Ethics and Integrity The Code of Conduct is our main document that summarizes the values, principles and behaviors expected of stakeholders. The Code applies to all our employees and is aligned with the REWE Group Code of Conduct, which is regularly reviewed and updated. The Code covers expectations on topics such as ethical decision-making, conflicts of interest, insider trading, sustainability, and other fundamental ethics and compliance topics. It also includes examples of how our employees can put integrity into action, outlines our non-return policy, and outlines the consequences of non-compliance with the Code. We have a number of measures to ensure compliance with the Code of Conduct, which include proactive measures such as a specific training curriculum on different topics related to ethics and integrity, customized for different structures. More information is available in the 'Risk management' section of this report. At the same time, all our employees have access to our company's policies, regulations and procedures, either through an intranet or through an interactive IT tool made available at group level. Information on the policies is communicated at the time of employment through the collective labor agreement, the internal regulations and the job description. We aim to implement our values in our supply chain as well, by implementing the PENNY standards for suppliers. These standards set out our fundamental expectations of our suppliers on topics such as food and product safety, consumer protection, compliance with trade laws, conflicts of interest and fair competition. The scope of the standards applies to all suppliers who sell their products to us for resale or for their own use and provides suppliers with examples of good practice in action. All these standards are part of the tender specifications during tenders and are subsequently included in the contracts. Suppliers are expected to cascade the requirements outlined in our Supplier Standards throughout their supply chain – including suppliers of raw materials, components or ingredients, as well as subcontractors and agents. Any complaint regarding a possible breach of the Code of Conduct can be submitted through the internal and external reporting mechanism called Hintbox. In addition, there are also dedicated email addresses that can be used both at the company and group level, thus facilitating the effective reporting of these situations. Anti-corruption policies In our work we do not tolerate any form of corruption, bribery or blackmail. No contract or commercial relationship or partnership entered into with our company may be used for personal benefit or for the benefit of a third party. More details can be found in the chapter Risk Management and Compliance. Fairness and anti-competitive practices We fully comply with anti-competitive practices and legislation. We have identified within our activities those structures and functions that have the greatest risk of exposure to this issue and that have a position to exert influence in this regard. We implement a number of measures to ensure fairness in our business practices. The measures range from specific training programs, to the helpline offered by the Compliance and Public Affairs team, directly or through external consultants. More details can be read in the chapter Risk Management and Compliance. Complaint management We implement a modular system for handling complaints of any kind. The modules made available to all stakeholders (internal or external) are: • Telephone line dedicated to any type of notifications, questions and complaints: 0800 110 111 • Online contact form available at: https://www.penny.ro/contact • E-mail: contact@penny.ro • Special e-mail for employees who make complaints in the field of harassment: egalitate@penny.ro • REWE Group Hintbox whistleblowing system, available at: https://rewe-group.hintbox.de/ T SUSTAINABILITY STEP-BY-STEP CORPORATE GOVERNANCE AND BUSINESS SUSTAINABLE ASSORTMENT ENERGY, CLIMATE AND RESOURCES EMPLOYEES AND SOCIETY INDEX GRI & SASB CORPORATE GOVERNANCE AND BUSINESS
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