Introduction

The Transparency Act is a law passed by the Storting, which entered into force on 1 July 2022. The Act is intended to promote companies' respect for fundamental human rights and decent working conditions, and to ensure public access to information. Pursuant to the Transparency Act, Act 2021-06-18-99, Section 5, ANTIMA GROUP is obliged to publish an annual report on the due diligence assessments the company has carried out pursuant to Section 4 of the Act. The period covered in the following statement is the financial year from 1 January 2023 to 31 December 2023.

Statement pursuant to the Transparency Act

Organization and Operational Areas

ANTIMA GROUP has existed since 2015, primarily working with residential property, and has recently initiated commercial property activities, in addition to buying and selling. The head office is located in Marbella, Málaga. Today, the ANTIMA GROUP consists of 13 companies with more than 30 luxury homes sold and a high-value commercial asset in a prime location ready for opening. All companies associated with the ANTIMA GROUP are covered by this report, regardless of whether they are individually obliged by law or not.

We have our main focus in Marbella, despite having developed interior projects in other areas of Spain and abroad.

Our business can mainly be divided into the following categories:

Property Development:

• Purchase of property according to the in-house procedures, renovation, and sale.
• Main stakeholders include builders, banks, suppliers of materials, landscaping companies, local authorities, lawyers, and real estate brokers.

Interior Design and Production of Furniture:

• Interior design and styling services are performed from ANTIMA GROUP for the villas developed within the group as well as in other projects for external clients.
• This business offers furniture through online and offline means, boosting the brand's strength and making the ANTIMA GROUP product recognizable for potential buyers.

Maintenance:

• Business dedicated to maintaining the value of properties developed by ANTIMA GROUP and other villas of external clients.
• Services include cleaning, general technical and mechanical maintenance, pool and landscape maintenance, and furniture substitution and cleaning when necessary.

Management and Administration of the Group and Projects:

• Typical suppliers include IT local companies, marketing-related agencies or partners, counseling partners for specific areas of the project, system suppliers of accounting and financial systems, and suppliers of office supplies.

Operation of the Commercial Center:

• Management of the operations of this asset and maintenance for the correct running of this center, whose renovation has been performed by ANTIMA GROUP.

Our Approach to Due Diligence

As a company, we have a responsibility to ensure that we are not involved in incidents that negatively affect people, society, and the environment. Our responsibility and commitment to respect human rights require us to conduct and incorporate due diligence in our operations, and to encourage the same from the suppliers and stakeholders. Based on the national and international guidelines for Responsible Business Conduct, and our internal Code of Conduct, we consider our responsibility to be inspired by the following:

• The activities of ANTIMA GROUP create value for the area, considering the area as its land and population.
• ANTIMA GROUP contributes to a healthy work environment within the companies of the group to encourage practices that are in line with the code of conduct.
• Efforts to have a strong relationship with the authorities, in favor of more balanced and fair rules, regulations, and protocols to ensure smooth operational practice.
• Early detection of practices in and around the group that can potentially create a negative impact.
• Taking the necessary distance from negative influences through other partners and entities.
• ANTIMA GROUP strives as far as possible not to contribute to any form of negative influences, neither by causing, contributing, or being directly connected.

The due diligence process is carried out in accordance with our own Business Partner Check, which, among other categories, analyzes the administrative strength, integrity, and capability to comply with regulations of each supplier.

Our business relationships are many. It is difficult to trace the operational performance of each and every subcontractor, but we make sure to have strong contracts that address the main guidelines to follow for contractors that subcontract at the same time. This way, we set the framework in which the group works so that the rest of the line has the opportunity to follow.

Our due diligence work is risk-based, and we focus on integrating the work into relevant processes and business activities. We therefore carry out analysis where we prioritize our risk areas according to how likely it is that the negative impact will occur and the severity of that impact.

