Version: September 2025

Policy Statement

At Cielo, our purpose is to illuminate talent, wherever it’s found, and our Responsible Business Strategy is core to achieving this. This Sustainable Procurement Policy is a direct extension of that strategy, formalizing our commitment to making a positive impact through our purchasing decisions. We are dedicated to integrating environmental, social, and economic factors into our procurement processes to ensure they protect the environment, uphold human rights, good governance and create an ethical marketplace. This policy serves as a guide for our employees and a statement of our expectations for our suppliers, ensuring that together, we build a more just and sustainable future for all.

Scope

This policy applies to all who work for and with Cielo, including employees, contractors, and all third-party suppliers, vendors, and business partners involved in providing goods or services to or on behalf of Cielo. We expect everyone to share our commitment and adhere to the principles outlined herein.

Core Sustainable Procurement Principles

Our procurement decisions will be guided by our core Responsible Business pillars. We will prioritize suppliers who demonstrate a clear commitment to these principles.

a. Climate Action and Environmental Stewardship

We are committed to protecting our planet and minimizing our environmental impact. We will actively work towards our carbon reduction ambitions by:

• Prioritizing suppliers who are measuring, managing, and reducing their own carbon footprint and other harmful emissions
• Utilizing carbon accounting such as (SBTi) methodology to measure and manage our own operational emissions and, critically, our supply chain (Scope 3) SBTi carbon emissions.
• Promoting a circular economy by reducing consumption, prioritizing recycled and renewable materials, and minimizing waste.
• Considering the total lifecycle impact of products and services, from creation to responsible end-of-life disposal.
• Conserving vital resources, including energy and water.

b. Thriving People and Upholding Human Rights

We believe that respecting and promoting human rights is a fundamental responsibility. We are committed to fostering safe, inclusive, and equitable environments. In our procurement practices, we will:

• Strictly prohibit human trafficking, forced, bonded, indentured, or child labor within our operations and supply chain.
• Partner with suppliers who guarantee safe and healthy working conditions and provide, at a minimum, a living wage compliant with local applicable laws.
• Promote a harassment-free workplace and prohibit all forms of unlawful discrimination.
• Uphold the principles of the International Labour Organization and the UN Universal Declaration of Human Rights.

c. Ethical Marketplace and Governance

We are committed to maintaining a culture of absolute integrity. We have a zero-tolerance policy for bribery and corruption and expect our suppliers to demonstrate the highest ethical standards. This includes:

• Complying with all applicable international and domestic laws regarding ethical business practices.
• Maintaining robust procedures to prevent bribery, corruption, fraud, and money laundering.
• Actively managing and transparently disclosing any actual or potential conflicts of interest.
• Competing fairly and honestly in compliance with all antitrust and competition laws.
• Safeguarding all personal and confidential data in accordance with applicable data privacy laws and policies.

d. Supplier Community Impact

We recognize that our differences make us stronger and are committed to building strong connections within our communities. We commit to encouraging our suppliers to invest in the social, economic, and educational well-being of the communities in which they operate.

e. Transparency and Accountability

• Maintain openness in procurement decisions and avoid conflicts of interest.
• Apply consistent criteria and document procurement decisions for auditability.