Anti-corruption Policy

Summary

The GEWISS Anti-corruption Policy, derived from the principles in the Code of Ethics of Gewiss Subsidiary, provides Company personnel with rules to comply with Anti-Corruption Laws. It prohibits all forms of corruption, including facilitation payments. The policy mandates adherence to anti-corruption laws, defines corruption, and outlines obligations for personnel involved in or aware of corrupt practices. Corruption is an offense in most operating countries, posing risks of prosecution, fines, and damage to the Company's public image. Gewiss Subsidiary implements actions against corruption, including reporting offenses to authorities, internal disciplinary actions, and terminating contracts with third parties involved in criminal activities violating anti-corruption policies. Gewiss personnel must maintain professionalism, objectivity, integrity, and independence in business activities, respecting company norms and the Code of Ethics.

1. Scope of Application

This policy applies to all activities performed by the Company and its personnel in both public and private sectors. Business Partners, consultants, suppliers, agents, Company collaborators, and all stakeholders are required to be aware of its general principles, though they are not bound by the detailed functional requirements applicable to Company personnel.

2. Legal References

• Code of Ethics.
• Policies and Corporate procedures.
• Existing legislation and regulations.

3. General Principles

In addition to the ethical principles of the Code of Ethics, all Gewiss Personnel must adhere to the following general principles to comply with this Policy:

• Separation of responsibilities: Duties, operational activities, and control functions must be separated, ensuring the person responsible for an operational activity is different from the one who controls and authorizes it.
• Attorney power system: Formally defined attorney powers must align with assigned organizational and management responsibilities.
• Clarity and simplicity: Duties and responsibilities within Company processes, including activities and controls, must be clearly defined and supported by easily applicable mechanisms.
• Impartiality and absence of conflicts of interest: All individuals working for or representing the Company must act with professionalism, impartiality, and in compliance with anti-corruption laws. They must avoid situations that could create conflicts of interest or potentially affect their ability to act in the company's best interest.
• Traceability and filing: All sensitive activities identified by this Policy must be traceable and auditable. Documentation related to this Policy and other procedures must be appropriately filed and stored.

4. Gifts & Hospitality

Common Provisions

Gewiss Personnel is forbidden from giving or receiving payments, gifts, hospitality, or other benefits intended to obtain undue commercial, contractual, or economic advantages, or that could compromise integrity or reputation, or create expectations of reciprocity.

However, Gewiss Personnel may give and receive gifts, hospitality, and other benefits to/from third parties if the gesture meets all the following characteristics:

• It is not a cash payment.
• It is provided in connection with good faith and legitimate business purposes.
• It is not motivated by the desire to exercise improper influence or expectation of reciprocity.
• It is reasonable according to the circumstances.
• It is appropriate and commensurate with generally accepted standards of professional courtesy.
• It complies with local laws and rules applicable to public officials or private subjects, as well as Company policy and guidelines.

The use of cash for gifts, hospitality, or other benefits to third parties (private or public) is forbidden. If this prohibition does not apply to the Company, any cash expense for such benefits must be adequately justified in the expense report for audit purposes.

5. Facilitation/Extortion Payments

A facilitation payment is a small payment made to a third party to ensure or speed up the performance of an activity within their duties, such as small payments to customs officers to expedite a customs control or visa request. Facilitation payments to individuals (private or public) are considered corruption and are forbidden by this Policy.

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

6. Political Contributions

In line with the Code of Ethics, the Company does not engage directly or indirectly in any form of political or electoral activity. The Company is forbidden from making any direct or indirect contribution to political parties, movements, committees, political organizations, trade unions, their representatives, or candidates.

Personal political or electoral activity by Gewiss Personnel, such as supporting local candidates or making contributions to candidates, must be conducted solely in compliance with the laws of the employee's jurisdiction, on a purely personal basis, and must not involve or appear to involve the Company.

7. Whistleblowing

For 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.