ANTI-BRIBERY AND CORRUPTION STATEMENT

Version 1.0 · Effective 2 November 2026

Our commitment

ECOFACTOR has zero tolerance for bribery and corruption in any form. We would rather lose a contract than win it improperly. This applies in every country where we do business, regardless of local custom, perceived business need or instructions from anyone.

In this statement, “ECOFACTOR”, “we” and “us” mean the companies operating under the ECOFACTOR brand: ECOFACTOR Sp. z o.o. (Poland), ECOFACTOR TECH UK LIMITED (United Kingdom) and ТОВ «ЗАРЯДНІ МЕРЕЖІ» (Ukraine).

The law we comply with

We comply with all anti-corruption laws that apply to us, in particular:

• United Kingdom — the Bribery Act 2010, including the offences of bribing (section 1), being bribed (section 2), bribing a foreign public official (section 6) and the corporate offence of failure to prevent bribery (section 7).
• Poland — the Criminal Code (Kodeks karny), in particular art. 228 (accepting a bribe by a public official), art. 229 (giving a bribe to a public official), art. 230 and art. 230a (trading in influence) and art. 296a (bribery in business), and the Act of 28 October 2002 on the liability of collective entities for acts prohibited under penalty.
• Ukraine — the Law of Ukraine “On Prevention of Corruption” and the Criminal Code of Ukraine, in particular art. 368 (acceptance of an improper advantage by an official), art. 368-3 (bribery of an official of a private-law legal entity), art. 369 (offering, promising or giving an improper advantage to an official) and art. 369-2 (abuse of influence), together with the criminal-law measures applicable to legal entities.

Where these laws differ, we follow the strictest standard.

What we prohibit

No one acting for ECOFACTOR may:

• offer, promise or give a bribe, kickback or any other improper advantage to anyone, including public officials and employees of private companies;
• request, agree to receive or accept a bribe or improper advantage;
• make facilitation payments — small unofficial payments to speed up routine official actions such as permits, inspections, grid connections or customs clearance — of any size;
• offer or accept anything of value to influence a public tender, a permit or an inspection;
• use an agent, consultant, distributor, installer or other third party to do anything that we may not do ourselves;
• hide, disguise or falsely record any payment or advantage.

The only exception is a payment demanded under a threat to someone’s life, health or liberty. Personal safety comes first. Any such payment must be reported to management as soon as it is safe to do so and recorded accurately.

Public officials and public tenders

We work with public authorities, local authorities and state-owned companies, including through public tenders. A “public official” includes employees of public bodies and local authorities, elected representatives and employees of state-owned or state-controlled companies. We:

• follow the rules of each procurement procedure strictly;
• do not offer gifts, hospitality or any other benefit to anyone involved in a tender, permit or inspection;
• do not seek or use confidential information about a tender;
• declare any personal connection with an employee of a procuring authority before taking part in the tender;
• report any suspected improper conduct by other bidders.

Gifts and hospitality

Gifts and hospitality can be a normal part of business, but must never influence, or appear to influence, a business decision. They must be modest, infrequent, transparent, permitted by the recipient’s own rules and disclosed to your manager. Cash and cash equivalents (such as vouchers or gift cards) are never allowed. Nothing may be given to or accepted from any party during a tender or contract negotiation in which it is involved.

Donations and sponsorship

ECOFACTOR does not make political donations. Charitable donations and sponsorship, including humanitarian support in Ukraine, must be made openly to legitimate organisations, must not be linked to any business decision and must be approved in advance by the management of the company concerned and recorded.

Third parties

We can be held responsible for bribes paid by those who act for us. Before engaging agents, intermediaries, distributors, consultants, installers or other partners who interact with customers or public authorities on our behalf, we take proportionate steps to:

• check their identity, ownership, reputation and sanctions status;
• assess the corruption risk of the country and the activity;
• pay only reasonable fees for legitimate, documented services, into an account in the partner’s own name;
• include anti-bribery obligations, audit rights and termination rights in our contracts where we can;
• monitor the relationship and act on warning signs.

Our expectations of suppliers are set out in our Supplier Code of Conduct.

Accurate books and records

All payments, gifts, hospitality, donations and fees must be recorded accurately and in sufficient detail. No off-book accounts or undocumented payments are permitted.

Training and responsibility

The management of each issuing company is responsible for applying this statement within its company. Managers make sure that people whose roles involve a higher risk, such as sales, tenders, procurement and work with public authorities, know this statement and how to apply it.

How to report

If you are asked for a bribe, are offered one, or suspect bribery by anyone acting for or dealing with ECOFACTOR, report it immediately. You can contact your manager or use our speak-up channel at info@ecofactor.eu, including anonymously. Details of all channels, including external authorities, are on our Report a Concern page (https://ecofactortech.com/legal/report-a-concern/).

We protect anyone who reports in good faith from retaliation, even if the concern turns out to be unfounded.

Consequences

Bribery is a serious criminal offence for individuals and companies in all the countries where we operate. Any breach of this statement may lead to disciplinary action up to and including dismissal, termination of contracts with third parties and reporting to the competent authorities.

Document control

Version 1.0 · Effective 2 November 2026 · Owner: Legal (in-house) · Approved by: adopted by ECOFACTOR Sp. z o.o. (Management Board), ECOFACTOR TECH UK LIMITED (directors) and ТОВ «ЗАРЯДНІ МЕРЕЖІ» (Director)