Quality policy

At CT, we provide innovative and technological solutions that make our customers more effective and competitive. In doing so, we aim to deliver a consistent, and high quality standard of service.

Our Quality Management System is the key to maintaining, and bettering our standard of service. Improvement comes from a constant review of our day-to-day activities. This is why everyone in the organization is an important part of Quality at CT, and why suppliers are encouraged to contribute too. We aim not just to meet, but also to surpass ISO 9001, and EN 9100 requirements.

​The following management principles and behaviors guide our Quality Policy:

• Achieve quality, and cost objectives within established timelines in projects.
• Build win-win relationships with customers and suppliers.
• Cultivate a motivating company environment that makes employees happy, and helps them work at their best.
• Actively manage risks, and proactively identify and adopt best preventive practices.
• Pursue continual improvement, and foster innovation.
• Provide trainings designed to develop employee capabilities, and encourage creativity, accountability and engagement.
• Maintain a clear and comprehensive understanding of customer, legal, and regulatory requirements.
• Observe and fulfill the product safety requirements set by our customers, legislation and regulations.
  

The market expects a continually improving service. At CT, we drive consistently to deliver a product that exceeds our customers´ expectations, and our own.

Our Quality Management System outlines the policies, organization, procedures, and management committees tasked with achieving our target quality standards.

Our Head of Quality is responsible for monitoring all quality systems, and reports on their deployment, status and performance to the General Manager periodically. The Quality & Operations committee defines Overall Company Quality objectives, which are monitored by the management board.

As the highest Quality representative for The CT Engineering Group, CT authorizes Julien Brunet as our Head of Quality, to ensure the achievement of our quality objectives.

Environment policy

The CT Engineering Group, dedicated to engineering projects, prioritizes quality and environmental responsibility as essential for its service provision. We commit to environmental protection and aim to exceed customer expectations while minimizing environmental impact. This strategy enhances our market position and distinguishes us from competitors. We believe sustainability and environmental responsibility are fundamental requirements that influence our operations. Recognizing our impact on greenhouse gas emissions, we’re committed to reducing our carbon footprint and addressing climate change through the following principles.

Applicability: This policy applies to all sites within the CT Engineering Group. Every site is expected to follow the guidelines and principles outlined in this policy.

Our environmental policy outlines our objectives and commitments in the areas of energy consumption, greenhouse gas reduction, waste management and recycling, and the promotion of sustainable consumption through environmental consulting services to help our customers design and promote their eco-friendly products:

Energy Consumption: the objective is to minimize the environmental impact by increasing the use of renewable energy sources, both through higher consumption and on-site generation, while also transitioning the vehicle fleet to zero-emissions vehicles, thus reducing energy consumption and contributing to environmental sustainability.
Targets:
1. Our main target is to increase our consumption of renewable electricity by 80% by 2025 and 100% by 2030.
2. To further our commitment to renewable energy, we aim to boost our renewable electricity generation by 10% by 2025 and by 15% by 2030.
3. By 2030, we plan to electrify 40% of our vehicle fleet and reach 100% zero-emission vehicles by 2040.

Greenhouse Gas Emissions Reduction: The objective is to develop and implement plans to reduce greenhouse gas emissions, including setting challenging reduction targets, and tracking progress regularly. Additionally, the goal is to prioritize the use of renewable energy sources, energy-efficient technologies, and sustainable transportation options, while also collaborating with suppliers and clients to reduce the indirect environmental impact of operations.

We are proud to be engaged in the Science Based Targets initiative (SBTi), which provides companies with a clear pathway to set science-based emissions reduction targets that are in line with the goals of the Paris Agreement. At CT, we have set science-based targets to reduce our greenhouse gas emissions in line with the latest climate science. We will regularly report our progress towards meeting these targets through the Climate Disclosure Program (CDP), a global platform for companies to report their environmental impacts and progress towards sustainability goals.
Targets:
1. The short-term objective is to reduce absolute scope 1, 2 and 3 GHG emissions 42% by 2030 from a 2022 base year.
2. The long-term objective is to reduce absolute scope 1, 2 and 3 GHG emissions 90% by 2050 from a 2022 base year (Net-Zero).

Waste Management and Recycling: The objective is to minimize pollution by reducing waste generated during our activities through the promotion of reuse and recycling whenever feasible, and optimize the efficient use of raw materials and energy.
Targets:
1. The aim is to purchase 95% recycled paper for all uses by 2025.
2. By 2030, the aim is to put in place an effective and sustainable waste sorting system at all company sites to optimise resource recovery, which includes recycling, the correct disposal of the various waste streams.

