The Management of ATRON HEALTH MEDICAL PRODUCTS AND MACHINERY S.A. recognizes the risks of Bribery and has all the necessary resources for the development and a comprehensive Management System for Combating Bribery in accordance with the guidelines of the international standard ISO 37001:2016.

Within the framework of this System, procedures are documented and implemented to meet the requirements of the Standard, ensuring the effective Combating of Bribery in all areas and activities of the Company.

The Management of ATRON HEALTH MEDICAL PRODUCTS AND MACHINERY S.A. throughout the Company’s operation:

• Prohibits any form of bribery or its acceptance.

• All employees are required to comply with state or federal bribery laws applicable to the Company.

• Encourages the contribution of all employees in the identification and suspicion of any possible bribery and prohibits the punishment or negative treatment of such employees.

• Commits to implementing measures and providing necessary resources in order to fight bribery.

• It sensitizes and properly trains its staff through continuous anti-bribery updates and trainings.

• It has established a specific Anti-Bribery Structure, which is independent from the rest of the staff, reports only to the General Manager and has the obligation and authority to investigate every possible case of bribery, examine and assess the risks of bribery and implement relevant measures . combating it.

• In case of bribery or non-compliance with the reports of the Anti-Bribery Management System, sanctions are imposed and in case of violation of relevant legislative requirements, a report is made to the Competent Authorities.

• It is committed to the continuous improvement of the Anti-Bribery Management System that implements.

Compliance with this policy is mandatory and binding for all Company staff and partners.

This text is available to all staff, customers, partners, suppliers of the Company as well as to any involved Public and Municipal Authority.

For concerns or possible complaints, you can contact our Company’s Anti-Bribery System Manager.