INDICATOR: 2-24

All corporate policies listed under disclosure GRI 2-23 are implemented and relevant continuous training ensures their knowledge and implementation.

No implementation discrepancies have been identified.

Audit of Regulations, Procedures, Performance Indicators, Contracts and Policies

A Group Internal Audit Division (GIAD) has been established, which reports administratively to the CEO and functionally to the Audit Committee. It consists of three Audit Departments (Administrative-Financial, Trading and Industrial Facilities & Supply) for complete audit coverage of all the company’s activities. In addition there is a Qualitu Assurance Department within GIAD and its mission is to ensure compliance of audit activities according to GIAD’s audit methodology, to introduce improvements and achieve continuous adherence with the International Professional Practices Framework of Intenal Audit.The independent GIAD, through conducting periodic assessments, ensures tha the risk identification and management procedures applied by the Management are adequate, tha the Internal Audit System operates effectively and that information provided to the BoD regarding the System of the Internal Controls, is reliable and good quality.

The Group’s Code of Conduct expressly provides that each employee must comply with the law and behave with honesty, transparency and responsibility towards customers, partners, shareholders and, more generally, towards social partners. The Code of Conduct has been translated into all the languages of the countries where the Group operates and is applied by their employees.

The Group also monitors relevant labor legislation (national, European, ILO), including issues related to respect for human rights and working conditions, and is in full compliance with collective and relevant international conventions.

The Code of Conduct (sections 7.2 & 7.3) and the Internal Regulations (article 18) provide guidelines for the protection of human rights throughout the supply chain.

The Internal Regulations and the Code of Conduct make clear references to respect for human rights. All employees have been made aware of these documents, which are accessible to all employees in the corporate network.

100% of the employees have been informed on Human Rights issues through the Internal Work Rules (Articles 22, 23, 26, 38 & 39) and the Code of Conduct (Chapter 7) which are communicated to all employees through the intranet. What is more, since 2019, the “Code of Conduct” has been available to all employees as an online course, through our training platform.

The following actions constitute indirect ways of human rights education:

• Employee participation in training workshops on sustainable development and corporate responsibility
• Establishment of a Group Sustainable Development

The Procurement Regulation has been in force since January 2017 and includes paragraphs that refer to the performance of our suppliers in terms of Sustainable Development and Corporate Responsibility issues, across the entire scope of their cooperation with the Group.

In addition, a ‘condition of compliance’ of our suppliers with the principles of the UN Global Compact has been incorporated in all new contracts and purchase orders for materials and services (100%) in the areas of human rights, labor, the environment and anti-corruption.

EKO Bulgaria

The Code of Conduct is applicable to the members of the management, executives, personnel and in general any person providing services to the Group, without exceptions or deviations. The obligation to comply with the Code of Conduct is included in the agreement with each partner. Concerns are dealt with in a confidential manner. No concerns have been raised. The internal rules for prevention of corruption were approved by EKO Bulgaria in 2020. The internal rules on Complaints were approved in December 2023.

EKO CYPRUS

The Group’s Code of Conduct was implemented in 2012. The Code has been communicated to all employees, suppliers and customers and is also part of our contracts.

EKO Serbia

The Group’s Code of Conduct was implemented in 2012. The Code has been communicated to all employees, suppliers and customers.

In accordance with local legislation and the Code of Conduct, each new hire receives the Code of Conduct which is presented in detail by the HR department, as well as information regarding the Law on Complaints etc. The employee shall sign the receipt of the above documents and keep them in his/her personal files. Employees are clearly informed (by the above documents and verbally) of their rights in relation to the above Laws and our practice of Open Door Policy, Transparency and encouraging all employees to communicate openly.

JUGOPETROL

The Group’s Code of Conduct was implemented in 2012. The Code has been communicated to all employees, suppliers and customers. Each new hire receives the Code of Conduct and signs a receipt.

OKTA

The Group’s Code of Conduct was implemented in 2023 and is published on the company’s website. Each new hire receives a copy of the Code of Conduct, the Workplace Harassment Protection Measures and Procedures, the Conflict-of-Interest Policy, etc. These documents are signed by the employee and communicated to HR.

At the same time, the Group is committed to implementing Management Systems and continuously improving its performance. The certifications of the Group’s facilities, warehouses, fuel stations, in accordance with internationally recognized standards, are presented below (the original year of certification is indicated).

Valid certification type and first year of certification