Environmental consulting services: Providing efficient engineering solutions tailored to the needs of our customers and stakeholders, using environmentally friendly and economically viable technologies, taking into account both the internal and external context of the organization.
Targets:
1. Our goal is to grow our portfolio of “green” technologies in the upcoming years. When we mention “green,” it is in line with the criteria set out in the EU Sustainable Finance Taxonomy. In the near term, we aim to raise the portion of our revenue derived from green projects, which align with the six environmental objectives outlined in the EU Taxonomy regulations, including Climate Change Mitigation, Climate Change Adaptation, Pollution Prevention and Control. This increase should reach 20% by 2025.
2. The long-term objective is to reach 80% of our revenue derived from green projects by 2040.

Education and awareness: Promoting training and awareness to raise awareness and responsibility among all personnel regarding environmental protection.
Targets:
1. Starting in 2025, it is mandatory for 95% of newly onboarded CT employees to receive training regarding the environmental policy and its impact on their day-to-day work

Adaptation: We will assess and manage the risks posed by environmental protection and climate change to our operations, assets, and supply chain. We will develop and implement strategies to adapt to the physical and economic impacts of climate change, including extreme weather events, changes in precipitation patterns, and shifts in market demand, ensuring the long term resilience of our business.

Applicable laws and regulations: This policy will be implemented with a commitment to adhere to the specific local environmental laws and regulations at each site within the group.

Environmental system based on ISO 14001: The CT Engineering group implements an environmental management system based on the UNE-EN-ISO 14001 standard in our headquarters, which facilitates well-done work and continuous improvement of the service in an environmentally respectful manner. The scope of this certification is “Engineering Services for Product Innovation, Development and life cycle Support”.

Accountabilities: The annual Environmental Committee, composed of the Country Managers and the Environmental Manager, is accountable for the company’s environmental policy, ensuring its adherence and continuous improvement. Simultaneously, the Environmental Manager takes on the daily responsibilities of animating the environmental system, overseeing compliance, monitoring and reporting, and engaging stakeholders in the company’s environmental efforts, while staying updated on relevant regulations. This dual approach ensures a holistic and effective approach to environmental sustainability within the organization.

Review mechanism: This policy is reviewed annually in October to assess its effectiveness and relevance, taking into account changes in regulations and best practices. Any necessary updates are made to ensure it remains aligned with our commitment to environmental sustainability.

At the CT Engineering Group, we believe that environmental stewardship is essential for the well-being of our planet and future generations. We are dedicated to upholding this policy to the highest standards and continuously improving our environmental performance.

This policy is communicated to all our internal stakeholders and is published on our intranet and website.

October the 16th, 2023

Health & Safety Policy

The CT Engineering Group, dedicated to engineering projects, recognizes the paramount importance of the health and safety of our employees, contractors, visitors, and the communities in which we operate. We are committed to providing a safe and healthy work environment and promoting a culture of safety throughout our organization. This commitment ensures the well being of our people, enhances our reputation, and fosters a productive and thriving workplace.

Applicability: This policy applies to all sites and activities within the CT Engineering Group.
Every site is expected to adhere to the guidelines and principles outlined in this policy.

Our Health & Safety Policy outlines our objectives and commitments in the following key areas:

• Incidents and Accidents Reduction: We are dedicated to proactively managing and reducing workplace incidents and accidents to ensure the safety and well-being of our employees.
  Targets:
  1.  Reduction of 30% in occupational safety incident rate by 2030.
  2.  From 2024, the aim is to have NO work-related accidents with leave.
• Hazard Identification and Risk Management: We are dedicated to identifying workplace hazards, assessing risks, and implementing appropriate control measures to eliminate or minimize potential harm.
  Targets:
  1.  More than 90% of the CT employees must be covered by a health & safety risk assessment.
• Incident Reporting and Investigation: We prioritize the reporting and investigation of all occupational incidents to prevent reoccurrence and continuously improve safety.
  Targets:
  1.  Communicate the incident and accident reporting process at least once a year.
• Emergency Preparedness: We are dedicated to being prepared for emergencies and ensuring the safety and well-being of our employees during unforeseen events.
• Education and awareness: Promoting training and awareness to raise awareness and responsibility among all personnel regarding safe work practices.
  Targets:
  1.  Starting in 2025, it is mandatory for 95% of newly onboarded CT employees to receive training regarding the health & safety policy and its impact on their day-to-day work

Applicable laws and regulations: This policy will be implemented with a commitment to adhere to the specific local health and safety laws and regulations at each site within the group

Health & Safety system based on ISO 45001: The CT Engineering group implements a health & safety management system based on the UNE-EN-ISO 45001 standard in relevant sites, ensuring the well-being of our employees and the safety of our work environment. The scope of this certification is “Engineering Services for Product Innovation, Development and life cycle Support”.

