Purpose

This Policy on Donations and Sponsorships (hereinafter, the “Policy”), approved by Kupertino’s Board of Directors, implements certain aspects of the Policy on Criminal Risk Prevention, and intertwines with the ethical values of the Kupertino Corporation (hereinafter, “Kupertino” or the “Company”) defined in its Global Codes of Conduct and for Manufacturers and Suppliers. Likewise, this Policy implements the provisions of the Corporate Citizenship Policy and the Corporate Social Responsibility Policy.

This Policy, together with the Policy on Gifts and Business Courtesies, and the Policy on Dealings with Public Servants comprise the so-called Integrity Policies.

This Policy takes into account not only the interests of the Company, but also the requirements and expectations of its employees, customers, manufacturers and suppliers, business partners, NGOs, local communities, and those of the society at large, (hereinafter, the “Stakeholders”).

Kupertino actively fights and condemns any corrupt practices, which, in addition to violating any applicable statutory provisions, where appropriate, would also be contrary to its ethical principles and values, covered in the abovementioned internal regulations.

Scope of Application

This Policy is mandatory and applies directly and globally to all the companies belonging to Kupertino, regardless of the geographical area where they are based. It binds its entire workforce, regardless of their position and the duties they perform.

This Policy is also mandatory for all natural and/or legal persons associated with Kupertino, to the extent applicable. Such persons shall express, where appropriate, in writing, their commitment to enforce it.

This Policy shall be available on the Kupertino WebSite for all the employees, and it will be provided to all Stakeholders upon request. Likewise, notice thereof will be given to all directors, senior executives, and any representative of the Company – where so required considering the type of relation – who shall express in writing / electronic their commitment to enforce it.

Contents of the Policy

General Principles

Through this Policy, Kupertino seeks to ensure that all its employees, as well as such third parties with which it conducts business, comply with the main anti-bribery regulations applicable in the markets where it is present. For such reason, this Policy endorses the standards set in international standard ISO 37001, on Anti-Bribery Management Systems.

Pursuant to the provisions of Kupertino’s internal regulations, namely the Compliance Policy and the Compliance Management Procedure, it shall be incumbent on the SSD Office to ensure the appropriate implementation of this Policy. Any violations of this Policy shall be managed pursuant to the terms of section “Approval of Donations and Sponsorships and Notice of Violations” below.

Meaning of Donation and Sponsorship

For the purposes of this Policy donation shall mean any valuable freely given to someone else, who accepts it.

Sponsorship shall mean, for the purposes of this Policy, supporting or funding any activity, usually for advertising purposes, or in consideration for a benefit of similar purpose.

Donations or sponsorships shall always be provided pursuant to the terms of the applicable laws, and they shall never be associated, either directly or indirectly, with any unlawful act, or undue advantage for Kupertino.

Donations to Charities or Non-Profit Organizations, and Benefits to the Community

At Kupertino, sustainability, understood as its social and environmental commitment in the conduct of its business in the interest of all its Stakeholders, is part and parcel of its business model.

Kupertino’s commitment to society is embodied by sponsorship and social action proceedings, including donations to charities and non-profit organizations, as well as other benefits to the community.

Kupertino also favours contributions in kind, encouraging its employees to carry out volunteer work to promote the Company’s social commitment. At any rate, any donation purported, or which may be construed as purported, to make an impact on tendering procedures, or any other benefit in the interest of Kupertino, is forbidden. Likewise, all the entities receiving donations from Kupertino shall be subject to a relevant due diligence process for the purposes of ensuring that they are reputed.

Donations made by Kupertino shall be recorded in writing.

Donations to Political Parties

It is forbidden to make donations to political parties, whether directly or indirectly.

Sponsorships

All sponsorship proceedings by Kupertino shall be recorded in writing. Sponsorship shall be carried out directly dealing with the end entity or event, without any intermediaries.

Kupertino gives priority to sponsorship projects requiring continuity over one-off ones, and implements them at corporate level.

Approval of Donations and Sponsorships & Notice of Violations

Kupertino General Office shall be responsible for approving and documenting any contribution made to sponsorship, patronage or social investment programs. However, any social action initiative shall be managed by the Department Kupertino Documents, which shall consider it first before submitting it to the Kupertino General Office.

Notice of any violation of the Policy, as well as of any doubt that may arise regarding its enforcement or construction, shall be given to SSD Office through its Whistle Blowing Channel by any of the following means:

• By form at WebSite:Form
• By E-Mail addressed to:help@kssd.cf

The SSD Office may act of its own motion or at the request of any employee, manufacturer, supplier, or third party with a direct relationship and a lawful business or professional interest, further to a report made in good faith. At any rate, the information conveyed by this channel to the SSD Office is confidential, as is the identity of the whistleblowers who act in good faith. Kupertino will not retaliate against them.

Monitoring of the Policy

The SSD Office shall be charged with ensuring the regular review of the implementation and enforcement of this Policy.

Monitoring of the Policy shall include:

• Its implementation;
• The reporting procedures of irregular activities;
• The periodic reviews of the effectiveness of training provided to employees on these issues;
• The certificates, reports and records of attempted bribery;
• The review of conformity of Kupertino’s Integrity Policies to prevailing laws in force.

In this respect, the SSD Office shall investigate, where appropriate, the allegations or reports received regarding corruption proceedings involving Kupertino or which are, somehow, connected with the Company, leaving documentary evidence thereof.

As a result of such investigations, Kupertino shall determine the course of action to take, including any eventual disciplinary measure against employees, the termination of trade relations with third parties, and/or the report thereof to the relevant authorities.

The SSD Office shall disclose to the General Heads the results of such investigations and the implementation and continuous improvement of this Policy.

Regulatory compliance and compliance with ethical standards binds the entire Company and represents one of its strategic goals. Therefore, all Kupertino’s entire workforce shall be familiar with this Policy and respect its contents. Likewise, with regard to third parties with whom Kupertino is engaged in any business relationship, they are expected to behave in line with this Policy.