ΠΟΛΙΤΙΚΗ ΚΑΤΑ ΤΗΣ ΔΩΡΟΔΟΚΙΑΣ ΚΑΙ ΤΗΣ ΔΙΑΦΘΟΡΑΣ - ISO 37001:2016

KALLIERGOS O.T.M. S.A., recognizing the need to combat corruption and bribery in order to enhance the Company’s credibility and reputation, as well as the transparency and efficiency of its business operations, and to respond to the needs and expectations of its stakeholders, has undertaken the development, implementation, and commitment to maintain and continuously improve an Anti-Bribery Management System, in accordance with the requirements of the International Standard EN ISO 37001:2016.

The scope of the System is:

• Preparation of Structural Studies
• Provision of Technical Consultancy and Supervision

In this way, the Company aims to reinforce Management’s commitment to zero tolerance towards bribery and to raise awareness among all employees and partners against bribery, by establishing a series of procedures designed to ensure the prevention, deterrence, and combating of bribery.

KALLIERGOS O.T.M. S.A. is particularly committed to:

• Complying with the current legal and regulatory framework for the fight against bribery.
• Complying with the requirements of the Anti-Bribery Management System according to ISO 37001:2016.
• Encouraging the confidential reporting of any incident, suspected incident, or attempted bribery through specific communication channels by employees and partners of the Company, without fear of retaliation, to the Anti-Bribery Compliance Function Manager (ACFO) and other relevant Company personnel.
• Ensuring and explaining the authority and independence of the Compliance Function Manager in the Company’s regulatory compliance and anti-bribery audit processes.
• Clearly communicating the consequences of non-compliance with this Policy.
• Supporting the function and independence of the ACFO in the Company’s regulatory compliance and anti-bribery audit processes.
• Providing the necessary resources and appropriate means to train, raise awareness, and involve staff in compliance and anti-bribery matters, aiming at the continuous improvement of the Anti-Bribery Management System.
• Continuously improving the Anti-Bribery Management System in its business operations through the following tools:

– Risk assessment and implementation of the necessary actions.
– Establishment and achievement of the Company’s regulatory and anti-bribery compliance objectives.

– Implementation of due diligence procedures and anti-bribery controls.
– Conducting internal audits.
– Staff training and awareness raising.
– Management of non-conformities and implementation of corrective actions.
– Review by Management and the Compliance Function Manager.

The relevant requirements of stakeholders regarding their obligations to comply with both the applicable legal framework and anti-bribery legislation, as well as their participation in the Anti-Bribery Management System, have been incorporated into the Company’s operations through the relevant System documents.

Within this framework, the Company’s Management is committed to supporting the implementation, monitoring, and maintenance of the System, which will be periodically reviewed, revised, and improved as necessary, in order to continuously ensure compliance with both the applicable legal framework and anti-bribery requirements.

Executives and employees of KALLIERGOS O.T.M. S.A., as well as third parties acting on its behalf, are strictly prohibited from offering, promising, or giving bribes to anyone, as well as from requesting or accepting bribes from anyone.

This Policy is binding on Management, executives, employees, and any other person involved in the operation of the business, including external providers and professional partners of any kind.

Failure to comply with this Policy, whether intentionally or unintentionally, may result in disciplinary action against those involved, as well as criminal prosecution in accordance with applicable anti-corruption laws.

This Anti-Bribery Policy is communicated to and made available to all interested parties and is reviewed periodically by the Company’s Management.

Communication and Reporting Channels

Athens, 16 January 2026

The Chairman of the Board & Managing Director

Ioannis Sigalas