TAB GROUP ANTI-BRIBERY AND CORRUPTION POLICY

The Company undertakes to execute the anti-bribery policy that includes procedures, administrativeprocesses, training, guidance, and control. The essence of the undertaking is that the Company ensures the lawfulness of operation, which makes the Company anti-corruption policy an integral part of daily practice.

Any form of bribery shall be strictly prohibited. Bribery is direct or indirect promising, offering, or giving of any undue benefit to

• a public employee,
• a political candidate, political party, or party official, or
• any employee (including a person who manages or works for a private firm, regardless of his or her function within the firm), and to request or accept any such undue benefit from the
  above-indicated persons in order to obtain, maintain, or manage a transaction, or ensure any other
  inadmissible business benefit.

The Company prohibits bribery in all transactions performed directly or through third parties, which specifically includes subsidiaries, joint ventures, agents, representatives, advisers, brokers, contractors, suppliers, or any other intermediaries under the effective control of the Company.

The Company prohibits bribery in any form, including bribery related to a contractual payment or a part of acontractual payment, or in any manner or by any means used to provide inadmissible benefits to its customers, agents, contractors, suppliers, or employees.

The system is established according to the international standard ISO 37001 anti-bribery management systems setting out guidelines for the establishment, introduction, maintenance, review, and improvement of the anti-corruption management system.

The Company, its employees, or agents may not give direct or indirect contributions to political parties, political party officials, candidates for political office, political organisations or individuals engaged in politics, as a pretext for bribery.

All political contributions should be transparent and in accordance with the applicable legislation.

The Company should ensure that charitable contributions and sponsorship are not used as a pretext for bribery. All charitable contributions and sponsorship should be transparent and in accordance with applicable legislation.

Prior to the appointment of a representative, consultant, or other agent, the Company shall carry out due diligence, where the circumstances so warrant.

Prior consent of the senior management shall be obtained for all agreements with representatives, consultants, or other agents.

Compensation for representatives, consultants, or other agents should be a reasonable and justifiable payment for provided legal services, and must be paid in good faith.

The Company shall monitor the behaviour of its representatives, consultants, or other agents, and shall have a contractual right to terminate the contract when their behaviour fails to comply with the anti-bribery policy.

The Company shall implement its procurement procedures fairly, and in transparent manner. In assessingcontractors, subcontractors, and suppliers, the Company should, if necessary, conduct due diligence to ensure that they have established effective anti-bribery policies.

Prior to the appointment of a representative, consultant, or other agent, the Company shall carry outdue diligence, where the circumstances so warrant.

The Company shall ensure that internal control systems, in particular accounting and bookkeeping practices, are subject to regular audits.

Company employees are expected to draw attention to cases at issue as soon as possible, and report suspicious circumstances to the competent employees of the Company.

The Company shall ensure safe and accessible channels through which employees and others can draw attention to cases at issue, and report suspicious circumstances (“whistleblowing”) in confidence and without the risk of retaliatory measures. The aforementioned channels should also be available for obtaining advice or making proposals on anti-bribery policies.

The employees and others may submit notifications on irregularities or non-conformities anonymously to the “WORKS COUNCIL” boxes, or e-mail them to the President of the Works’ Council at: matjaz.obretan@tab.si, or directly to the Legal Department: ales.horvatic@tab.si (tel.: 02 87 02 464). Please do not hesitate to contact the Legal Department for further clarification or to make suggestions regarding this Policy, or relevant laws and regulations.