Compliance For us, the concept of "Compliance" means conformity with the rules to which we are subject, whether it is legislative conditions, internal procedures and policies or development directions established at Group level. Among the main topics addressed are ethics, corruption, unfair competition, discrimination. This dimension, like that of legal compliance, is closely linked and depends on effective risk management. The PENNY principles of compliance are: z Compliance with legal provisions and internal rules and procedures in all our activities z Prohibition of corruption and bribery z Taking measures to prevent or eliminate cases of corruption z Respect for the principle of transparency, objectivism, and good faith z Zero tolerance for accepting gifts from third parties, regardless of the occasion During the reporting period, our company was not involved in legal actions or other incidents regarding anticompetitive behavior, violations of antitrust law or ethical issues. At the same time, this year there were no fines or cases of corruption at the company level, and the standards of collaboration with contractual partners remained at the same level, continuing this year with the 100% rate of signing and assuming the anti-corruption clause for all new partners. The Code of Conduct remains the basic tool through which we define and implement standards of conduct that are binding on all employees – including CEOs and management. To ensure effective compliance at the level of our company, we implement the Compliance Management System (CMS), which is managed by the local Compliance Department, through a specific system, implemented at Group level. The QMS also involves a centralized model for approaching and reporting compliance situations. The Compliance Department pays particular attention to the management of the hintbox at national level and to the management of the Risk to change the “R2C" system, primarily intended for the identification and reassessment of compliance risks. At the same time, we constantly implement and update the compliance program that includes a variety of preventive measures, such as risk assessments, training, and counseling. The staff responsible for implementing this system are the Chief Compliance Officer (established at Group level) and the local Compliance Officers who are available to all employees on compliance issues. All stakeholders, including employees, are encouraged to report any compliance concerns or irregularities, which are assessed by the Compliance Officer through interviews and internal checks, with particular attention to confidentiality. Employees can use existing modules to submit compliance-related complaints and referrals s, outlined in the "Complaint Management" section. In 2023, compliance-related complaints were registered only through REWE Hintbox. Thus, there were 9 complaints, of which 3 on internal standards of conduct were confirmed and for which immediate corrective actions were taken. In the 2023 reporting year, there were no incidents of corruption identified either. The external stakeholder measures we implement to ensure compliance include: z Letters of Compliance for Potential Future Business Partners (used in tenders) z Compliance details on the website for submitting compliance advice (including information on methods for submitting complaints) In addition to encouraging the flagging of concerns or violations, other internal measures we implemented in the reporting year were: z Internal audits for buyers (Purchasing Departments) on antitrust z Round tables and training courses with the Purchasing Departments z Participation of compliance officers in some of the negotiations with suppliers z Training of fruit and vegetable suppliers on compliance, anti-corruption, and anti-fraud issues z General training sessions on various compliance, anti-fraud, anti-corruption, and antitrust topics SUSTAINABILITY REPORT PENNY ROMANIA 2023 94/256 MESSAGE FROM THE GENERAL DIRECTORS SUSTAINABILITY STRATEGY AND GOVERNANCE ABOUT US AND OUR VALUE CHAIN ABOUT THE REPORT THE FUTURE IS MADE TODAY SUSTAINABILITY MILESTONES CONTENTS
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