To assess risks related to our environment and action area, we use, among other things, national tools such as the National Institute of Statistics, official and approved valuation entities, and specific tools such as reports drafted and issued by trusted local and national partners. For example:

• Annual Real Estate reports
• Annual Wealth reports
• Reports from different banks
• Reports issued by important national and international law firms such as PwC

To assess risk in different parts of the supply chain, we use national regulations related specifically to construction and the recommendations issued by the local authorities and associations set up in the different urbanizations where the group operates, which are a thermometer that ensures smooth and correct development of the activity.

Evaluation of risk and due diligence are both very high on the internal agenda of the organization, with a particular focus on the company areas that are closest to the areas we consider to be of elevated.

Our Account of Due Diligence

In the framework of the high level of the Group’s transactions throughout the year, our main suppliers are contractors related to construction, which at the same time subcontractors such as electrical, plumbing and other installations, fire consultants, as well as insurance or waste management.

Despite the fact that the total supplier base is huge, a high percentage of our purchases are made from less than 10 trusted suppliers with whom we have established good, long-term agreements. We have agreements with all of our trusted suppliers for each of the projects, which helps us ensure a solid collaboration over time and increases our capacity to set our preferred procedures to operate.

Our suppliers and business partners are mainly well-established, Spanish companies that are subject to the same laws and regulations as the group and thus have a lower inherent risk than if we were to purchase large volumes of goods and services from foreign players. In some isolated cases, some materials can be purchased abroad from internationally renowned brands, although this is not the regular habit.

Assessment of Risk Internally in ANTIMA GROUP

ANTIMA GROUP currently has 36 employees in Spain, the majority of whom are located at the company's headquarters in Marbella. We are constantly working on internal focus areas to improve our employees' working conditions and well-being:

• We are proud of our working environment, characterized by a strong commitment to diversity, including employees of different origins and nationalities. The group is committed to a remuneration system based on merits and ensures no discrimination based on gender, race, beliefs, or any other circumstance.
• We have a good and safe working environment that promotes well-being in the workplace. Our organization relies on partners such as Labour Risk Prevention to make sure that the workplace complies with the safest measures for employees to develop their tasks.
• We focus on promoting the physical and mental health of our employees. We offer our employees the opportunity to participate in Pilates classes and receive muscular relief sessions at different moments throughout the year.
• Outside of our core operations, we count on external professionals that advise us on certain matters to expand our knowledge and broaden our limits for growth.
• We are proud of not having experienced any serious injuries or accidents since the conception of the ANTIMA GROUP. Our protocols on-site, which is the area of more risk in our daily operations, are strong enough to keep our employees safe at all times.

Assessment of Country Risk

Antima Group’s operations are mainly connected to the Spanish market, more specifically to Costa del Sol. The countries we have minimal activity in are Belgium, the Netherlands, Sweden, Denmark, and Finland. The Real Estate market in Marbella has shown along the activity of the ANTIMA GROUP to be a healthy and fruitful area to develop activities, in which the authorities have a great commitment to security, high standards of maintenance in the city, and local and foreign investment. Spain and Costa del Sol are considered areas with a low risk when it comes to political and financial stability or environmental risk. Fortunately, Spain is a healthy and growing area to develop our activity, with a strong capacity to attract wealth and well-being.

Based on an overall assessment of our associated risk, we consider our activity in Marbella to be very safe when it comes to potential instability of the country or the continent as this area has shown a high resistance to the uncertainty of other locations in the country and out of it.

Assessment of Risk in the Construction Site

Given that our processes involve different subcontractors on the construction sites, a Health and Safety coordinator is appointed in every project to make sure that no violations of the regulation regarding labor are allowed on the construction site. The coordinator for Health and Safety is entitled to request all the necessary documentation to avoid non-compliance, risky, or inadequate practices on the site, as well as to dismiss from the site any team of workers that does not comply with the regulations, or whose practices are not in line with the required conduct, whatever the motivation is. This is applicable to all agents that participate in each of the projects: carpenters, painters, tile setters, masons, workers dedicated to electricity, plumbing, cleaning, or any other involved.

