Introduction to the Thule Group policy about Anti-Corruption

Corruption is a broad concept and many different definitions exist. Generally, the term is associated with the giving and taking of bribes. Anti-bribery laws work against corruption by criminalizing bribery and undue influence from being directed against someone who has been entrusted to act on behalf of others – may it be on behalf of individuals, corporate entities, organizations, judicial or governing bodies, agencies or municipalities, or the society at large.

This manual applies to everyone at the Company – all employees, managers, executive officers, and members of the board of directors (all of whom are included in the term “employees” as used in the remainder of this manual).

With regard to business partners, this manual applies to those who represent the Company or act on its behalf, such as consultants, agents and certain service providers and suppliers. This manual does not apply to business partners acting independently of the Company.

Executive Summary

• It is strictly forbidden to directly or indirectly offer, promise, grant, or authorize the giving of money or anything of value to someone in order to unduly influence the performance of the recipient’s (or someone else’s) professional duties or to obtain or retain an undue business advantage.

• Extra care must be taken when interacting with representatives of the public sector and in relation to public procurement and governmental decision making. Benefits should never be offered to public sector representatives, their associates, or any other party with the intent of influencing an award of a bid or any other decision.

• Adequate third party risk assessment procedures and contractual warranties are required to mitigate anti-bribery risks.

• Violations of anti-bribery laws can result in substantial monetary penalties, imprisonment, and severe reputational harm to the Company.

• Contact the Anti-corruption Compliance Officer if ever in doubt about whether a specific benefit such as a meal, gift, event, or similar benefit is permissible.