Accountabilities: The annual Health and Safety Committee, composed of the General Manager, the Country Managers, the COO and the Health and Safety Manager, is responsible for overseeing the company’s health and safety policy, ensuring its adherence, and promoting continuous improvement. The Health and Safety Manager will oversee the daily responsibilities of maintaining a safe work environment, compliance, and engagement of all stakeholders in our health and safety efforts.

Review mechanism: This policy is reviewed annually in October to assess its effectiveness and relevance, taking into account changes in regulations and best practices. Any necessary updates are made to ensure it remains aligned with our commitment to health and safety.

At the CT Engineering Group, we believe that the health and safety of our people is a fundamental priority. We are committed to upholding this policy to the highest standards and continuously improving our health and safety performance.

This policy is communicated to all our internal stakeholders and is published on our intranet and website.

October the 19th, 2023

Labor & Human Rights Policy

The CT Engineering Group, dedicated to engineering projects, is committed to upholding labor and human rights as fundamental principles within its operations. We recognize the importance of ensuring fair and ethical treatment of our employees, fostering diversity, equity, and inclusion,
and eradicating child and forced labor.

Applicability: This policy applies to all sites within the CT Engineering Group. Every site is expected to adhere to the guidelines and principles outlined in this policy.

This policy outlines our objectives and commitments in key areas related to labor and human rights:

Diversity, Discrimination & Harassment: The CT Engineering Group is committed to creating a diverse, equitable, and inclusive workplace and to the principle that every individual should have access to equal treatment and opportunities, irrespective of personal characteristics unrelated to their skills, performance, or qualifications. CT prohibits any form of discrimination, harassment, or intimidation based on factors such as age, origin, skin color, disability or impairment, nationality, race, religion, gender, sexual orientation or preference, gender identity, appearance, political affiliations, marital status, or any other characteristic protected by law. CT expects its employees, in all circumstances and locations, to maintain an environment free from discrimination, harassment, intimidation, or retaliation. CT is a politically neutral space: we
deeply respect the political freedom of thought of all individuals working within the company, and therefore, we refrain from expressing political comments or opinions on internal forums and
communication networks.
Targets:
1. The goal is to reach 50% of employees trained on discrimination and harassment
by 2030.

Child and Forced Labor: The CT Engineering Group unequivocally condemns child and forced
labor, as well as human trafficking.
Targets:
1. To maintain a zero-tolerance policy towards child labor and forced labor, as well as
human trafficking, ensuring compliance with international labor standards.
2. To establish an agreement with our suppliers and partners to enforce this zero tolerance policy. The objective is to ensure that 100% of our engineering suppliers have the relevant clause approved within our supplier framework contract by 2026.

Whistleblowing channel Reporting and Investigation: The CT Engineering group undertakes to investigate and settle any report received through the Compliance Officer. We ensure the confidentiality of the information contained in the report and expressly prohibit any form of retaliation against the whistleblower.
Targets:
1. The Compliance Officer must inform the whistleblower of receipt of the report within
a maximum of 3 working days.

Working Conditions: The CT Engineering Group is dedicated to providing fair and conducive working conditions to its employees. At CT we understand flexible working hours as a
mechanism of mutual benefit: company-employee. Flexibility allows the employee to better reconcile and attend to personal commitments. For the company, it is a way to better adapt to the needs of its clients and improve its performance, while at the same time contributing to creating a better working environment. Part of the employee voice is giving people the opportunity to express their concerns or ideas for potential improvement. At CT, there are multiple processes to fuel continuous improvement: lessons learned, audits, innovation
proposals… but sometimes these feedback don’t fit into any of CT’s processes. A dedicated
process is therefore available for employees to propose any type of concern and feedback
related to working conditions.
Targets:
1. A working environment survey is sent every year. The objective, included in the incentives of the managers, is to reach 90% in the last question of the survey: “I definitely recommend to work in The CT Engineering Group to a friend of mine?”

