ERAM · Compliance · Contractor Code

Contractors &
Sub-Contractors Code.

Construction-specific extension of the Supplier Code. Sets out the procurement principles, FIDIC-style contract framework, site-level controls, and the explicit safeguards that apply when a Kelmendi Holdings group affiliate is engaged as designer, supervisor, contractor or sub-contractor.

Effective date: 1 May 2026 · Last updated: 13 May 2026 · Owner: Construction Management (with Investment Committee oversight) · Review cycle: Annual

1. Purpose and scope

This Code sets the standards ERAM Real Estate Sh.P.K. ("ERAM", "the Company", "we") expects of every general contractor, design office, supervision firm, specialty sub-contractor, consortium member, and further-tier sub-contractor engaged on a project developed under an ERAM project special-purpose vehicle (SPV).

It is incorporated by reference into every design contract, construction contract, supervision contract, sub-contract and consortium agreement issued by ERAM or any project SPV from the effective date, and is read together with the Supplier Code of Conduct as the contractor-specific extension.

2. The group-affiliate context — full disclosure

ERAM Real Estate Sh.P.K. is a member of Kelmendi Holdings. The following Kelmendi Holdings group affiliates are engaged in the design, supervision, and construction of ERAM projects, and are listed publicly on the Partners page of this website with their corporate identities visible from day one:

  • KST Institute Sh.P.K. — engaged as the independent design and supervision firm. KST contracts directly with the project SPV, separately from the contractor consortium described below, with a contractually-protected reporting line that preserves the independence of the supervision function;
  • Contech Group Sh.P.K. — engaged as leader of the construction consortium. The project SPV signs a single construction contract with Contech Group as consortium leader, with joint and several liability provisions covering the consortium members below;
  • APIS Sh.P.K. — engaged as a consortium member, providing mechanical, electrical and plumbing (MEP) installation scope within the consortium;
  • ERAM Group Sh.P.K. — engaged as a consortium member, providing complementary technical capability. ERAM Group is an independent sister company of ERAM Real Estate within Kelmendi Holdings;
  • Virtual Era Sh.P.K. — engaged as a consortium member, providing information and communications technology (ICT) scope within the consortium.

ERAM discloses these affiliations transparently, from day one, on the public Partners page of this website, in every project's Information Memorandum, in the procurement record of every relevant tender, and in each project SPV's annual audited financial statements. Engagement of any of these affiliates is governed by the safeguards set out below, in addition to the general protections of the Conflict of Interest Policy.

3. Procurement principles for affiliate engagements

Where ERAM or a project SPV proposes to engage a Kelmendi Holdings affiliate as a contractor, sub-contractor, design firm, or supervision firm, the following procurement principles apply, without exception:

  1. Competitive benchmarking — every affiliate engagement is benchmarked against at least one bona fide external offer for the same scope of work. Where a competitive tender involving non-affiliated bidders is feasible, it is run; where it is not feasible (urgency, specialist scope, prior site knowledge), the rationale is documented in the procurement file;
  2. No preferential pricing for the affiliate — the affiliate is not awarded the contract because of the affiliation. If the affiliate's offer is materially higher than a credible external benchmark, the work is offered to the external supplier; if the affiliate matches or improves on the external benchmark, the engagement may proceed on the affiliate's terms;
  3. Independent oversight — affiliate engagements above the threshold defined in the Conflict of Interest Policy require approval by the Investment Committee, with conflicted directors recused. The decision rationale is recorded in the related-party-transactions register;
  4. Arm's-length contractual terms — payment terms, performance bonds, liquidated damages, warranty, defect liability, dispute resolution, and termination rights are no more favourable to the affiliate than would be agreed with an unrelated third party;
  5. Annual auditor verification of pricing — the project SPV's independent statutory auditor reviews, as part of the annual audit, the pricing of every material related-party transaction with a group affiliate against external benchmark evidence retained in the procurement file. Any auditor finding of non-arm's-length pricing is disclosed in the SPV's audited financial statements and reviewed by the Investment Committee;
  6. Disclosure to investors — each material affiliate engagement is disclosed on the public Partners page of this website, in the project's Information Memorandum, in quarterly investor reports during the construction period, and in the SPV's audited annual financial statements;
  7. Independent supervision — where Contech Group is the lead construction consortium contractor, the design and supervision firm (KST Institute) contracts separately with the project SPV. The supervision firm's reporting line, scope of authority, fee structure (which is not linked to construction performance bonuses) and right of escalation to the Investment Committee are documented to preserve the operational independence of the supervision function from any sister-company contractor.

4. FIDIC-style contract framework

ERAM's standard construction-contract framework is aligned with FIDIC principles: fixed-price or guaranteed-maximum-price construction contracts, milestone payments certified by an independent engineer, performance bond from the contractor, liquidated damages for delay, defect-liability period after handover, and dispute resolution through institutional arbitration or the competent Kosovo courts.

