Policies

Vision Statement:

Powered by decades of industrial leadership, to pioneer institutional real estate investments that build resilient communities and deliver enduring prosperity for our stakeholders.

Mission Statement:

To architect premier, full-lifecycle real estate investment solutions by channelling the engineering depth, manufacturing mastery, and developmental legacy of our founding industrial houses delivering unmatched competitive advantages and enduring value for our clients and investors.

Code of Conduct

IMM REIT MANAGEMENT COMPANY LIMITED
CODE OF ETHICS & PROFESSIONAL BUSINESS CONDUCT
Corporate Governance & Regulatory Compliance Framework
MANDATORY COMPLIANCE DIRECTIVE: This Code of Ethics and Professional Business Conduct establishes the fundamental principles, fiduciary standards, and corporate governance obligations governing all employees, management, and Directors of IMM REIT Management Company Limited (IMM RMC). Compliance with this framework is mandatory across all operations and managed REIT schemes.

1. INTRODUCTION & STATEMENT OF COMMITMENT
IMM REIT Management Company Limited ('IMM RMC' or the 'Company') is dedicated to maintaining the highest benchmarks of fiduciary responsibility, professional integrity, transparency, and corporate governance in managing Real Estate Investment Trust (REIT) schemes. This Code sets forth the non-negotiable standards of personal and professional conduct required of all personnel.

1.1 Fundamental Principles of Professional Conduct
Unless specifically restricted or qualified, the objectives, obligations, and professional tenets outlined herein apply uniformly to all personnel, irrespective of rank or operational mandate. Professionals serving IMM RMC are expected to demonstrate:
 a) Technical Competence: Specialized technical competence, rigorous analytical acumen, and market expertise gained through continuous learning, certifications, and professional training.
 b) Fiduciary Duty & Public Stewardship: Unconditional recognition of a dual duty of care acting in the highest interest of the Company, unitholders, and investors, while safeguarding broader public confidence and societal welfare in the capital markets.
 c) Objectivity and Independence: Maintaining complete impartiality, professional scepticism, and analytical detachment, ensuring that investment judgments and valuations are free from bias, personal interest, or external pressure.
d) High-Performance Benchmarks: Delivering world-class real estate asset management, property diligence, advisory, and execution services in strict adherence to industry best practices and global benchmarks.
The technical expertise and specialized training embedded within IMM RMC constitute core institutional assets. Supervisory and senior managerial personnel bear an active obligation to foster skill transfer, impart regulatory knowledge, and mentor sub-ordinates within an ethical corporate environment.

1.2 Core Professional Standard and Conservative Interpretation
All associated persons must observe internationally recognized canons of professional practice, prevailing capital market ethics, and applicable statutory laws. Where ambiguity arises regarding the meaning, boundary, or application of any regulation, directive, internal rule, or statutory provision, personnel are strictly mandated to adopt the most conservative and risk-averse interpretation.

2. INSTITUTIONAL CODE FOR IMM REIT MANAGEMENT COMPANY LIMITED
IMM RMC conducts its business affairs with uncompromised integrity, market discipline, and accountability toward unitholders, regulatory bodies, and business partners. The Company binds itself to the following institutional mandates:

2.1 Fair Representation and Transparent Investor Engagement
The Company shall always formulate, implement, and maintain promotional, marketing, and investor disclosure policies that are scrupulously accurate and fair. Specifically, IMM RMC strictly prohibits:
* Issuing exaggerated, speculative, or unverified claims concerning fund returns, net asset values (NAV), rental yields, occupancy rates, or past management track record.
* Misrepresenting institutional capabilities, technical infrastructure, or historical achievements in managing REIT schemes, assets, or third-party real estate advisory portfolios.
* Employing high-pressure sales tactics, misleading financial projections, or unethical solicitations to induce investors or institutions to acquire units of any existing or forthcoming REIT scheme managed by the Company.

2.2 Corporate Social Responsibility and Community Development
IMM RMC recognizes its civic duty to cultivate sustainable communities and generate positive socio-economic impacts. The Company, along with the REIT schemes under its management, actively supports environmental, social, and governance (ESG) initiatives and social development programs through designated budgetary allocations. Personnel are encouraged to propose impactful, verifiable community causes for institutional sponsorship.

2.3 Equal Opportunity Employer Framework
IMM RMC operates strictly as an Equal Opportunity Employer. The Company categorically rejects all forms of unlawful discrimination or bias based upon gender, race, religious conviction, ethnicity, age, or physical disability. All decisions pertaining to recruitment, compensation, role assignment, talent development, and executive promotion are governed solely on merit, professional qualification, demonstrable competence, and organizational suitability.

