Table of contents
Company Information
Whistleblowing and Speak-up Mechanisms Employees and external stakeholders are encouraged to report any concerns related to potential violations of the Code of Conduct, internal policies or applicable laws. Concerns can be raised through various internal channels including line management, the People & Culture department, the Legal department, WIN/ Compliance or Group Internal Audit department. For individuals who prefer to remain confidential or anonymous, Schréder provides the WIN Line: an independent reporting platform accessible via a secure website and dedicated phone lines. All reports are handled confidentially and investigated in accordance with established procedures. Individuals who report concerns in good faith are protected from retaliation. The WIN Line is embedded within Schréder’s governance framework and referenced in key policies, including the Code of Conduct, the Supplier Code of Conduct, the Anti-Bribery and Anti- Corruption Policy, the Human Rights Policy and the Sustainable Procurement Policy.
Prevention and Detection of Corruption and Bribery Schréder applies a zero-tolerance approach to bribery, fraud and corruption. These risks were identified as material governance topics through the Double Materiality Assessment due to their potential impact on fair competition, business integrity, and the Group’s legal and reputational exposure. The Anti-Bribery and Anti-Corruption Policy, together with the Code of Conduct, provides the framework for ethical behaviour throghout the organisation. All employees, intermediaries and relevant business partners are expected to comply with these principles. Key elements of this framework include mandatory compliance training, periodic acknowledgement of the Code of Conduct and risk-based due diligence on third parties. Due diligence has been applied to intermediaries across the Group since 2020 and has been extended to suppliers through the Sustainable procurement framework. In 2025, Schréder reinforced its commitment by updating the Anti-Bribery and Anti-Corruption Policy, enhancing intermediary due diligence, and deploying a structured risk-scoring methodology for intermediaries and subsidiaries. A global e-learning programme available in eight languages achieved an 87% completion rate. In collaboration with the Legal, Sourcing and Internal Audit teams, Schréder continues to strengthen the prevention, monitoring and management of integrity risks through the WIN programme.
Incidents of Corruption or Bribery Schréder monitors potential incidents of corruption, bribery and other breaches of business conduct through its compliance processes, internal controls and reporting channels, including the WIN Line. Reports are assessed and investigated in accordance with established procedures, and appropriate corrective actions are implemented where necessary. In 2025, Schréder did not record any material confirmed incidents of corruption or bribery requiring public disclosure. Fair Competition Schréder is committed to fair and open competition in all of the markets in which it operates. The Competition Law Policy sets out how the company should interact with suppliers, customers, competitors and trade associations and is embedded in the Group’s governance and compliance framework. In 2025, awareness and compliance were reinforced through targeted initiatives including Legal Coffee Break sessions for European entities and legal guidance for sales teams, as well as raising awareness of dawn raid procedures. This was supported by the deployment of local guidance for employees. Competition-related risks are monitored through the WIN programme and supported by legal reviews, training and internal controls. Data Protection Since the implementation of the General Data Protection Regulation (GDPR) in 2018, Schréder has proactively undertaken numerous initiatives to ensure compliance with the law on Personally
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