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528 – Gifts & Hospitality Policy

1. Purpose

528 is committed to conducting business with integrity, transparency, and fairness.

This Gifts & Hospitality Policy defines clear rules and monetary limits for offering or accepting gifts,

hospitality, and other advantages in order to:

• Prevent bribery, corruption, and undue influence

• Protect employees from ethical pressure

• Safeguard the reputation and independence of 528

• Ensure compliance with applicable anti-corruption legislation and EcoVadis requirements

2. Scope

This policy applies to:

• All employees and management of 528

• Temporary staff, consultants, agents, and intermediaries acting on behalf of 528

• Interactions with customers, suppliers, distributors, business partners, and public officials

It covers all forms of gifts and hospitality, whether provided directly or indirectly.

3. Definitions

4. General Principles

All gifts and hospitality must meet all of the following conditions:

• Legitimate business purpose

• Reasonable, proportionate, and infrequent

• Transparent and openly declared where required

• Not intended to influence or reward a business decision

• Compliant with this policy and applicable law

If any of these conditions are not met, the gift or hospitality is not permitted.

5. Monetary Limits (Defined Thresholds)

5.1 Acceptable Gifts (Non-Cash)

5.2 Hospitality (Meals, Drinks, Events)

5.3 Gifts & Hospitality Above Threshold

Any gift or hospitality exceeding the limits above:

• Requires prior written approval from management

• Must be recorded in the Gifts & Hospitality Register

• Must be demonstrably linked to a legitimate business purpose

6. Strictly Prohibited Practices

The following are strictly prohibited, regardless of value:

• Cash or cash equivalents (gift cards, vouchers, cryptocurrencies)

• Gifts or hospitality linked to contract awards, pricing decisions, or exclusivity

• Personal services or benefits (travel upgrades, accommodation, private use)

• Gifts during tender, bidding, or contract-renewal phases

• Any gift or hospitality intended to create a sense of obligation

7. Public Officials – Zero Tolerance Standard

Gifts or hospitality involving public officials are subject to stricter rules:

• Gifts to public officials are not permitted, except for low-value promotional items (< €25) and only

where legally allowed

• Hospitality for public officials requires prior written approval from management

• Cash, travel, accommodation, or entertainment for public officials is strictly prohibited

8. Giving Gifts & Hospitality on Behalf of 528

When offering gifts or hospitality on behalf of 528:

• Employees must comply with local laws and the recipient’s internal policies

• The gift or hospitality must reflect 528’s premium yet ethical brand values

• Company funds may never be used for personal benefits

9. Declaration and Registration

528 maintains a Gifts & Hospitality Register.

Employees must declare:

• Any received or offered gift close to or above the defined thresholds

• Any situation that may give rise to perceived conflicts of interest

The register includes:

• Date

• Parties involved

• Description and estimated value

• Approval (if required)

10. Handling Unacceptable Gifts

If an employee receives an unacceptable gift:

• Politely refuse and explain this policy, or

• If refusal is not possible, immediately inform management

• Management will decide on return, donation, or neutral handling

11. Responsibilities

12. Reporting and Whistleblowing

Any suspected violation of this policy must be reported via:

• The designated whistleblowing channel

• Management or a trusted contact

Retaliation against individuals raising concerns in good faith is strictly prohibited.

13. Sanctions

Violations of this policy may result in:

• Disciplinary measures

• Termination of employment or contract

• Legal action where applicable

14. Final Provision

This Gifts & Hospitality Policy supports 528’s commitment to ethical business conduct, transparency,

and long-term trust with customers, partners, and society.

When in doubt: do not accept or offer — ask first.

15. Review

This policy will be reviewed annually or when:

• There are changes in regulations or standards

• Incidents indicate the need for revision