GEWISS Anticorruption Policy

Summary

This 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 corruption in all its forms, including facilitation payments. The policy establishes the obligation to adhere to anti-corruption laws, defines corruption, and outlines obligations for personnel involved in corruption practices.

Corruption is an offense in most countries where Gewiss Subsidiary operates, posing risks of prosecution, incarceration, and fines for the Company and its personnel. Failure to enforce policies against corruption can significantly damage the Company's public image.

Gewiss Subsidiary is committed to implementing actions against corruption, including: reporting offenses to authorities, enacting internal disciplinary actions, and terminating contracts with third parties involved in criminal activities violating anti-corruption policies.

Gewiss personnel must ensure professionalism, objectivity, integrity, and independence in business activities, maintaining strong relationships with collaborators and suppliers while adhering to current norms and the Company's Code of Ethics.

1. Scope of Application

This policy applies to all Company activities and personnel in both public and private sectors. Business Partners, consultants, suppliers, agents, collaborators, stakeholders, and shareholders are required to understand the general principles outlined herein, 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, the following general principles must guide the organization and activities in risk-conducive areas to ensure compliance with this Policy:

• Separation of responsibilities: Duties, operational activities, and control functions should be distinct, ensuring the person responsible for an activity differs from the one who controls and authorizes it.
• Attorney power system: Attorney powers must be formally defined, consistent with assigned organizational and management responsibilities, and exercised within defined limits.
• Clarity and simplicity: Duties and responsibilities for all involved in Company processes must be clearly defined with easily applicable mechanisms.
• Impartiality and absence of conflicts of interest: Personnel must act with professionalism, impartiality, and in compliance with anti-corruption laws, avoiding situations that create conflicts of interest or affect their ability to act in the company's best interest.
• Traceability and filing: All sensitive activities 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 are 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 from third parties if they meet the following criteria:

• Not a cash payment.
• Provided in connection with legitimate business purposes.
• Not motivated by improper influence or expectation of reciprocity.
• Reasonable according to circumstances.
• Appropriate and commensurate with professional courtesy standards.
• Compliant with local laws and rules for public officials or private subjects, and Company policies.

The use of cash for gifts, hospitality, or other benefits to third parties is forbidden. If an exception applies, cash expenses must be adequately justified in expense reports for audit purposes.

5. Facilitation/Extortion Payments

A facilitation payment is a small sum paid to a third party to ensure or speed up an activity within their duties, such as small payments to customs officers. Facilitation payments to private or public individuals are considered corruption and are forbidden by this Policy.

Extortion payments are made under coercion, threat of force, violence, or fear. Requests for extortion payments to a Public Officer must be reported and documented promptly.

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 contributions to political parties, movements, organizations, trade unions, their representatives, or candidates.

Personal political or electoral activity by Gewiss Personnel must be conducted in full compliance with local laws, on a purely personal basis, and must not involve or appear to involve the Company.

7. Whistleblowing

For reports of violations of this Policy or unlawful conduct, please refer to the "Reporting Procedure" available on the Company website in the "Governance" section.