Anti-corruption policy

ANTI-CORRUPTION POLICY ADOPTED 2023-06-30 Last Revised 2024-06-22

The Board of Directors of Earl Holding III AB (reg. no. 559032-9339) (the “Company” ) has on 2024-06-22 adopted this Anti-Corruption Policy.

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1. Background and purpose Eton must never engage in any kind of corruption. Eton will work to eliminate all forms of corruption, including but not limited to, extortion, bribery, facilitation payments, nepotism, fraud, insider trading and money laundering.

2. Procedure statement 2.1 Bribery A bribe occurs when a person requests, receives, offer, pay, seek or accept an offer or an improper advantage or reward in connection with his or her position, office or assignment. You shall not, directly or through intermediaries, offer or promise any financial or other advantage to any person or organization, in order to obtain any preferential treatment in connection with Eton’s business. The term “advantage” may include – but is not limited to – gifts, loans, money, travel, exclusive entertainment and personal favors.

2.2 Facilitation payment Offering facilitation payment, which is where a government official is given money or goods to perform, or speed up the performance of, an existing duty, is not accepted at Eton.

2.3 Gifts, meals and entertainment All corporate hospitality should be characterized by cost consciousness. You should be prudent in corporate hospitality that recurs frequently with the same individual or group. Ensure that social activities arranged on behalf of Eton are suitable for all, regardless of gender or religion.

You may accept reasonably priced gifts on appropriate occasions, corresponding to a price of $50 or below under the circumstance that the gift does not influence your business decision. If you are offered a gift that exceeds this limit, politely decline and explain the company’s rules. If this is deemed improper or impolite, you may accept the gift and notify your manager, who will decide whether the gift may be kept, donated to charity or distributed to a larger group of employees. Gifts shall always be registered by Eton.

1 Includes all subsidiaries of the company group in which Earl Holding III AB is the parent company.

2.4 Conflict of interest We recognize that transparency in our business is crucial in order to avoid conflict of interest. Dealing with business partners must be impartial and professional. A conflict of interest arises when personal relationships, participation in external activities or interest in a venture influence or could be perceived to influence business decisions. Employees must be open about potential conflict of interests and withdraw from decision-making that creates or could be perceived to create a conflict of interest.

2.5 Political contributions, donations and sponsorship Eton is politically neutral and does not make financial contributions to political parties, politicians, or political campaigns. Charitable donations or sponsorships should not be aimed at or result in any inappropriate or hidden commercial or direct return to Eton. A donation is a charitable donation with no expectation of direct corporate gain. Sponsorships are programs where Eton sponsors organizations or events to promote the Eton brand, our services or enhancing our reputation. All donations and sponsorships must be made openly, in line with this policy and reported to management.

2.6 Fair competition Eton is committed to promoting fair competition and an open market. Fair competition is the basis for all business development and innovation. We are firm believers that free and fair competition works in our favor, allowing us to conduct good and sound business.

Agreements, including but not limited to price fixing, market sharing, bid rigging and output restrictions are considered as corruption.

On a yearly basis Eton shall provide anti-corruption training to all employees.

3. Relevant entity/BU This Policy applies to all entities within the Group.

4. Roles and responsibilities The Board of Directors is the approver of this policy.

The Group CEO is the owner of this policy.

The Group CEO shall ensure that this policy and knowledge about corruption and bribery, and how to combat it, shall be distributed to employees within the Group.

5. Exception There are no exceptions to this policy. Any need for exceptions to this policy must be clearly defined and documented. All exceptions shall be approved by the Board of Directors.

6. Monitoring of compliance Monitoring of compliance of this policy is done through trainings provided to all employees on an annual basis. Compliance is also monitored as a part of the annual risk assessment and management procedure.

7. References