRESB scoring. In 2022 and in line with the framework of ESG criteria, Planet will also start implementing measures to start quantifying the consumption and the emissions of building site activities.

Planet regularly conducts assessments of risks related to corruption and bribery, including frequent reviews of the U.K. Bribery Act, U.S. Foreign Corrupt Practices Act (FCPA), Brazilian Clean Company Act and any other country-specific requirements.

Planet formalises and distributes our Anti-Bribery and Corruption policy and Gifts, Entertainment and Hospitality policy to all employees and records
the confirmation of acknowledgment, acceptance, and commitment from employees and leadership alike.

The company provides clear information to all employees on the mechanisms available for anonymously reporting non-compliance with these policies. This is supplemented by regular anti-corruption training on key regulatory requirements for new and existing employees.

Anti-corruption clauses are included in contractual agreements with third parties and all suppliers are required to assure compliance with anti-corruption law under our Supplier Code of Conduct. To reinforce these measures, Planet monitors extended suppliers and third parties for corruption risks on
an ongoing basis.