DKC PO2 Anti corruption policy

DKC PO2 Anti corruption policy_2025Valid for: Approved by Created by Document no. Version Date DK Company A/S RASJ CSR RASJ CSR DKC PO2 2 12.08.2025 Anti-Corruption Policy Introduction Acting responsibly and with integrity is at the core of DK Company. We are committed to conducting our business in an honest, ethical, and transparent manner in all our dealings and relationships wherever we operate. This policy is anchored in a zero-tolerance approach to corruption and bribery. It defines our position on:  Bribery and facilitation payments  Gifts and hospitality  Conflicts of interest  Antitrust and competition law  Books and records  Non-retaliation and reporting We require compliance with all applicable anti-bribery and anti-corruption laws and regulations, including but not limited to:  U.S. Foreign Corrupt Practices Act (FCPA)  UK Bribery Act 2010 (UKBA)  Relevant Danish and EU legislation  Any other applicable national anti-bribery laws where DK Company operates This policy applies to all employees of DK Company and its subsidiaries, regardless of position, location, or type of employment. It also applies to third-party partners, intermediaries, and any person acting on behalf of DK Company. Bribery and facilitation payments  DK Company strictly prohibits any form of bribery.  No one may offer, promise, give, or accept money or anything of value—directly or indirectly via third parties—to improperly influence a decision.  This prohibition applies to both public officials and individuals in the private sector.  Facilitation payments ('grease' or 'speed' payments) to expedite routine services to which we are legally entitled are not allowed, even if customary locally. Gifts    and Hospitality (Meals and Entertainment) We do not offer, give, or accept gifts, entertainment, or hospitality if they: o Exceed local triviality limits o Are unrelated to a legitimate business purpose Such gestures must: o Be reasonable, proportionate, and infrequent o Be made in good faith, without any obligation or expectation o Comply with legal requirements and DK Company’s internal guidelines All gifts and hospitality must be connected to a business interaction and documented where possible. 1Side 2