(This statement is in English due to the nature of our international stakeholders).

As a FIDI Affiliate, Royal De Gruijter & Co, agrees and commits to:

1. Never engage in any form of bribery, either directly or through any third party.
2. Never offer or make an improper payment, or authorise an improper payment (cash or otherwise) to any individual, including any local or foreign official anywhere in the world.
3. Never attempt to induce an individual, or a local or foreign official to act illegally or improperly.
4. Never offer, or accept, money or anything of value, such as gifts, kickbacks or commissions, in connection with the procurement of business or the award of a contract.
5. Never offer or give any gift or token of hospitality to any public employee or government official or representative if there is any expectation or implication for a return favour
6. Never accept any gift from any business partner if there is any suggestion that a return favour will be expected or implied.
7. Never facilitate payments to obtain a level of service which one would not normally be entitled to.
8. Never disregard or fail to report any indication of improper payments to the appropriate authorities.
9. Never induce or assist another individual to break any applicable law or regulation.

As a FIDI Affiliate, Royal De Gruijter & Co, agrees and commits to:

1. Never make direct or indirect (via third parties including agents, suppliers or
   customers) contact with an actual or potential competitor or other third party,
   the object of which is to engage in cartel behaviour.
2. Never propose or reach an agreement, whether directly or indirectly, formally
   or informally, with actual or potential competitors, regarding any sensitive
   competition-related issues, including:
   • Fixing prices
   • Dividing or sharing markets, customers or territories
   • Rigging a competitive bidding process
3. Report any indication or initiative of improper anticompetitive business
   conduct by an actual or potential competitor in accordance to your internal
   reporting procedure, including but not limited to, reporting to your legal
   department and/or to the relevant Anti-Trust authorities.

This conduct is part of our CSR Policy

January 2020

Remko Hitijahubessy
Managing Director