Unifarm is committed to upholding the fundamental principles of good corporate conduct and integrity in all its activities. The establishment and implementation of the Anti-Corruption Program (hereinafter: the Program) is an important part of this commitment.

Our Program is based on the laws of Bosnia and Herzegovina, anti-corruption conventions to which BiH is a signatory, the world’s best practices in combating corruption, as well as the specific anti-corruption requirements of our partners.

The purpose of our Program is to foster a culture of compliance, prevention, and detection of violations of the law or internal company acts. Unifarm expects that the behavior and actions of our employees, contractors, agents, representatives, and any other individuals acting on behalf of the Company will be fully aligned with applicable laws, our codes, policies, procedures, guidelines, and work instructions. If the Company becomes aware of any violations of laws or internal acts, we will immediately initiate an investigation, take appropriate disciplinary action, and implement corrective measures to prevent future violations.

Unifarm recognizes that our Program must continuously evolve to effectively respond to changing circumstances within the Company and its environment. Therefore, we are committed to continuously improving the quality of the Program based on regular reviews and assessments of the regulatory and business landscape.

Responsibility and Oversight

Unifarm has assigned responsibility for developing, implementing, and monitoring the Program, as well as proposing improvements, to the Management Representative for Business Ethics and Compliance. This Representative reports on their work and on all significant matters related to the Program directly to the Company Director. The Company Director oversees the work of the Representative and conducts an annual assessment of the effectiveness of the Program.

Internal Anti-Corruption Legislation

Unifarm’s Anti-Corruption Policy, Code of Conduct, procedures, guidelines, work instructions, and other directives are mandatory for all employees, contractors, agents, representatives, and all other persons acting on behalf of the Company (hereinafter: Personnel). To emphasize the importance of compliant behavior, we require every employee to confirm that they are familiar with and agree to comply with all Unifarm policies and procedures.

Unifarm conducts all its operations in an honest and lawful manner. We maintain zero tolerance for corrupt behavior, including bribery, fraud, anti-competitive conduct, coercion, and obstruction. The Anti-Corruption Policy strictly prohibits such actions and clearly states that Unifarm does not tolerate behavior inconsistent with the Policy.

Our Code of Conduct provides guidance on how to conduct business in a fair, ethical, and lawful manner. All Unifarm personnel must know, understand, and comply with the Code, including its anti-corruption provisions.

Our Program includes numerous reporting, monitoring, and certification controls, as well as mandatory training components, described in detail in the Employee Code of Conduct and in our Procedure for Training and Professional Development. Procedures for resource allocation and employee management clearly define the processes of recruitment, monitoring, advancement, and termination. These procedures also include anti-corruption elements regarding relations with public officials, conflicts of interest, and compliance with laws and internal regulations.

Unifarm expects its suppliers, business partners, and all third parties acting for or with the Company to comply with all applicable laws and the highest anti-corruption standards. To avoid improper third-party behavior, Unifarm has developed the Third-Party Code of Conduct, which prescribes a detailed due-diligence process before any engagement.

We have also defined monitoring mechanisms for third parties, recognizing the legal and business risks associated with their selection. Marketing procedures, including sponsorship allocation processes (recognized as high-risk), also define advertising requirements in line with regulatory expectations.

Unifarm aims to ensure that all Personnel clearly distinguish between acceptable business behavior and conduct that is unethical, unlawful, or contrary to good corporate governance and best practices. Therefore, behaviors related to high-risk processes—such as donations, gifts, hospitality, representation, and travel—are thoroughly regulated by our Integrity in Cost Management Rulebook.

The detection of any legal or internal violations is of highest priority. Our Procedures for Non-Compliance Management and Corrective Actions prescribe the processes for identifying, investigating, and addressing such issues.

Corruption Risk Assessment

The corruption risk assessment is the foundation of our Program and supporting policies, procedures, and instructions. It is a continuous process that provides systematic insight into corruption-related risks. Results of the assessment guide the development of controls and activities aimed at reducing or eliminating identified risks.

This process is essential because the insights gained shape our Program and ensure its continuous improvement. The assessment is conducted annually and includes evaluation of business processes and job positions, the adequacy of internal policies and procedures, the analysis of historical data, and the assessment of employee awareness and compliance.

Training and Communication

Education and training are key to effectively communicating the Program and its requirements. All Personnel receive training on the Program, Code of Conduct, and all anti-corruption rules, procedures, guidelines, and work instructions relevant to their roles.

We maintain detailed training records to ensure all Personnel have completed required training. We consider legal and ethical awareness essential for proper business conduct.

Unifarm provides Program training as part of onboarding for all new employees. Annual anti-corruption training is mandatory for all Personnel, with additional advanced training provided where risk of exposure to bribery or corruption is higher. Personnel must annually confirm compliance with all legal and internal requirements.

Counseling and Detection of Irregularities

Unifarm is committed to fostering active dialogue between management and employees on ethical and compliance matters. Personnel are encouraged to seek guidance and to report any irregularities or concerns.

The Company has established dedicated channels for consultation and reporting potential irregularities. We maintain an “open-door policy,” encouraging employees to discuss concerns with their supervisor or the Company Director.

Unifarm guarantees that any employee who reports a concern in good faith will not face retaliation. Any form of retaliation or discrimination is strictly prohibited.

Corrective Actions

Our Program increases the likelihood of preventing or identifying unlawful or unethical behavior. However, even the most effective program cannot eliminate all risks. Therefore, the Company must respond immediately to any potential violations, take disciplinary actions, assess whether internal policies or controls contributed to the violation, and implement corrective measures to prevent recurrence.

Implementation and Discipline

All Program activities are defined in the annual Anti-Corruption Plan, based on corruption risk assessments. Individuals bear personal responsibility for non-compliance, and any violation is treated as a disciplinary matter.

Confirmed violations will lead to disciplinary measures proportionate to the offense and may result in termination or legal action.

Relations with Third Parties

Unifarm is committed to conducting all activities in compliance with applicable laws and ethical standards. We are a fair and honest business partner and therefore require all third parties to adhere to the principle of zero tolerance for corruption.

We clearly communicate our Program and zero-tolerance policy to suppliers, business partners, and all third parties at the start of our cooperation and whenever necessary thereafter.

We believe we have developed and implemented an effective Anti-Corruption Program and will continue to improve it and all activities related to anti-corruption.