Our guiding principles: z Conducting business in accordance with legal provisions and internal rules and procedures z Prohibition of corruption and bribery z Corruption is criminalized and strictly not tolerated in the company z The company takes action to prevent or eliminate corruption z Working activities are carried out in accordance with the principles of transparency, objectivity and good faith. z Zero tolerance for accepting third party gifts or incentives, no matter the occasion or context Measures we implement: z Sanctioning of persons committing acts of corruption z Global case monitoring and process improvement z Assessing risks and taking the necessary measures to eliminate cases of corruption To ensure compliance with legal and internal regulations we implement a number of tools such as: z A compliance program that includes a variety of preventive measures such as risk assessments, training and counselling z A Compliance Management System (CMS) to ensure compliance with legal and internal regulations and to ensure personal accountability of company management and employees z Website dedicated to any interested party (customers, partners and employees) for information on compliance issues z Training workshops for all employees on procedural and compliance rules at least once a year z Legislative management application in the fields of environment and energy that support us in remaining timely informed and aware of new legal regulations and requirements applicable to our business The Compliance Management System (CMS) is managed by the local Compliance Department through a specific system implemented at Group level; in addition, there is a Chief Compliance Officer established group-wide. All complaints reported by both internal and external stakeholders on topics such as ethics, corruption, unfair competition, discrimination are assessed by the Compliance Officer through interviews and internal checks, with particular attention to confidentiality. An internal reporting tool is also provided. Gabriela MIHĂILESCU Compliace and Public Affairs Manager Compliance, fraud, corruption At national level, our company is covered by a comprehensive compliance risk assessment system, which includes corruption-related risks. At the same time, during the reporting period, our company was not involved in any legal actions regarding anti-competitive behavior or antitrust violations. A total of 13 high-risk situations, including competition and GDPR issues, were brought to the attention of the company's management in 2022 and communicated to the relevant authorities. The concept of Compliance is one of the core principles of our company, and it supports the mission of each of us to respect the "rules of the game", such as legal provisions and internal procedures. Through the Code of Conduct, we have defined standards of behavior that are binding for all employees – in particular for the CEOs and management. We have assessed our corruption-related risks and identified bribery from a corporate perspective to be a significant one. Particularly, there are risks related to price agreements, exploitation of market power towards suppliers, employee corruption and personal, individual benefits. SUSTAINABILITY REPORT PENNY ROMANIA 2022 80/250 SUSTAINABILITY STRATEGY ABOUT US AND OUR VALUE CHAIN THE FUTURE IS MADE TODAY SUSTAINABILITY HIGHLIGHTS MESSAGE FROM THE GENERAL DIRECTORS CONTENTS SUSTAINABILITY STEP BY STEP
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