3. CODE OF CONDUCT FOR EMPLOYEES AND DIRECTORS
Every staff member, executive, and member of the Board of Directors of IMM RMC is required to uphold the integrity and operational resilience of the organization. The following behavioural standards and proscriptions are strictly enforceable:
a) Operational & Reputational Integrity: Personnel must continuously appreciate the direct connection between daily decisions and the Company's operational and reputational exposure, always conducting themselves with impeccable integrity and personal accountability.
b) Prohibition of Self-Dealing: Personnel are strictly prohibited from engaging in self-dealing, nepotism, or personal enrichment defined as exploiting one's position, authority, or proprietary insight to enter transactions with the Company or managed REIT funds that yield personal or related-party benefits at the expense of IMM RMC or unitholders.
c) Capital Market Abuses & Market Manipulation: In connection with any publicly listed or privately placed REIT units, debt instruments, or related securities managed by or associated with IMM RMC, employees and directors are unconditionally forbidden from:
i.    Participating in or facilitating transactions designed to create a false or misleading appearance of active trading or artificial liquidity (wash trading/matched orders).
ii.    Engaging in price rigging, benchmark distorting, marking the close, or manipulative quoting practices.
iii.    Leaking, discussing, or transmitting material non-public, price-sensitive information (MNPI) to brokers, market participants, financial analysts, or unauthorized third parties.
iv.    Executing or facilitating insider trading or tipping, whether for personal accounts or beneficial third parties.
d) Prevention of Tax Evasion: Personnel must not formulate, facilitate, or execute transactions involving tax evasion, abusive tax sheltering, or non-compliance with statutory fiscal obligations, whether for corporate accounts or personal finances.
e) Statutory and Regulatory Compliance: Employees are duty-bound to prevent any deliberate act or omission that would breach statutory enactments, SECP REIT Regulations, NBFC rules, the Companies Act, or the Trust Deeds and Offering Documents of managed REIT funds.
f) Proprietary Confidentiality: All institutional data, internal manuals, proprietary valuation algorithms, financial models, pipeline deal structures, tenant lease registries, IT systems, and human capital records are strictly proprietary and confidential. Disclosure is prohibited without formal corporate authorization.
g) Investor & Beneficiary Data Privacy: Information concerning unitholders, high-net-worth investors, institutional partners, and trust beneficiaries must be guarded with the utmost discretion. Client details may only be shared where:
i.    Prior explicit written authorization has been obtained from the unitholder/investor;
ii.    Disclosure is strictly required under valid court order, regulatory subpoena, or statutory mandate; or
iii.    Disclosure is immediately imperative to defend the assets of the Company or REIT funds against criminal conduct, misappropriation, or substantiated fraud.
h) Conflict of Interest & External Appointments: Full-time employees are prohibited from engaging in external commercial engagements, freelance advisory, or commercial gain outside IMM RMC. Purely charitable, educational, or civic activities are permissible only provided they do not generate actual or perceived conflicts of interest and have received prior written approval.
i) Zero-Tolerance on Bribery & Corruption: Offering, soliciting, facilitating, or accepting any kickback, bribe, secret commission, illegal gratification, or corrupt facilitation payment—whether in cash, luxurious gifts, hospitality, or kind—is treated as gross misconduct subject to immediate summary dismissal and law enforcement referral.
j) Independence and Appearance of Propriety: In appearance and in substance, IMM RMC and all personnel must remain uncompromised by secondary financial arrangements, undisclosed commercial relationships, or conflicting fiduciary allegiances.
Scope of Coverage: This Code applies unconditionally to executive directors, non-executive directors, senior leadership, mid-tier managers, portfolio analysts, operational staff, and contractual personnel. All designated individuals must execute an annual written compliance acknowledgment.

4. GOVERNANCE, WHISTLEBLOWING & ESCALATION PROCEDURES
IMM RMC is dedicated to maintaining an uncompromising compliance culture aligned with Securities and Exchange Commission of Pakistan (SECP) standards and best practice corporate governance. The Company enforces clear reporting and whistleblowing protections:

4.1 Whistleblowing and Mandatory Escalation
If an employee becomes aware of, suspects, or discovers any ongoing or imminent violation of applicable laws, SECP REIT regulations, Trust Deeds, accounting standards, or this Code, the employee is under a mandatory professional duty to submit a written disclosure immediately.
i.    The disclosure must be submitted to the employee's Immediate Reporting Supervisor, with an immediate concurrent copy marked to the Head of Legal & Compliance and the Internal Audit function.
ii.    Where the concern involves executive leadership or potential conflicts at the supervisory tier, the report may be submitted directly to the Board Audit Committee.
iii.    IMM RMC strictly enforces a Non-Retaliation Policy. Any officer or employee attempting to penalize, harass, or disadvantage a bona fide whistleblower will face immediate disciplinary termination.

