16 The company shall provide information about its system for preventing, detecting, investigating and prosecuting allegations or cases of Corruption and Bribery, including the relevant training.

17 The purpose of this disclosure requirement is to provide transparency regarding the company's key procedures for preventing, detecting and addressing allegations of Corruption or Bribery. This includes training for own employees and/or information provided internally or to Suppliers.

18 The disclosure referred to in paragraph 16 shall include the following information:

(19) If the undertaking does not have such procedures in place, it shall disclose this and, where appropriate, present its plans for their implementation.

20. the disclosures referred to in paragraph 16 shall include information on how the company communicates its policies to those to whom they are relevant, to ensure that the policy is accessible and that its impacts are understood.

21. the disclosures referred to in paragraph 16 shall include information on the following aspects relating to Training:

AR 4 "High-risk functions" are functions which, due to their duties and responsibilities, are considered to be at risk of Corruption and bribery.

AR 5 Disclosures may include details of risk assessments and/or mapping and monitoring programs and/or internal control procedures that the company implements to detect Corruption and Bribery.

AR 6 The company's policies on Corruption and Bribery may be relevant to certain groups of people, either because they are expected to implement them (e.g. employees, contractors and suppliers of the company) or because they have a direct interest in their implementation (e.g. Value chain workers, investors). The company may specify the means and channels of communication (e.g. brochures, newsletters, dedicated websites, social media, face-to-face interactions, trade unions and/or Workers' representatives) to communicate its policies to these groups. This may also include how potential barriers to dissemination are identified and addressed, e.g. through translation into relevant languages or the use of graphic representations.

AR 7. the company may provide an analysis of its training activities, for example by training region or employee category, if its programs differ significantly based on such factors and such information would be useful to Users.

AR 8. the entity may present the required information about training using the table below:

In FY 20XY, ABC provided training to its own at-risk workforce on its policies (see Note x). Training is mandatory for those in high-risk roles, but ABC also provides voluntary training for other own workers. Details of training provided during the year:

Our company pursues clear strategies to combat Corruption and Bribery, based on precise guidelines and regular training. The aim is to promote an ethical working environment and prevent violations.

Anti-Corruption Policy

Our anti-corruption policy ensures that both national and international laws are complied with, particularly with regard to Bribery and Corruption. It regulates the handling of gifts, invitations, sponsorship, donations, suppliers and business partners. The policy sets out clear standards of conduct for all employees, managers and governing bodies of the company, both in national and international markets.

This policy was introduced in 2022 and ensures transparency and an in-depth understanding of the relevant provisions. It is regularly reviewed and updated to ensure that it meets the highest ethical standards.

Responsibilities and review

Responsibility for implementing and monitoring the Anti-Corruption Policy lies with the Compliance department. Internal investigations are carried out by the internal audit department as required. There is no separate investigation committee or officer. In addition, an annual report is prepared documenting progress and challenges in the area of corruption prevention.

All operating sites are subject to regular audits for corruption risks.

Training measures

A central aim of our corporate strategy is to increase awareness of compliance issues. At the beginning of each financial year, all employees receive mandatory web-based training on compliance requirements, which must be completed within one year. In addition, we offer specific classroom training courses tailored to different target groups.

The Compliance department monitors participation in these training courses and informs the Management Board of progress on a monthly basis. In this way, we ensure that all employees receive continuous training and actively implement the corporate values in their day-to-day work.