ANTI-BRIBERY & ANTI-CORRUPTION POLICY

I. Purpose & Management Commitment

The MC CHARGERS IKE, a pioneer in the design, production and distribution of electric vehicle charging stations (EV Chargers), is committed to conducting all of its business activities with absolute integrity, ethics, transparency and Zero Tolerance for any form of bribery or corruption.
This Policy expresses the unwavering commitment of Top Management to the development, implementation, maintenance and continual improvement of the Anti-Bribery Management System in accordance with ISO 37001:2016, complementing and strengthening the company’s existing Management Systems.

II. Scope
The Policy applies mandatorily to:
• All executives, directors, employees and workers (full-time or part-time) of MC CHARGERS IKE.
• All external associates, representatives, distributors, equipment suppliers, subcontractors, consultants and, in general, third parties acting on behalf of or for the account of the company.
• All business transactions, public tenders, government procurements, subsidized/co-financed infrastructure projects and private commercial contracts at both domestic and international level.

III. Key Principles & Policy Requirements

1. Absolute Prohibition of Bribery:
• The offering, promising, giving, accepting or soliciting of any bribe, financial or other improper advantage, directly or indirectly through third parties, to or from any person (government/public officials, private customers, partners, etc.) for the purpose of obtaining or retaining a business advantage is expressly prohibited.
• Facilitation payments are strictly prohibited.
2. Compliance with Legislation:
• MC CHARGERS IKE is committed to full compliance with Greek and European anti-bribery and anti-corruption legislation, as well as international legal regulations in the countries where it operates.
3. Independence of the Anti-Bribery Compliance Officer:
• An Anti-Bribery Compliance Officer is appointed with full authority, operational independence, adequate resources, and a direct line of communication and reporting to Top Management and the Governing Body.
4. Due Diligence:
• A strict due diligence process is applied to new hires, cooperation with suppliers, subcontractors and representatives, and participation in major infrastructure projects or public contracts where a bribery risk is identified.
5. Gifts, Hospitality and Sponsorships:
• The offering or acceptance of gifts, hospitality or corporate benefits that could influence (or be perceived as influencing) the professional judgment and independence of any party is prohibited.
• Any customary low-value gifts are recorded and subject to approval based on the established limits.
6. Safe Reporting Mechanisms (Whistleblowing) & Protection Against Retaliation:
• MC CHARGERS IKE encourages personnel and interested parties to report confidentially and securely (or anonymously) any incident, suspicion or attempted bribery through the designated reporting channels.
• Non-Retaliation Guarantee: No employee shall suffer demotion, dismissal, discrimination or any adverse treatment because they refused to engage in bribery or because they made a report in good faith.
7. Continual Improvement:
• The company is committed to continuous monitoring, periodic risk assessment and continual improvement of the effectiveness of the Anti-Bribery Management System.
IV. Consequences of Non-Compliance
Compliance with this Policy is mandatory. Any violation of the Policy or the relevant procedures:
• For employees: constitutes a serious disciplinary offense leading to disciplinary sanctions, up to and including termination of employment, as well as legal claims.
• For business partners: entails immediate cancellation and termination of the commercial cooperation/contract and pursuit of compensation.
V. Communication & Awareness
This Policy is communicated to all personnel, is posted in prominent locations at the company’s facilities, and is published on its official website (mc-chargers.com) for the information of customers, suppliers and other interested parties.

For MC CHARGERS IKE,
Charalampos Marmaggelos