1. Purpose
This policy ensures ethical business practices by preventing corruption, bribery, and undue influence in all company operations. It provides clear guidelines on acceptable behavior regarding gifts, entertainment, and business conduct.

2. Scope
This policy applies to all employees, contractors, and representatives of ESSL.

3. General Principles
• Employees must act with integrity and avoid conflicts of interest.
• Bribery in any form is strictly prohibited.

4. Gifts and Entertainment Guidelines
• Acceptable Gifts: Employees may accept small, non-cash gifts (e.g., promotional items) valued under € 50, provided they are not intended to influence business decisions.
• Unacceptable Gifts: Cash, loans, or gifts of significant value that may create the appearance of improper influence are strictly forbidden.
• Entertainment: Employees may accept or provide reasonable entertainment (e.g., business meals) if it is modest, infrequent, and directly related to business. Lavish or excessive entertainment is prohibited.

5. Reporting
Employees must report any offer or request for a gift, entertainment, or favor that could be considered inappropriate or a potential bribe to the ESSL Executive Board.

Decided by the ESSL Executive Board at its meeting on 16 December 2024.