ANTI-CORRUPTION POLICY

1. Introduction

Artema Concept adopts a zero-tolerance policy towards any form of corruption, bribery, fraud, favoritism or abuse of power. We are committed to conducting all our activities in an ethical, legal and transparent manner, in accordance with the highest international standards of professional integrity.

This policy is based on:

• UN Convention against Corruption (UNCAC);

• Principle 10 of the UN Global Compact:
  "Businesses must fight corruption in all its forms, including extortion and bribery" ;

• OECD Recommendations on Business Ethics;

• Romanian Criminal Code – art. 289–294 regarding corruption crimes.

---

2. Scope

This policy is mandatory for:

• Artema Concept employees and collaborators;

• Members of the management team;

• Suppliers, subcontractors, distributors and consultants involved in commercial relations with the company;

• Any partner acting on behalf of or for the benefit of Artema Concept.

---

3. Definitions and prohibited forms of corruption

3.1 Corruption

Corruption is any act by which a person offers, promises, requests or accepts an undue advantage to influence a decision, action or outcome.

3.2 Bribery

It is prohibited:

• Offering money, gifts, favors, services, travel or sponsorships in exchange for an advantage;

• Requesting or accepting these advantages in the exercise of professional duties;

• Involving intermediaries (agents, relatives, front companies) to mask such facts.

3.3 Conflicts of interest

• Conflicts of interest must be declared and resolved;

• Preferential contracts and non-transparent hiring are prohibited.

3.4 Abuse of influence and influence peddling

• The use of function, position or relationships to obtain undue advantages for oneself or others is not tolerated.

---

4. Preventive measures

• Signing of an Integrity Commitment by all employees and suppliers;

• Introducing anti-corruption clauses in all commercial contracts;

• Annual team training on identifying, preventing and reporting corruption risks;

• Legal and reputational verification of suppliers before contracting;

• Limiting cash in activities and documenting all payments;

• Clear separation of decision-making and approval responsibilities.

---

5. Reporting channels and corrective measures

Any suspicion of corruption can be reported to:

• etica@artema-concept.com (confidential address);

• Directly to the founder or the integrity officer.

• All reports are investigated internally with the utmost seriousness;

• Sanctions proportional to the seriousness of the act are applied: warning, contract termination, notification to authorities;

• Whistleblowers benefit from full protection against retaliation.

---

6. Monitoring and accountability

• The policy is communicated annually to all parties involved;

• It is integrated into onboarding and all internal ethics manuals;

• The review is carried out annually or whenever legislative changes occur;

• Elena Artene, as founder, is responsible for overseeing this policy.

---

Last revised: June 2025
Responsible: Elena Artene – Founder of Artema Concept
Date: June 2025