Compliance and Whistleblowing

Consistent with its values of Respect, Responsibility, Stability and Courage, KKCG has a firm commitment to operating in an ethical and lawful manner. This non-negotiable commitment made by our senior leadership, with the support of our Founder and Chairman, applies to KKCG companies and staff worldwide. To support this commitment, KKCG has an established compliance program to ensure the group complies with all applicable laws and its own ethical standards. KKCG has a suite of policies to address bribery, anti-money laundering, fair competition, and other compliance topics.

Anti-Bribery and Corruption

KKCG believes that bribery undermines public institutions, distorts markets and harms society. For that reason, KKCG’s Anti-Bribery & Corruption Policy absolutely prohibits giving bribes to anyone; taking bribes from anyone; suggesting, proposing, requesting, offering, brokering, or handling bribes; and using other people to do any of the above. In this context, a bribe is anything given to someone to induce or reward the improper performance of a function or activity.

KKCG takes active steps to exclude bribery from its business. Specifically, KKCG trains staff on how to recognize and prevent bribery; chooses business partners that share its commitment to anti-bribery; makes political donations only when it is lawful and appropriate to do so; and does not use its Social Responsibility activities to achieve commercial objectives. KKCG encourages the raising of concerns (see “Questions, Concerns and Whistleblowing” below), and responds swiftly to concerns once they are raised. Click here to read an abridged version of our Anti-Corruption & Bribery Policy.

Questions, Concerns and Whistleblowing

KKCG staff and business partners can obtain advice on ethics or compliance issues from KKCG’s Compliance department, which can be contacted at [email protected].

KKCG Group's Whistleblowing System and the Internal Whistleblowing System of KKCG a.s.

KKCG Group actively encourages employees of its Group companies, including KKCG a.s., business partners, and members of all the communities in which it operates to utilize the internal whistleblowing system, established by KKCG a.s. in compliance with Act No. 171/223 Coll. on the protection of whistleblowers (so-called “Whistleblower Protection Act”) to report any concerns about potential unethical or illegal conduct in the business activities of individual KKCG Group companies.

**Reporting options ** • Use of an external online platform “FaceUp” by clicking on this link: (www.faceup.com/c/deoo3kdl) or by scanning the QR code:

The platform is available around the clock, allowing anonymous reports in written form and voice recordings. To submit a report via the FaceUp form, use also the code: 12aaque52C. After making a report, we recommend that you retain the twelve-digit access code, generated after the report was sent, for possible further communication.

• By contacting the designated competent person on the telephone number listed below during business hours from 9:00 a.m. to 5:30 p.m.

• In person with one of the designated persons listed in the subsequent paragraph, preferably following an appointment.

• Via a letter addressed to the designated person listed below at KKCG a.s., Evropská 866/71, 160 00 Prague 6. Please mark the envelope "DO NOT OPEN - WHISTLEBLOWING".

Designated persons in charge of follow-up on the report

• Petra Dolejšová, HR Business Partner at KKCG a.s., T: +420 775 877 179, E: [email protected]

• Filip Šúň, Compliance Officer of KKCG Group, T: +420 225 010 398, E: [email protected]

What to expect after notification

The designated person will issue an acknowledgement of receiving the report to the reporting person within 7 days of its receipt. Within 30 days of receiving the report, the reporting person will be informed of the assessment of the report and propose corrective actions. In complex reports that demand high time consumption for investigation, the period may be doubled to a total of 60 days.

Whistleblower protection

The whistleblower is protected from any retaliation under the Whistleblower Protection Act and his identity remains known only to the designated person in charge of investigating the case.

In addition to the Whistleblower Protection Act, KKCG and KKCG a.s. also accept reports that do not fall within the scope of the Whistleblower Protection Act, including anonymous reports. The whistleblowers need to submit their reports in good faith, based on credible facts and factual evidence. They must not deliberately submit false information through the internal whistleblowing system. Such unfounded reporting is not under the protection of ZOO and may result in a) disciplinary actions from the employer, or b) a potential fine of/up to CZK 50,000 in an administrative proceeding for committing an offence.

Reporting to the Ministry of Justice

A report of unlawful conduct can also be submitted through the reporting system of the Ministry of Justice of the Czech Republic, available at the following website: justice.cz/oznameni

Information on Personal Data Processing