Social Dialogue: We are committed to cultivating organised and constructive interactions with employee representatives and trade unions, with the aim of facilitating fair and cooperative decision-making. We actively seek to engage with and show consideration for employee
representatives, and are committed to supporting the creation of trade unions where employees
express a desire to do so, in compliance with applicable labour regulations. All employees have
the right to join trade unions, works councils or other collective bargaining groups.
Targets:
1. From 2023, the aim is to reach 90% of employees covered by formally-elected
employee representatives (work councils).

Career Management & Training: At CT, we’re committed to helping our employees build their careers and continuously improve. We make sure everyone knows their job, responsibilities,
and what’s expected of them. As you progress, your technical career advances through Personal
Skill List (PSL) and the opportunity to take on different roles, all evaluated annually. We don’t tie your salary to preset criteria but to your contributions and the depth of your role development, while encouraging professional growth without requiring a move into management. We provide opportunities for internal mobility, allowing you to explore new roles and challenges within the company. Our aim is to support your career development and provide fair and equitable compensation, emphasizing learning and growth. The Annual Evaluation Interview (AEI) is the cornerstone of this policy: the AEI primary goals are to provide performance feedback, identify training needs, create a clear training plan with specific goals and assess technical contributions.
Targets:
1. From 2023, 90% of employees who meet specific criteria (those with more than one
year’s seniority in CT and who remain employed) must complete an AEI.

Education and awareness: Promoting training to raise awareness and responsibility among all personnel regarding labor and human rights practices.
Targets:
1. Starting in 2025, it is mandatory for 95% of newly onboarded CT employees to receive training regarding the labor & human rights policy and its impact on their day-to-day work.

Applicable laws and regulations: This policy will be implemented with a commitment to adhere to the specific local labor & human rights laws and regulations at each site within the group.

Accountabilities: The annual Labor & Human Rights Committee, composed of the General
Manager, the COO and the Head of People & Culture, is responsible for overseeing the
company’s labor & human rights policy, ensuring its adherence, and promoting continuous
improvement. The Head of People & Culture will oversee the daily responsibilities of maintaining
a work environment that upholds labor and human rights, ensures compliance, and fosters
engagement of all stakeholders in our efforts to protect and promote these rights.

Review mechanism: This policy is reviewed annually in October to assess its effectiveness and
relevance, taking into account changes in laws and best practices. Any necessary updates are
made to ensure it remains aligned with our commitment to labor and human rights.

At The CT Engineering Group, we believe that respecting and upholding labor and human rights
is essential for the well-being of our employees and the sustainable growth of our organization.
We are dedicated to adhering to this policy to the highest standards and continuously improving
our practices.

This policy is communicated to all our internal stakeholders and is published on our intranet and
website.

November the 11th, 2023

Information Security Policy

The CT Engineering Group (hereinafter CT) is continuously managing, exchanging and processing internal and external information of its customers and suppliers.

Keeping in mind the values of the Company:

• Establish a horizontal organization focused on the Customer.
• Simplify the processes to the maximum by increasing the training and versatility of the staff. In those cases in which the complexity of the task or process does not allow the complete assignment to a single person, it will be entrusted to a team composed of specialists in different subjects.
• Plan the provision of the services provided properly, so that unforeseen events are eliminated as much as possible. To get this, we use IT tools that support the main service processes. The specific objectives of the strategies in matters of Information Security are materialized and reviewed in the Security Committees that are held periodically.
• Implement all the necessary measures to comply with the applicable regulations, laws and customer requirements in terms of Information Security with the support of an Information Security Management System (ISMS) where rules, procedures and controls that ensure confidentiality (data managed by CT are accessible by authorized users only), integrity (data being accessed or read has neither been tampered with, nor been altered or damaged through a system error) and availability (data accessible when needed, ability to respond to emergency situations restoring the operation of critical services in the shortest time possible) of information are defined, and promote awareness and training in information security.
  The objective of this policy is to establish and communicate the principles, guidelines and basic rules to protect information and information systems against a variety of threats that may negatively impact our activities and the future of CT, following the principles of continuous improvement inherent to any management system.

All policies, procedures and technical instructions are internally published in CT Insider (Intranet), there is a dedicated blog and any user can access to “Regulation of use and behavior regarding Information Systems” document (easy-to-understand guidelines and policies for end users).

It is important for everyone to understand that the security of information is OUR RESPONSIBILITY, and that all of us are involved in its achievement.

We have all the staff and their professional sense to help in the protection of projects information, information technologies, communications and especially the data of CT, to ensure the continuity and quality of our services.

As the highest representative of the company’s ISMS, I empower David Uriarte as Head of the ISMS to ensure the achievement of the objectives set.