SCHREDER - Sustainability Report 2023

Company Information

Competition Law Policy Competition is vital. It enables businesses to compete on a level playing field in the market, while constantly striving to offer customers the best possible products at the best possible prices. Competition stimulates Schréder’s drive for innovation and long-term economic growth. Schréder promotes fair competition and encourages its employees and intermediaries to play by the rules. Our Competition Law Policy sets out competition rules for doing business with suppliers, distributors and customers, as well as our dealings with competitors and trade organisations. Competition risks are regularly assessed, identified and effectively managed. Policies are in place to minimise these risks and to mitigate their impact. Regular and mandatory training is provided throughout the organisation to raise awareness on this important topic. Fraud and Corruption Fraud and corruption undermine fair trade and equal treatment of business partners. Most countries have anti-fraud and anti-corruption laws. Violations of these laws and regulations are not only contrary to our principles and values but can also affect the company’s reputation and result in significant civil and criminal penalties. Schréder is committed to conducting business in an honest and ethical manner. We condemn any form of fraud or corruption at all levels of the company. Our Anti-Bribery and Anti- Corruption (ABC) policy is designed to ensure that all employees always maintain the highest standards of professional and personal behaviour and avoid any form of fraud or corruption, or the appearance thereof.

In our ongoing efforts to uphold these standards, we conduct thorough due diligence on all intermediaries and partners in our supply chain. Since 2020, this due diligence process has been applied to all commercial intermediaries within our Group. As of 2023, we have expanded this process to include our local supply chain partners, demonstrating our commitment to ethical business practices throughout our operations. Data Protection Since the implementation of the GDPR in 2018, Schréder has proactively undertaken numerous initiatives to ensure compliance with Personal Identifiable Information (PII) laws. These efforts include the publication of information notices, staff training, and the establishment of a register of processing activities. In 2022, recognising the dynamic digital landscape of its environment, particularly in the realm of smart cities, Schréder embarked on a new programme called Priva-see. This initiative adopts a more structured approach to PII law compliance. Inspired by the ISO 27701 standard, the programme Priva-see introduced additional measures throughout 2023. These included the appointment of a Data Protection Programme Manager, active engagement and sponsorship from top management, development of digital registers of processing activities, implementation of risk management strategies encompassing DPIAs (Data Protection Impact Assessments) and TIAs (Transfer Impact Assessments), customisation of documentation and agreements to address Schréder’s supply chain management, and revision of data protection policies and training programmes. These comprehensive measures have significantly enhanced the transparency of personal data flows across the entirety of Schréder’s organisational

framework. It complements Schréder’s data protection compliance journey, along with Schréder’s ISMS (information security management system) and ISO27001 certification. Policy on Policies Schréder has adopted a new Policy on Policies in its commitment to ethical governance. This framework ensures clarity, consistency, and compliance in the development and management of corporate policies. This initiative strengthens Schréder’s governance structure, driving performance and long-term value creation. The Policy on Policies has been implemented in four key departments: IT, Legal, People, and Finance. This initial rollout sets the foundation for future integration across additional departments. Human Rights Policy In 2023, Schréder launched its Human Rights Policy. This policy underscores Schréder’s dedication to upholding fundamental human rights principles across all aspects of its operations, supply chain, and interactions with stakeholders. By embracing this policy, Schréder aims to integrate respect for human rights into its corporate culture, policies, and procedures. This proactive initiative highlights Schréder’s responsibility to respect, protect, and promote human rights, thereby contributing to positive impacts on the communities and environments in which it operates.

16.5 - Substantially reduce corruption and bribery in all their forms.

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