1. Purpose

The purpose of this Policy is to assist staff and agents (including consultants, advisers, intermediaries or any other individual or business that acts on behalf of Karl Faller) in identifying anti-bribery and corruption-related issues and in understanding and complying with our related procedures.

2. What is bribery?

Bribery means giving or offering (as well as demanding or receiving) any undue advantage to or from:

• A public or government official
• A political candidate, party or official, or
• Any private sector employees, directors or officers, or their agents or representatives

3. Zero tolerance policy statement

The Company prohibits bribery and corruption in all business practices and transactions carried out by its staff and by agents acting on its behalf.

All staff and agents of the Company are protected from any penalty or adverse consequences for identifying concerns related to suspected bribery, for refusing to participate in bribery or for refusing to pay a facilitation payment.

Staff and agents of the Company must not engage in bribery in connection with any dealings or activities involving private or public companies, government or public officials, organisations or individuals.

4. Facilitation payments

Facilitation payments are sums of money paid to obtain preferential treatment for something the recipient would otherwise still be required to do.

Facilitation payments of any kind are strictly prohibited under this policy. Staff or agents who are asked to make a facilitation payment should immediately report this to Nadine Reidenbach.

5. Gifts and hospitality

Staff and agents acting on behalf of the Company must never use gifts or hospitality to improperly influence the business decision-making process or cause others to perceive an improper influence.

All gifts or hospitality above [e.g., €500] must be recorded in the Gifts and Hospitality Register. Gifts and hospitality should be offered only to better present our products or to establish cordial relations with prospective business partners. Staff and agents must disclose if they have been offered gifts and/or hospitality.

6. Charitable and political donations

Charitable donations will never be made to influence a business decision-making process. All such donations (if made) will be made directly to selected charitable organisations and never to an individual. The Company does not make political donations of any kind.

7. Use of cash

No payment to or from any business counterparty shall be made in cash. Any exception to this rule requires advance written approval from Nadine Reidenbach.

8. Reporting

Any staff or agents who identify (or suspect) instances of bribery should report this immediately to:

Name: Nadine Reidenbach

Email: compliance@karl-faller.de

9. Investigation and sanctions

All actual or suspected cases of bribery will be fully investigated. Staff and agents found to be in breach of this policy could face disciplinary action.

Updated:02.02.2026