Introduction

1. Win-Invest, including its subsidiaries and related companies worldwide (hereinafter: the “Company”), is committed to maintaining the highest standards of business integrity and ethical conduct. The Company has a strict zero-tolerance policy toward any form of bribery or corruption.
2. This policy has been developed to promote ethical behavior and compliance with relevant laws. It applies to all Company employees and associated parties, including regional managers, directors, consultants, contractors, suppliers, service providers, agents, and other business partners (“Relevant Parties”).
3. This policy complements the Company’s ethical code and specific compliance procedures for engagements with public authorities, insurance companies, and banks.
4. This policy is based on international norms and may not reference specific local legislation. Local legal advice should be sought where necessary.

Objectives of the Policy

5. This policy aims to identify and manage situations that may involve bribery or corruption, including requests for or offers of bribes involving public officials.
6. It provides guidelines for employees and Relevant Parties to comply with anti-corruption laws.
7. Clear standards for interactions with public officials, reporting, and monitoring are outlined.
8. The policy applies to all Company operations and subsidiaries globally.

Definitions

9. This policy applies to all employees and associated parties acting on behalf of the Company.
10. “Public Official” refers to any individual employed in public service or working for entities providing public services. This includes:

• Government employees at any level.
• Political party officials or candidates.
• Employees of government-controlled entities.
• Representatives of international public organizations.
• Employees of organizations providing public services.

11. A public official may also include private individuals performing public duties, such as consultants hired by public institutions.

Zero Tolerance for Non-Compliance

12. All employees and Relevant Parties must comply with this policy and applicable anti-corruption laws. Any deviation will not be tolerated.
13. Key guidelines include:

• Avoid offering, promising, or giving any benefits to public officials.
• Never approve or facilitate improper payments through third parties.
• Always ensure payments to third parties are justified and documented.
• Service providers must be informed of and adhere to this policy.

Rules for Engaging Relevant Parties

19. Every business opportunity or new project involving public officials must be managed and documented by the Legal Department.
20. Written agreements must be approved in advance and comply with this policy.

Prohibited Payments

21. Payments must be made only to registered accounts of service providers in their country of operation.
22. Accurate invoices and receipts must be issued.
23. Payments to offshore companies without clear relationships must be avoided.
24. Cash payments are strictly prohibited.
25. Payment terms must be clearly defined in contracts.

Documentation

26. Records of transactions, agreements, and due diligence must be kept for at least seven years.

Hospitality of Public Officials

27. The Company has a strict policy regarding expenses for business visits, including meals, travel, and accommodation.
28. Payments for local public officials' expenses are prohibited.
29. Personal expenses unrelated to business activities are not allowed.

Hospitality of Foreign Public Officials

30. Hosting foreign public officials must serve a clear business purpose.
31. Hospitality must be reasonable, proportional, and necessary.

Gifts

32. The Company has a strict policy regarding gifts to public officials.
33. In certain cultures, modest gifts may be appropriate.
34. Guidelines for gift-giving include:

• Gifts must be given in good faith, without expectations of reciprocity.
• They must be visible, reasonable, and moderate.
• Prior written approval from the Compliance Officer is required for exceptions.

By adhering to this policy, the Company and its employees can maintain the highest ethical standards and comply with anti-corruption laws, fostering a culture of integrity in all business operations.