Anti-Bribery & Anti-Corruption Policy

Zero-tolerance statement

GW LASER TECHNOLOGY S.R.L., hereinafter Uzinex, categorically and unreservedly declares that it adopts a policy of zero tolerance towards any form of bribery, corruption, influence peddling, facilitation payments, illegal favouritism or the obtaining of advantages by improper means, regardless of their value or context. This policy applies to all employees, managers, directors, consultants, representatives, agents, suppliers, subcontractors, commercial partners and any other persons acting on behalf of or for the benefit of Uzinex, in all jurisdictions in which the company operates. Integrity is a fundamental value of Uzinex and is not subject to compromise, regardless of commercial pressures or any loss of business.

Legal framework and applicable standards

Uzinex's policy is aligned with the following legal instruments and international standards: (1) Law No. 78/2000 on preventing, discovering and sanctioning acts of corruption in Romania; (2) the Romanian Criminal Code, in particular Art. 289-292 on corruption offences; (3) Law No. 161/2003 on measures to ensure transparency in the exercise of public office; (4) Law No. 571/2004 on the protection of public-authority personnel who report breaches of the law (whistleblower protection); (5) the National Anti-Corruption Strategy periodically adopted by the Romanian Government; (6) the UK Bribery Act 2010 — one of the strictest anti-bribery laws in the world, with extraterritorial applicability; (7) the US Foreign Corrupt Practices Act (FCPA) — applicable to companies with links to the USA; (8) the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions; (9) the UN Convention against Corruption (UNCAC); (10) the Council of Europe Criminal Law Convention on Corruption; (11) the EU public procurement directives (2014/24/EU, 2014/25/EU) which include anti-corruption provisions; (12) the ISO 37001:2016 standard on anti-bribery management systems.

Essential definitions

• —Bribery — offering, promising, giving, requesting or accepting, directly or indirectly, any undue advantage (money, goods, services, favours, positions, opportunities) to or from a person, in order to influence an official or commercial decision.
• —Corruption — abuse of entrusted power for personal gain or an undue advantage for third parties.
• —Influence peddling — the act of a person who, having real or claimed influence over an official, requests, receives or accepts money/other benefits to cause that official to perform, not perform, expedite or delay the performance of an act within their duties.
• —Facilitation payments (speed money, grease payments) — small payments to public officials to speed up routine administrative procedures (issuing a permit, processing documents). Even if accepted in some jurisdictions, Uzinex categorically prohibits them.
• —Illegal favouritism — granting unjustified advantages to persons or entities based on personal, political or business relationships, to the detriment of fair competition.
• —Conflict of interest — a situation in which the personal interests of a Uzinex employee or representative may influence the objectivity of their professional decisions.
• —Money laundering — the process by which funds obtained from illegal activities are made to appear legitimate through financial transactions.

Strictly prohibited behaviours

• —Offering or promising money, goods or favours to Romanian or foreign public officials, in order to influence a commercial, administrative or public-procurement decision.
• —Offering unjustified gifts or hospitality to representatives of clients, suppliers or authorities, which could create obligations or be perceived as bribery.
• —Accepting payments, commissions or personal benefits from suppliers, subcontractors or partners, in exchange for awarding contracts or other decisions.
• —Facilitation payments, regardless of their value or apparent justification.
• —Disguised sponsorships or donations aimed at obtaining an unjustified commercial advantage.
• —Engaging intermediaries (agents, consultants, lobbyists) without carrying out appropriate due diligence on their integrity.
• —Using corporate vehicles (offshore companies, opaque transactions) to conceal real beneficiaries or to evade controls.
• —Undeclared conflicts of interest — employees are obliged to report any situation that could create the appearance of a conflict.
• —Financing political parties or individual politicians, on behalf of or from the resources of Uzinex, without express approval and transparent registration.
• —Using Uzinex facilities, resources or information for personal purposes or to obtain unjustified advantages.

Gifts, hospitality and corporate events

Uzinex recognizes that offering symbolic gifts and reasonable hospitality is a normal practice in business relationships. However, to prevent any confusion with bribery, the following strict rules apply: (1) Gifts and hospitality must be reasonable in value (the indicative limit is EUR 100 per occasion, per person), occasional and aligned with legitimate industry practices; (2) They must be linked to clear business purposes — product presentations, industrial events, inaugurations; (3) They must be transparent — declared to direct managers and recorded in the gift register when they exceed the symbolic value; (4) They must not be offered with the aim of influencing a specific decision or during an active public-procurement procedure; (5) Gifts to public officials are allowed only in exceptional cases (promotional souvenirs of minimal value) and must be approved in advance; (6) Cash, cash equivalents (uncontrolled gift cards, cheques), unjustified tourist trips or high-value vouchers are strictly forbidden as a form of gift or hospitality.

