Cez group’s anti-bribery policy

WE DO NOT TOLERATE CORRUPTION

To enforce our ethical business standards, CEZ Group management has taken systemic measures to mitigate the risk of unethical or unlawful conduct, which constitute an integral part of CEZ Group’s Compliance Management System. CEZ Group's anti-corruption policy is based on the international standard ISO 37001:2016 – Anti-Bribery Management System.The fundamental principle of CEZ Group’s anti-bribery agenda is zero tolerance of any form of corruption, whether directly or through third parties.

Prohibition of any inadmissible payments, including bribes, illegal commissions and payments lacking legal justification stems from CEZ Group’s Code of Conduct. To support this rule, an internal regulations have been adopted, precisely defining permissible and impermissible gifts, prohibiting facilitation payments, and defining corrupt behavior. This document also defines the limits for permissible donations (accepted and provided). These limits are in line with common practice in the sector. Employees are obliged to keep a register of gifts and acceptance of any admissible gifts is subject to approval by a supervisor.

Another measure to reduce the risk of corruption and conflicts of interest is a system of third-party due diligence. These checks are a mandatory part of the purchasing process for potentially high-risk business cases. Conflicts of interest are also covered, among other things, in the Company's Rules of Procedure.

CEZ Group also has strict rules in place for negotiating brokerage contracts to prevent any form of corruption. The parent Company ČEZ is not involved in public politics, except for officially promoting its interests in the European Union through its Brussels representation office and does not make financial contributions to any political groupings. The Head of the Public Affairs department as well as both employees of the representation office in Brussels are registered in the EU’s transparency register. All standpoints of ČEZ on proposed legislation are exercised through the European Commission website and they are published there too.