Anti-Bribery & Corruption (ABC) Policy

Effective Date: Jan 01, 2026 | Version: 1.0 | Approved By: Youssef Khayali, CEO

1. Purpose & Scope

Sustalium B.V. is committed to conducting all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships globally. This policy applies to all employees, directors, contractors, and third-party vendors working on behalf of Sustalium B.V.

2. Zero Tolerance on Bribery

Employees and representatives of Sustalium B.V. must never offer, promise, give, request, agree to receive, or accept any financial or other advantage to induce or reward improper performance of a function or activity. This applies strictly to dealings with both private enterprises and public/government officials.

3. Gifts & Hospitality

  • Threshold: Gifts or hospitality exceeding €50 in value must be formally approved by management and recorded in our internal Gift Register.
  • Cash: The giving or receiving of cash or cash equivalents (e.g., gift cards) is strictly prohibited.

4. Facilitation Payments & Kickbacks

Sustalium B.V. does not make, and will not accept, facilitation payments or "kickbacks" of any kind. A facilitation payment is a small, unofficial payment made to secure or expedite a routine government action by a government official.

5. Charitable & Political Contributions

Sustalium B.V. does not make political contributions. Charitable donations made on behalf of the company must be legal, ethical, and approved by the CEO to ensure they are not used as a subterfuge for bribery.

6. Raising Concerns (Whistleblowing)

All employees and partners are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. Reports can be made confidentially to compliance@sustalium.com. Sustalium B.V. guarantees that no individual will suffer detrimental treatment as a result of refusing to take part in bribery, or because of reporting a suspicion in good faith.