Business Ethics

Zero tolerance to corruption and bribery, in accordance with the key pillars of the Code of Business Conduct and the Suppliers & Business Partners Code of Conduct, which may be updated as required.

The Company's “Responsible Corporate Citizenship” is reflected in its engagement in international transparency initiatives (UN Global Compact), national working groups and, more generally, in its commitment to ethical business practices and good corporate governance. Metlen is formally committed to the 10th principle of the UN Global Compact, according to which it works against corruption in all its forms, including extortion, bribery, and facilitation payments. Such principle acts as a catalyst in the development of the ethical culture throughout the Company.

Impacts

Actual positive impacts

Anti-corruption and bribery as well as Business Ethics are essential issues for Metlen because they can:

1. contribute to the identification, recording, better assessment and management of risks, as well as to compliance with laws, which is a non-negotiable principle for Metlen, in every region or country where it operates;
2. serve its business goals, such as fulfilling relevant tender requirements for construction projects of customers or financial institutions; and
3. shield the Company against corruption, fraud, embezzlement, and abuse, further enhancing its corporate image.

The Company's operation is based on transparency, placing emphasis on its firm commitment to zero tolerance to corruption and bribery in its business, implementation of Codes of Conduct, and avoidance of unfair business practices that prevent fair competition.

Potential negative impacts

Potential negative impacts Metlen recognizes that corruption, bribery, fraud, violation of fair competition, and money laundering undermine the ethical environment of any business. Potential impacts include human rights abuses, adverse environmental impact, indirect engagement in unfair practices, especially in countries with high corruption rates, and obstruction of wealth distribution and economic growth of the countries. Such phenomena are a major obstacle to Sustainable Development, with a disproportionate impact on poor communities, eroding the social structure.

Major risks

As a result of its activity in developing countries with high energy needs that, according to the annual Corruption Perceptions Index of Transparency International, present a high risk of corruption, Metlen may be exposed to facilitation payments or other benefits to local partners, in order to pursue the unimpeded operation of its projects. Any deviation from the Company's principles and ethical practices endangers the good reputation, credibility, trust of social partners and, by extension, its financial results and ability to undertake projects.

• Metlen conducts an annual Enterprise Risk Management study related to potential corruption and bribery risks.
• In countries with a high corruption risk, the Company has a Grievance Mechanism in place.
• In 2021, Metlen Compliance Division issued a Conflict-of-Interest Policy for employees and business partners.
• The Company ensures the systematic training of staff by category of exposure to regulatory risk in matters of the Code of Conduct.

• 0 (zero) confirmed incidents of corruption, Through the control mechanisms applied in the Purchasing–Procurement Departments of the Business Units.
• The Metallurgy BU of Metlen has no production activity in the 20 countries with the worst ranking according to Transparency International.
• 0 (zero) incidents of political contributions to political parties or persons.
• Α Compliance and Data Protection risk assessment is conducted every year.