5. DISCIPLINARY MECHANISMS & CATALOGUE OF MISCONDUCT
5.1 Due Process and Corrective Action
Adherence to institutional discipline is a prerequisite for employment at IMM RMC. In the event of an alleged violation of this Code or organizational policy, the Company shall follow an equitable administrative process, issuing a formal Show-Cause Notice providing the employee a fair opportunity to furnish a written explanation and appear before an inquiry committee. Where explanations prove unsatisfactory or wilful defiance is established, the Management may institute disciplinary sanctions, up to and including termination for cause.

5.2 Major Acts of Professional Misconduct
The following acts represent severe breaches of discipline and trust. Commission of any such offense warrants decisive disciplinary action, alongside potential civil litigation and criminal reporting before law enforcement agencies or regulatory tribunals:
i. Code Violation: Material or deliberate breach of the provisions contained within this Code of Ethics and Professional Business Conduct.
ii. Insubordination: Wilful refusal, insubordination, or gross defiance committed individually or in concert of legitimate, reasonable managerial instructions.
iii. Fraud & Dishonesty: Theft, embezzlement, falsification of REIT accounts, fraudulent valuation, or intentional deception touching Company property or assets.
iv. Property Damage: Wilful, reckless, or malicious damage to, or destruction of, corporate assets, physical properties, software, or premises under REIT administration.
v. Corrupt Practices: Solicitation, receipt, or distribution of illicit financial incentives, kickbacks, bribes, or unlawful gratification.
vi. Gross Negligence: Dereliction of fiduciary obligations, egregious operational negligence, or reckless oversight resulting in financial damage or regulatory sanction.
vii. Unauthorized Commitments: Executing contractual liabilities, investment mandates, or financial guarantees beyond delegated limits under the Corporate Delegation of Authority.
viii. Moonlighting & Undisclosed Business: Participating in, operating, or advising competing commercial enterprises or unauthorized outside employment without prior formal consent.
ix. Disorderly Workplace Conduct: Riotous behaviour, intimidation, harassment, violent threats, or acts actively subversive to workplace safety and organizational harmony.
x. Labor Disruption & Sabotage: Instigating or participating in unlawful strikes, malicious work slowdowns, or calculated operational paralysis.
xi. Unauthorized Absence: Habitual non-attendance, abandonment of post, or prolonged absenteeism without approved leave entitlement.
xii. Chronic Late Attendance: Persistent, unexcused failure to adhere to designated office hours and core duty obligations.
xiii. Regulatory Contempt: Severe breach of statutory enactments, internal operating manuals, or directives issued by the SECP and financial authorities.
xiv. Judicial Conviction: Conviction by a court of competent jurisdiction for any offense involving moral turpitude, financial fraud, or criminal wrongdoing.

6. ADMINISTRATIVE PROTOCOLS & GOVERNANCE COMPLIANCE
6.1 Delegation of Authority
All administrative, investment, procurement, and financial authorizations must strictly conform to the thresholds codified in the formal Delegation of Authority (DoA) Matrix approved by the Board of Directors. No employee is permitted to approve or execute matters transcending their explicit authority limits.

6.2 Adherence to Standard Operating Procedures
Detailed Standard Operating Procedures (SOPs), Investment Due Diligence Frameworks, Valuation Policies, and Risk Management Guidelines issued by the Company are subject to periodic review and circulation. Personnel must execute their daily functions in absolute fidelity to both the letter and the spirit of these operational manuals.

7. ANNUAL COMPLIANCE UNDERTAKING & AFFIRMATION
All Directors, Officers, and Employees of IMM REIT Management Company Limited must execute the following declaration upon assumption of duties and on an annual recertification cycle thereafter:
Employee / Director Name:
Designation / Title:
Department / Division:
Employee ID / CNIC:
Date of Affirmation:
Signature:

I hereby confirm that I have meticulously read, fully understood, and pledge to strictly abide by the IMM REIT Management Company Limited Code of Ethics & Professional Business Conduct. I understand that failure to observe these provisions will result in disciplinary and legal proceedings in accordance with applicable corporate policies and prevailing legislation.