Anticorruption Policy

Summary

The following Anti-Corruption Policy, approved by the Board of Directors of Gewiss, derives from the principles defined in the Code of Ethics of the same, and aims at providing all Company personnel with the rules to follow in order to comply with Anti-Corruption Laws. It establishes the prohibition of corruption in all of its forms, including facilitation payments. In particular, this policy establishes the obligation of adhering to anti-corruption laws, providing a detailed definition of what is to be interpreted as corruption and defining the obligations to notify corruption practices in which Gewiss personnel may be actively or passively involved.

Corruption is recognized as an offense in most countries where Gewiss operates and exposes the Company and its personnel to the risk of prosecution, incarceration, and payment of fees. Consequently, the failed enforcement of policies aimed at precluding corruption by Gewiss personnel or by individuals acting on its behalf, regardless of the country in which the action takes place, exposes the Company's public image to significant damage.

Gewiss is devoted to implementing proper actions against corruption, including: i) denouncing the perpetration of offenses to the relevant public authority, supervisory body, or police force; ii) enacting internal disciplinary actions against the involved parties; and iii) terminating contracts with third parties for which illicit activities in violation of anti-corruption policies have been detected.

Gewiss personnel must therefore ensure, in the conduction of business activities, an appropriate equilibrium between establishing and maintaining strong relationships with collaborators/suppliers and the capacity to grant adherence to the principles of professionalism, objectivity, integrity, and independence, as well as respect for current norms on the subject. Gewiss personnel are furthermore required to fully comply with all norms and procedures adopted by the Company regarding the Code of Ethics.

Finally, Gewiss undertakes to update and periodically verify this Policy, to implement and keep active its Anti-bribery Management Systems, providing the necessary resources and defining objectives and measurable improvement targets on which to compare and evaluate the validity and effectiveness of the System itself.

1. Scope of Application

This policy is applicable to the development of activities performed by the Company and all its personnel in the public and/or private sector. Business Partners, consultants, suppliers, agents, Company collaborators, and, in general, all stakeholders and shareholders of the Company, are required to know and take note of the general principles mentioned in this Policy, although they are not required to fulfill the detailed functional requirements provided for the personnel of the Company.

2. Legal References

• Code of Ethics.
• Business procedures.
• Existing legislation and regulations.
• Organization Management and Control Model pursuant to Legislative Decree 231/2001.
• ISO 37001 - Anti-bribery management systems.

3. General Principles

In addition to the ethical principles stated in the Code of Ethics of the Company, which must at all times guide the activities of all Gewiss Personnel and in compliance with the requirements of the Anti-bribery management systems according to UNI ISO 37001, the following general principles must inspire the organization and the activities performed in the main risk and risk-conducive areas:

• Separation of responsibilities: Duties, operational activities, and control functions should be appropriately separated, ensuring that the person in charge of the operational activity is always different from the one who controls and authorizes such activities.
• Attorney power system: Attorney powers, which are formally defined, must be related to and consistent with the organizational and management responsibilities assigned and exercised within the defined limits.
• Clarity and simplicity: The duties and responsibilities of all those involved in the Company processes, including activities and controls, must be clearly defined and should provide mechanisms that are easy to apply.
• Impartiality and absence of conflicts of interest: Everyone who works directly for or represents the Company must act with professionalism, impartiality, and in compliance with anti-corruption laws. They must therefore avoid all and any situations that might give rise to a conflict of interests, and which may even potentially affect their ability to act in the interests of the company and in accordance with such laws.
• Traceability and filing: All sensitive activities as identified by this Policy must be traceable and auditable ex post; all documentation expected from this Policy and other related procedures must be appropriately filed and stored.

4. Gifts & Hospitality

Common Provisions

In accordance with the Code of Ethics of the Company, it is forbidden for all Gewiss Personnel to give or receive payments, gifts, hospitality, and other benefits (i) aimed at obtaining undue commercial, contractual, and economic advantages, and/or (ii) susceptible to compromising the integrity or reputation of one of the parties, or that can be interpreted by an impartial observer as aimed at creating an expectation of reciprocity or obtaining undue advantages.

Notwithstanding the previous prohibition, and in accordance with the Code of Ethics, Gewiss Personnel may give and receive gifts, hospitality, and other benefits to and from third parties, provided that the gesture possesses all the following characteristics:

• Not be a cash payment.
• Be provided in connection with good faith and legitimate business purposes.
• Not be motivated by the desire to exercise improper influence or the expectation of reciprocity.
• Be reasonable according to the circumstances.
• Be appropriate and commensurate with generally accepted standards of professional courtesy.
• Comply with local laws and rules applicable to public officials or private subjects, in addition to the provisions provided for in this Policy and any other procedure/guideline of the Company.

The use of cash to provide gifts, hospitality, or other benefits to either private or public third parties is forbidden. Special attention must be paid when offering a gift, act of hospitality, or other utility to Public Officials, regardless of the degree and nationality of the entity in which they operate. In line with D.P.R. 62/2013, no gifts to Public Officials may be given above the limit indicated in this standard and specified in the Guidelines. If the recipient has direct or indirect decision-making power over an open matter concerning Gewiss, it is prohibited to give gifts.

5. Facilitatio/Extorsion Payments

A facilitation payment is a small amount of money paid to a third party to ensure or speed up the performance of an activity within its scope of duties. Common examples include small payments to speed up routine public activities, such as payment to a Customs Public Officer to expedite a customs control or a visa request. Facilitation payments to both private and public individuals are considered corruption and are therefore forbidden by this Policy.

Extortion payments are those made under coercion, through the actual or threatened use of force, violence, or fear, or under the guise of a legitimate request. In the case of requests for extortion payments to a Public Officer, such a payment must be timely reported and duly documented.

6. Political Contributions

In line with the Code of Ethics, the Company does not involve itself directly or indirectly in any form of political or electoral activity. It is forbidden for the Company to make any direct or indirect contribution to political parties, movements, committees, political organizations, or trade unions, nor to their representatives and candidates.

Personal political or electoral activity by Gewiss Personnel, such as supporting local candidates or making contributions to candidates running for office, may be conducted only in full compliance with the laws of the jurisdiction where the employee resides; must be performed on an entirely personal basis and must in no way involve, or seem to involve, the Company.

7. Whistleblowing

With reference to any reports of violations of this Policy or unlawful conduct, please refer to the "Reporting Procedure" available on the Company website, in the "Governance" section: https://www.gewiss.com/ww/en/.