Anti-Bribery and Corruption Policy

It is our policy to conduct our business in honest and ethical manner and in compliance with applicable legislative. We take zero tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business relationships regardless of who our business partner is.

Legal or physical persons acting on behalf of Gorenje may not act corruptly in our dealings with any other person. In case the act of non-compliance with Policy represents a criminal act, the employee or business partner may face criminal prosecution.

Our Anti-Bribery and Corruption Policy is made available to all our employees and business partners. Policy implementation is regularly monitored and encouraged. The Anti-Bribery and Corruption Policy is published and accessible through the Group website. Policy is not a part of any formal contracts and we may change and amend it at any time.

Policy applies to all persons that are in any kind of business relation with Gorenje, to all persons working for us and on our behalf, including all our employees at all levels (full or part time), directors, trustees, officers, agency workers, interns, agents, contractors, external consultants, third party representatives, business partners and other persons related to our company regardless of their location or nature of their activities or place of performing their operations.

Bribe means a financial or other inducement or reward by action, which is illegal, unethical or represents breach of trust in any improper way. Bribes can take many forms, for example: money (or cash equivalent like shares, cryptocurrency), unreasonable gifts, entertainment or hospitality in extended form, loans, fees, rebates or commissions (for example to sales or marketing agents), services, the award of a contract or any other advantage or benefit that is intended to influence a decision or action.

Bribery includes giving, offering, promising, seeking or accepting a bribe with the goal of inducement or reward the performance of activities, responsibilities and duties inappropriately.

Corruption means any form of abuse of power or position for business and/or personal gain and may include but is not limited to bribery. Represents any breach of the duty of responsibility of the responsible persons, as well as the conduct of the persons who are the initiators of the breach or the persons who can benefit from the breach, for the purpose directly or indirectly promised, offered or given, or claimed, accepted or expected benefits for themselves or for others.

All forms of bribery and/or corruption are strictly prohibited and are not tolerated by Gorenje. Not only giving or receiving a bribe, but also any related activity, such as a promise or agreement to give or receive a bribe, is considered an act of corruption.

Policy does not prohibit the giving or receiving reasonable and appropriate acts of hospitality or gifts for legitimate purposes such as binding relationships, managing the company’s image or reputation or marketing company’s products or services.

Gifts and hospitality should be such of general purpose, reasonable and given or accepted in the ordinary course of business and must comply with local laws. All gifts which are given are given in the name of Gorenje, not in the name of an individual. Giving and receiving gifts or hospitalities should be avoided when conducting final stages of negotiations, signing contracts or similar decision making activities.

Gifts must be of appropriate value and type, depending on the circumstances and taking into account the reason of the gift. A gift must never include cash or cash equivalent, neither can cash or equivalent be given or taken in secret.

Promotional gifts of low value such as branded materials like stationery, may be given or accepted by existing or potential customers, suppliers and business partners.

Where local law, regulations or standards, apply and require more stringent processes/ controls, then such more stringent processes/ controls are followed.

To be transparent, Group keeps records of any hospitalities and gifts given or received. This records may be disclosed to owners, regulators and other stakeholders.

If anyone offers a bribe to an employee or asks for a bribe, or if a bribe, corruption or violation of this Policy is suspected, the employee is required to notify their compliance manager.

In the event of uncertainty as to whether certain acts may constitute acts of bribery or corruption, the Chief Compliance Officer shall provide an appropriate response.

Chief Compliance Officer contacts:

Chief Compliance Officer

Gorenje, d. o. o., Partizanska cesta 12

3320 Velenje, Slovenia

cco@gorenje.com