When it comes to the main contractor, a full Due Diligence is conducted prior to the signing of the contract. As stated before, the signed contract contains the main regulations to follow and the main requested documents to be able to start the works.

Assessment of Risk in the Services Offered

Although the main focus of the risk assessment is placed on suppliers and business partners, the capacity of the ANTIMA GROUP to influence people and the environment through the activities and customer’s attitude is not to be underrated. This is something we at ANTIMA GROUP very much recognize and which is part of our risk reduction work. The majority of our clients and tenants are established Marbella with Spanish companies that are subject to the same laws and regulations that we, as a company, are subject to.

To ensure that our customers and tenants uphold requirements for human rights, we offer them the Maintenance services to avoid illegal employment practices in vulnerable industries such as cleaning or gardening. Our business model is characterized by having a close dialogue with our customers so that we can easily identify risks and suspicions of any potentially damaging practices, which also affect our reputation as trusted developers in the area. Our construction managers have good control over renovations in the commercial premises in our commercial assets, as well as other decoration works parallel to our operations in private villas, to avoid any non-compliance under our watch. They maintain ongoing dialogues with our tenants, including through physical visits to the locations.

Identified Challenges and Violations

We have not registered any actual adverse impacts or harms on fundamental human rights and decent working conditions. At ANTIMA GROUP, there is a serious commitment to the protection of the workforce and the land that allows its operations.

Status, Measures, and the Way Forward

The work with due diligence assessments and the work that is conducted for the detection of risks and observation of the regulations is performed daily and is at the core of ANTIMA GROUP values. We place high demands on all our affiliated suppliers and business partners. We consider ourselves to be implementing the right measures to not only comply but excel when it comes to the protection of Human Rights, Sustainable Development Goals, and other international guidelines.

Implemented Measures:

• Creation of a Code of Conduct document with a description of habits, protocols, routines, and processes for how ANTIMA GROUP works with due diligence assessments and anchored this in the organization.
• Creation of the Due Diligence Protocols before signing contracts with contractors.
• Application of clauses in contracts that oblige contractors to comply with the regulations of the field in which they operate.
• Appointment of the Health and Safety coordinator for each project to control onsite that the contractor follows the correct practices.
• Appointment of the Labor Risk Prevention coordinator for the offices to prevent accidents and ensure an ergonomic and healthy workplace for the employees of the group.
• Creation of the ANTIMA FOUNDATION to give back to the area and the environment we work in.

Initiatives for Implementation:

• Formal Internal whistleblowing channel or appointment of an “Ombudsman” to reinforce Human Resources action.
• Creation of a stronger after-sales department to manage potential complaints and avoid reputational damage.
• Review and update of the ANTIMA GROUP internal principles and guidelines for business ethics, social responsibility, the environment, human rights, and sustainability in the internal Code of Conduct to adapt to the different realities and circumstances that surround the business.
• Development of a formal written Business Partner Check for the suppliers to fill in and sign themselves in order to formalize the process on a higher level.

With the measures we have implemented, as well as those that will be implemented in the coming periods, we have more robust routines for identifying, assessing, and managing risks associated with our Group. We expect this to help reduce risk, as well as increase the chance that we will uncover any breaches and negative impacts.

Responsibility for the implementation of measures and ongoing work on due diligence lies with responsible resources in operations and administration. Compliance with the Transparency Act within the group has been a priority for all the companies that integrate the group from the beginning of the operations and is infiltered in all departments at all levels, making each one of the employees aware and vigilant in this sense.

If actual violations of human rights or decent working conditions are discovered, we undertake to deal with this in accordance with the requirements of the Transparency Act.

Information Requirements

Where the public has a right to information from a company about how they handle actual and potential negative consequences pursuant to Section 4 of the Transparency Act, ANTIMA GROUP has a duty to provide information to respond to requests.

In 2023, ANTIMA GROUP did not receive any information requirements related to the Transparency Act.