Anti Bribery policy

ANTI-BRIBERY POLICY

VASILEIOS & IOANNIS MANTZARIS S.A. is engaged in the import, trade, distribution and technical support of medical devices. The Board of Directors, as the governing body, and the Management of the company are committed to preventing, detecting and addressing bribery in all of the company’s activities. To this end, the company operates an Anti-Bribery Management System in accordance with the international standard ISO 37001:2025 and provides the resources required for its implementation.

Compliance with this Policy is mandatory for all members of the Board of Directors, all personnel and all business associates acting on behalf of the company.

The company:

·         prohibits bribery in any form, whether offering, promising or giving, or requesting or accepting, an undue advantage, directly or through third parties, to or from public officials or private persons;

·         prohibits so-called “facilitation payments” to public officials or third parties to expedite or secure actions to which the company is entitled in any event;

·         requires its personnel and business associates to comply with the applicable anti-bribery laws;

·         applies a zero-tolerance policy towards bribery and corruption and acts with professionalism, legality and integrity in all its dealings;

·         promotes, through the personal example of Management, a culture of integrity at all levels of the company;

·         requires every member of staff to declare any actual or potential conflict of interest and manages these declarations in a documented manner;

·         carries out due diligence, proportionate to the assessed risk, before entering into or renewing business relationships and before assigning personnel to positions with a more than low bribery risk;

·         applies clear rules on gifts, hospitality, sponsorships, donations and support for scientific events, in accordance with the regulatory framework of the Greek National Organisation for Medicines (EOF) and the codes of ethics of the medical technology sector;

·         informs and trains its personnel, as well as business associates that pose a more than low bribery risk;

·         encourages the reporting, in good faith, of suspected or actual bribery, by name or anonymously, ensures confidentiality and protects those who report from any form of retaliation, even if the report is not ultimately confirmed;

·         provides the framework for setting and reviewing anti-bribery objectives and is committed to meeting the applicable legal, regulatory and contractual requirements;

·         has appointed an Anti-Bribery Compliance Officer with the necessary competence, status, authority and independence and with direct access to the Board of Directors, who oversees the System and investigates any possible case of bribery; the independence of this function is supported by an external audit of the System;

·         imposes sanctions in case of bribery or breach of this Policy, which may extend to termination of employment or of the business relationship, and, where the law is breached, reports the matter to the competent authorities;

·         is committed to the continual improvement of its Anti-Bribery Management System.

Reporting concerns

Any person may report a concern, by name or anonymously, to the Anti-Bribery Compliance Officer by e-mail ([email protected]), by telephone (2107706258) or in writing, in a sealed envelope marked “Confidential – Anti-Bribery Compliance Officer”, to 2-4 Mesogeion Avenue, 115 27 Athens, Greece. Reports may also be submitted directly to the Greek National Transparency Authority (external reporting channel under Law 4990/2022).

This Policy is approved by the Board of Directors, reviewed annually, published on the company’s website and communicated to personnel and business associates.

Athens, 26/09/2026

Ioannis Mantzaris
Chairman of the Board & Managing Director