Anti-Bribery and Corruption Policy

(ANTI-BRIBERY)

Publication date: December 2025

1. DEFINITIONS

For the purposes of this document, bribery shall be understood as the offering, promising, giving, accepting or soliciting of an undue advantage, directly or indirectly, of any value or nature, as an incentive or reward for a person to act or refrain from acting in relation to the performance of their duties.

The Organisation shall be understood as SERVICIOS Y LOGÍSTICA DE RESCATE, S.L. (hereinafter, SLRESCUE).

2. INTRODUCTION

Bribery and corruption constitute serious phenomena that negatively affect good corporate governance, free competition and the proper functioning of markets.

SLRESCUE maintains a firm and irrevocable commitment to legality, ethical principles and business integrity, establishing a policy of zero tolerance towards bribery and corruption, both in the public and private sectors.

3. PURPOSE AND SCOPE

This Policy constitutes an internal regulatory framework of mandatory compliance, the purpose of which is to prevent, detect and respond to bribery and corruption risks. It shall apply to:

  • Governing Body
  • Management
  • Employees
  • Professionals and collaborators
  • Business partners

4. PRINCIPLES RELATING TO CORRUPTION AND BRIBERY

The following are strictly prohibited:

  • Active and passive bribery
  • Bribery of public officials
  • Trading in influence
  • Private corruption in business
  • Facilitation payments

5. GUIDELINES FOR ACTION IN RISK SITUATIONS

5.1 Due diligence in staff recruitment

Recruitment processes shall be governed by objective criteria, and ad hoc or artificial hiring practices are prohibited.

5.2 Due diligence with business partners

The reputation, experience and risks of third parties shall be assessed prior to entering into business relationships.

5.3 Incentives and variable remuneration

Remuneration systems may not encourage conduct contrary to legality.

5.4 Facilitation payments

Facilitation payments are strictly prohibited, except in situations of extortion involving serious risk, which must be reported immediately.

6. GIFTS AND HOSPITALITY POLICY

Gifts and invitations must:

  • Have a legitimate and professional purpose
  • Be reasonable and proportionate
  • Not exceed an annual limit of €200 per person
  • Not contravene the rules of the recipient

The giving or receiving of cash or cash equivalents is prohibited.

7. TRAVEL, EVENTS AND DONATIONS

Travel and accommodation for third parties may only be covered where there is professional justification, prior authorisation and economic proportionality.

Donations to political parties are prohibited.

8. COMMUNICATION

SLRESCUE expresses its commitment to the implementation of internal mechanisms that allow the communication of potential regulatory breaches or conduct contrary to this Policy, ensuring the confidentiality of the information and the protection of persons who report facts in good faith.

The Organisation will progressively implement an internal reporting channel in accordance with Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption.

9. TRAINING

The Organisation shall promote periodic and appropriate training in the prevention of bribery.

10. MONITORING, REVIEW AND CONTINUOUS IMPROVEMENT

This Policy shall be reviewed periodically and whenever relevant regulatory, organisational or risk-related changes occur.

11. CONSEQUENCES OF NON-COMPLIANCE

Non-compliance with this Policy may give rise to disciplinary measures and legal liabilities.