SPECTRE | CSR Report 2021/2022

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Legal Compliance

Legal Compliance Anti-corruption and whistleblower protection As a signatory of United Nations Global Compact we are committed to its principles including Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery. As a company operating in a globally with suppliers from Europe, Asia and North America. We conduct business in an honest and ethical manner. Regardless of the geographical location of our activities, Spectre has a single company spirit and business philosophy which is rooted in our Core-value Model with integrity being one of them. We have a zero-tolerance approach towards bribery and corruption, and we remain bound to the UK Bribery Act and the national legislations of the countries in which we operate. We implemented a group-wide anti-corruption policy in 2015 and we have continuously improved. In 2021 we revised the Anti-corruption policy, further explaining issues with conflict of interest and revised procedure for dealing with gifts. Each year we reassess all our operations for risks of corruption and have identified the following activities that are exposed to risks of corruption: • All management positions • Import/export of goods including contact to customs authorities • Supplier contacts/Purchasing duties • Quality audits • Social audits • Price negotiations with suppliers and customers • Financial audits • Payments of invoices • Payments to and contacts with tax authorities • Salary payments • Sales efforts aimed at customers Together with the revised Anti-corruption Policy we implemented a Whistleblower Protection Policy to ensure compliance with EU Whistleblower directive and new local legislation in the EU Member states. The policy was communicated to all employees in Denmark, Vietnam and Latvia by publishing it on the company intranet and training was provided to all employees that are involved in any of the activities exposed to risks of corruption making up 100% of employees in Denmark, 6% of all employees in Latvia, 5% in Vietnam. Whistle-blower Protection Policy was also communicated to all employees with posters on the reporting mechanism and main points of the policy in Vietnamese, Latvian and English. Two of five Board Members received training on the policy. Next year’s emphasis will be to improve the reporting mechanism and communication of the Whistle-blower Protection Policy to be applicable also to external stakeholders. Clauses of anti-corruption are also included in Spectre’s Code of Conduct which is communicated to all suppliers and subcontractors. In 2021/22 we have not found any violations of our anti-corruption policy.

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