Public procurement, SEAP/SICAP and relations with the state

Given that Uzinex frequently participates in public procurement procedures through SEAP and SICAP and works with state institutions on EU-funded projects (PNRR, POIM, POCU) and with the defence sector, we apply the strictest integrity standards in this area: (1) We fully comply with Law No. 98/2016 on public procurement and Law No. 99/2016 on sectoral procurement; (2) We do not offer any kind of unjustified advantage to members of evaluation committees, public officials or representatives of contracting authorities; (3) We do not participate in cartel-type arrangements with other bidders to distort competition; (4) We do not accept requests for informal payments, commissions or other forms of remuneration outside the contract; (5) We fully document all interactions with contracting authorities and maintain the traceability of decisions; (6) If we identify suspicions of corruption within a procedure, we report to the competent authorities (ANAP, DNA, ANI, Court of Accounts) and cooperate with investigations; (7) For EU-funded projects, we additionally comply with the specific rules on conflicts of interest, publication of beneficial-owner data and fraud prevention (OLAF).

Third-party due diligence

Uzinex carries out reasonable due diligence before initiating commercial relationships with third parties that could represent a corruption risk: (1) Verifying the identity, history and reputation of the potential partner through open sources (ONRC, ANAF, SEAP, press, public registers); (2) Checking international sanctions lists (OFAC, EU Sanctions Map, UN Sanctions); (3) Assessing beneficial ownership (Ultimate Beneficial Owner) to identify the persons with real control; (4) Analysing political exposure (Politically Exposed Persons — PEP); (5) Checking for prior judicial issues related to corruption or fraud; (6) Strict contractual anti-bribery clauses and Uzinex's right to terminate immediately in the event of a breach; (7) Continuous monitoring of strategic partners, with periodic reassessment; (8) Avoiding relationships with intermediaries who do not provide real, substantial and verifiable services.

Reporting mechanism — the anti-corruption line

Uzinex has implemented a confidential reporting system for suspicions of bribery, corruption or other ethical misconduct. Any employee, partner, client, supplier or third party can report suspicious situations via: (1) A dedicated email — info@uzinex.ro with the subject [WHISTLEBLOWER] or [ANTICORRUPTION]; (2) Phone — (+40) 769 081 081, requesting a confidential discussion; (3) In writing, by post to the company's registered office; (4) Directly to managers, compliance officers or company leadership. All reports are: treated with absolute confidentiality, investigated professionally and objectively, and followed by concrete actions when the identified issues are confirmed. Uzinex guarantees the protection of whistleblowers against any form of retaliation, dismissal, demotion, discrimination or other negative consequences, in accordance with Law No. 571/2004 and EU Directive 2019/1937 on the protection of persons who report breaches of EU law.

Investigating reports and disciplinary measures

• —Any report received is registered and assigned to an independent investigation team, made up of persons with no conflicts of interest in that case.
• —The investigation is carried out with objectivity, speed and respect for the rights of all parties involved.
• —Documentary evidence is collected, interviews are conducted with witnesses and the persons concerned, and the relevant financial transactions are analysed.
• —The conclusions of the investigation are documented in a confidential report presented to management.
• —Disciplinary measures may include: warning, suspension, dismissal, termination of commercial contracts, civil action to recover damages, notification of the competent authorities (DNA, DIICOT, Prosecutor's Office, ANI) in the case of criminal offences.
• —Major findings are reported to management and, where appropriate, integrated into the annual compliance reports.

Training and organizational culture

Uzinex invests continuously in training employees on ethics and anti-corruption: (1) Mandatory training in the onboarding process for all new employees; (2) Annual refresher sessions for all staff, with case studies and practical exercises; (3) Specialized training for people in higher-risk roles (sales, procurement, relations with authorities); (4) E-learning modules available at any time, with certification; (5) Constant internal communication through newsletters, posters, team meetings; (6) Integration of anti-corruption principles into the company's code of conduct; (7) Cultivating a culture in which ethics is discussed openly and employees feel encouraged to raise questions or report concerns without fear.

Transparent financial management

• —All financial transactions are recorded fully, correctly and on time in the accounting records, in accordance with the law.
• —There are no parallel, off-the-books bank accounts or undeclared funds.
• —Payments are made only through official banking channels, with complete supporting documentation.
• —Representation expenses, gifts and hospitality are declared separately and approved in accordance with the internal policy.
• —Internal and external audits periodically verify compliance with the anti-corruption policy.
• —We work closely with authorized accountants, financial auditors and tax consultants to ensure traceability.

Sanctions for breaching the policy

Any breach of this policy is considered a serious offence and attracts sanctions proportionate to the gravity of the act: (1) For employees — disciplinary measures under the Labour Code, from a written warning to disciplinary termination of the employment contract; (2) For suppliers, subcontractors or partners — immediate termination of contracts, exclusion from the lists of authorized partners, recovery of the damage caused; (3) Civil action to recover the material and moral damage suffered by Uzinex; (4) Notification of the competent authorities (DNA, DIICOT, General Prosecutor's Office, ANI, Court of Accounts) for criminal investigation; (5) Publication of information about the breach when transparency is required by law or the public interest. No person, regardless of their position within the company or the importance of the commercial relationships, is exempt from the application of sanctions.

Responsibilities and governance

The application of this policy is the responsibility of all Uzinex employees and partners, but ultimate responsibility rests with executive management. The company's administrator ensures: (1) The approval and updating of the anti-bribery and anti-corruption policy; (2) The allocation of the resources needed for implementation (staff, training, systems); (3) The monitoring of application through periodic reports; (4) The firm sanctioning of any breaches; (5) The public communication of the company's commitment to integrity. A Compliance Officer coordinates the day-to-day activities related to prevention, training, investigation and reporting.