7. Anti-Corruption and Bribery Policy

PURPOSE AND IMPORTANCE

Aluminij Industries (hereinafter: “Aluminij” or “we”/“us”/“our”) is committed to upholding the highest standards of integrity and ethical business conduct. Corruption and bribery are serious threats to fair competition, trust, and sustainable development, and they pose significant risks to our company’s reputation and operations.

This Policy sets out Aluminij’s zero-tolerance approach to bribery and corruption and provides guidance to all employees and business partners on how to recognize, prevent, and report such risks. By fostering a culture of compliance and accountability, we aim to protect our stakeholders and ensure long-term business sustainability.

SCOPE

This Policy applies comprehensively to Aluminij, including all employees, officers, contractors, consultants, agents, suppliers, vendors, business partners, and any other third parties acting on behalf of or in the interest of the Company. It covers all business activities conducted both domestically and internationally.

Aluminij requires full compliance with this Policy in all interactions with public officials, private sector entities, and third parties, regardless of local customs or business practices. The Policy aligns with applicable anti-corruption legislation in Bosnia and Herzegovina as well as internationally recognized standards and frameworks.

To ensure effective implementation, Aluminij carries out regular and systematic risk assessments of bribery and corruption vulnerabilities across its operations, supply chains, and partnerships. Results of these assessments inform ongoing improvements to our internal controls, training programs, and reporting mechanisms.

All personnel and partners must act in accordance with this Policy to prevent, detect, and respond promptly to any suspected or actual corrupt practices, fostering a culture of transparency, integrity, and accountability throughout the organization.

CORRUPTION RISK ASSESSMENT

Aluminij conducts regular corruption risk assessments across all business functions and operational processes within the company, with particular focus on interactions with external partners and public institutions.

The objective of these assessments is to identify, analyze, and mitigate corruption-related risks associated with bribery, conflicts of interest, undue influence, and facilitation payments—especially in higher-risk functions such as procurement, licensing, international business, and government-facing operations.

The risk assessment process includes:

• Identification of internal processes and external relationships with elevated corruption risk;
• Due diligence and evaluation of third parties (e.g., suppliers, agents, international partners);
• Review of internal controls and any past incidents of non-compliance;
• Documentation of findings and implementation of risk mitigation measures.

Risk assessments are conducted at least once every two years, or more frequently under the following circumstances:

• Entry into new markets or expansion of international operations;
• Engagement with new high-risk third parties or public entities;
• Significant changes in anti-corruption laws or regulations in Bosnia and Herzegovina or other relevant jurisdictions;
• Internal or external audit findings indicating heightened exposure to corruption risk.

All findings are recorded in the company’s internal compliance reports and reviewed by the Compliance Officer. The results are used to inform internal policies, training programs, and control mechanisms aimed at strengthening Aluminij’s anti-corruption framework.

PROHIBITED CONDUCT

Bribes or other improper or unauthorized payments - whether in cash or in kind - are prohibited. This includes:

• Promising, offering, or giving money or anything of value to public officials, political figures, or private individuals to secure or retain business or gain any improper advantage;
• Any form of “facilitation payments” or kickbacks;
• Making or authorizing “facilitation payments” to expedite routine governmental actions, which are explicitly prohibited under this Policy;
• Providing gifts, entertainment, hospitality, or other benefits that may influence a decision improperly or create the appearance of impropriety;
• Use of third-party intermediaries to channel bribes or conceal improper payments.

INDICATORS OF CORRUPTION RISK

Employees must be alert to situations that may involve corruption, including:

• Unusually high or unexplained commission payments;
• Requests for cash payments;
• Involvement of politically exposed persons (PEPs) without clear business rationale;
• Lack of transparency in vendor selection or procurement;
• Pressure to hire or retain consultants without clear deliverables;
• Third parties who refuse to disclose beneficial ownership or prior clients.

This list is non-exhaustive. Identified risks are recorded and addressed in Aluminij’s annual compliance and risk reports.

GIFTS, HOSPITALITY AND ENTERTAINMENT

Gifts or hospitality may be offered or received only if they are:

• Of nominal and reasonable value;
• Given in good faith and not intended to obtain or retain business.

Employees must consult with their immediate supervisor or Compliance Officer when in doubt.

TRAINING AND AWARENESS

Aluminij provides mandatory anti-corruption training to all employees upon hiring and at least annually thereafter, including tailored sessions for high-risk functions such as procurement, sales, and government relations.

Training records are maintained and periodically reviewed to ensure awareness and effectiveness.

REPORTING AND WHISTLEBLOWING

Violations or suspected breaches of this Policy must be reported immediately to the Compliance Officer or via the confidential whistleblowing channel.

Reports may be submitted anonymously, and Aluminij strictly prohibits any form of retaliation against whistleblowers acting in good faith.

ENFORCEMENT AND SANCTIONS

Failure to comply with this Policy may result in:

• Disciplinary measures, including suspension or termination;
• Civil or criminal liability for individuals and the company;
• Termination of contracts or relationships with third parties in breach of anti-bribery commitments.

POLICY REVIEW

This Policy is reviewed at least once every two years, or sooner in case of:

• Changes in legislation or regulatory requirements;
• Expansion into new markets or high-risk jurisdictions;
• Findings from internal audits or external reviews.

The results of the policy review and any necessary updates are documented and communicated to all relevant stakeholders.