Contractors and sub-contractors agree to operate under this framework and to provide the documentation, certifications, and warranties that the framework requires.

5. Health and safety on site

Construction-site safety is non-negotiable. Contractors and sub-contractors:

  • Comply fully with the Kosovo Law on Safety and Health at Work and any further safety law applicable on the project site;
  • Appoint a competent on-site safety officer with documented qualifications;
  • Maintain a method statement and a risk assessment for every significant activity, accessible to ERAM and the supervision firm on request;
  • Provide personal protective equipment (PPE) to every worker on site and enforce its use;
  • Operate a documented permit-to-work system for high-risk activities (work at height, hot works, confined-space, electrical, lifting operations);
  • Report every accident, near-miss, dangerous occurrence and serious injury to ERAM within 24 hours, in writing, with a documented root-cause analysis to follow;
  • Stop work immediately on becoming aware of an unsafe condition.

6. Labour standards on site

Contractors and sub-contractors comply with the labour-standards minimums set out in the Supplier Code, with the following additions specific to construction:

  • All site personnel are employed under written contracts and registered with the competent Kosovo authorities;
  • Working hours, rest periods and overtime comply with Kosovo labour law without exception;
  • Migrant and seasonal workers are afforded the same protections as local workers and are not subject to passport retention, recruitment fees or debt-bonding arrangements;
  • Welfare facilities on site (drinking water, sanitary facilities, rest areas, weather protection) meet legal and good-practice standards.

7. Environment and embodied carbon

Contractors and sub-contractors operate to the environmental design brief incorporated in each project's construction contract, including:

  • Materials specification with documented environmental product declarations (EPDs) where available;
  • Construction-waste management plan, with waste-stream segregation and licensed disposal;
  • Dust, noise and vibration controls to protect neighbouring properties;
  • Pollution-prevention measures for runoff, soil, and air;
  • Reporting of energy and water consumption during construction.

8. Anti-corruption — site-level controls

Construction is a corruption-vulnerable activity. The following controls apply to every site:

  • No facilitation payments to officials, regardless of local custom or perceived expectation;
  • No gifts or hospitality to public officials or to ERAM personnel beyond those permitted by the Anti-Bribery & Corruption Policy, properly recorded;
  • Variation orders, change orders and acceleration claims are documented, technically justified and approved by the supervision firm before payment;
  • Sub-contractor selection is documented and conflicts disclosed;
  • Site staff training on the Anti-Bribery Policy and on the Whistleblowing channel within the first month of mobilisation.

9. Supervision and quality control

ERAM appoints an independent supervision firm for every project. The supervision firm certifies milestone progress, approves variation orders, witnesses material acceptance, and signs off on quality. Where KST Institute Sh.P.K. acts as supervision firm and a sister-company is the contractor, the supervision function is contractually structured to preserve operational independence: separate reporting line to the project SPV's board, separate fee structure unrelated to construction performance bonuses, and right of escalation to the Investment Committee.

10. Insurance

Contractors maintain at minimum: Construction All-Risks (CAR), Erection All-Risks (EAR) where mechanical/electrical works are in scope, Public Liability with a project-appropriate limit, Employer's Liability for their own workforce, and Professional Indemnity for design and supervision activities. Certificates of insurance are provided to ERAM before mobilisation and renewed annually.

11. Reporting concerns

Every contractor and sub-contractor representative who suspects or witnesses behaviour that breaches this Code, the law or any ERAM policy — including suspected corruption, unsafe practice, labour abuse, environmental harm, or related-party self-dealing — is obliged to report through the Whistleblowing channel. Retaliation against good-faith reporters is strictly prohibited.

12. Audit and consequences of breach

ERAM, the project SPV's auditor, the independent supervision firm, and any independent reviewer appointed by the Investor Representative may audit any contractor's or sub-contractor's compliance with this Code at any time.

Material or repeated breach is grounds for suspension or termination, in addition to any rights and remedies available under the contract and applicable law. Where the affiliate relationship contributed to the breach, the affiliate's continued eligibility for further ERAM contracts is reviewed by the Investment Committee.

13. Acknowledgement

By executing a design, construction, supervision, MEP, ICT, or sub-contract with ERAM Real Estate Sh.P.K. or any project SPV, the contractor or sub-contractor acknowledges receipt of this Code and undertakes to comply with it. The Code is also binding on the contractor's employees, agents and further-tier sub-contractors via flow-down obligations in their respective contracts.

Contact

Questions regarding this Code, or to report a concern: [email protected]. Confidential reports may also be made via our Whistleblowing channel.

ERAM Real Estate Sh.P.K. · Business no. (NUI) 812052025 · Registered 13/06/2023 · Rruga Agim Ramadani, Nr. 2, 10000 Prishtina, Kosovo