CORPORATE GOVERNANCE Anti-Bribery and Anti-Corruption Policy

In 2022 the Board approved the Group’s AntiBribery and Anti-Corruption Policy which codifies our commitment to strictly comply with all anti-corruption laws applicable to the countries within which the Group operates. It reinforces the Group’s commitment to maintaining the highest possible standard of business and personal ethics as set forth in the ANSA McAL Group’s Code of Ethics.

The Policy addresses infractions such as the payment of acceptance of bribes or other inducements but also goes further, providing guidance and clarity to employees and affiliates in relation to the giving and receiving of gifts. The policy also highlights the key considerations to be made in relation to charitable contributions and actions to be taken in case of extortion or duress where an employee may be facing imminent danger. There is a list of red flags and an internal procedure for obtaining further guidance in the event that employees remain uncertain about the appropriateness of a transaction after consulting the policy. Importantly, the policy makes clear the Group’s commitment to protect employees who report actions in breach of the policy.

The Whistle-blower Policy, approved in August 2022, aligns closely with the Group’s Code of Ethics and the Anti-Bribery and AntiCorruption Policy. The Whistle-blower Policy has been introduced in support of the ANSA McAL #SpeakOut initiative which includes free and anonymous access to a 24-hour whistleblower hotline. The #SpeakOut campaign was relaunched in July 2022 and was welcomed by employees who have eagerly embraced the Group’s enhanced governance structures. The Group is proud of its continued commitment to abiding by the highest standards of transparency, probity and accountability and policies of this nature and assure stakeholders that ethics and integrity are a priority in our business model.