system, implemented at group level. The CMS also involves a centralized model for approaching and reporting compliance situations. The Compliance Department pays special attention to the management of the hintbox at national level and to the management of the Risk to chance "R2C" system, mainly intended for identifying and reassessing compliance risks. At the same time, we are constantly implementing and updating our compliance program that includes a variety of preventive measures, such as risk assessments, training, and counseling. Several stakeholders are involved in the program update, including the legal and compliance department, as well as group-level entities that are responsible for ensuring compliance. The structures 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 for 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 a particular focus on privacy. Employees can use the existing modules to submit compliance complaints and reports, presented in the "Complaint Management" section. In 2024, compliancerelated complaints were registered only through REWE Hintbox. Thus, there were 12 notifications, of which 4 on internal standards of conduct were confirmed and for which immediate corrective actions were taken. The external stakeholder measures we implement to ensure compliance include: • Letters of Compliance for Potential Future Business Partners (Used in Tenders) • Compliance details on the website for submitting compliance advice (including information on how to submit complaints) In addition to encouraging the flagging of concerns or violations, other internal measures we implemented in the reporting year were: • Internal audits for buyers (Buying Department) on antitrust topics • Round tables and training courses with the Buying Department • Participation of compliance officers in some of the negotiations with suppliers • Training of fruit and vegetable suppliers on compliance, anti-corruption and antifraud topics • General training on various compliance, anti-fraud, anti-corruption and antitrust topics Training We continued the compliance training program carried out throughout the year, and in 2024 we achieved: Physical courses (type of participants) Total 673 Colleagues in executive positions Managers 54 619 Physical courses (type of training) Total hours 44.5 Anti-Trust Compliance 38.4 6.1 MESSAGE FROM THE GENERAL MANAGEMENT SUSTAINABILITY STRATEGY AND GOVERNANCE ABOUT US AND OUR VALUE CHAIN ABOUT THE REPORT THE FUTURE IS MADE TODAY SUSTAINABILITY MILESTONES SUSTAINABILITY REPORT PENNY ROMANIA 2024 98/276
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