POLICY CONCERNING THE PREVENTION OF HARASSMENT, DISCRIMINATION AND MOBBING IN INTEGER CAPITAL GROUP (hereinafter “Policy”)

I. Objective

The purpose of this policy is to regulate the principles and procedures applied by Integer.pl S.A. and subsidiaries thereof, within the meaning of Article 4 § 1 point 4) of the Code of Commercial Companies (hereinafter referred to as the “Group”), pertaining to the prevention of harassment, discrimination and mobbing.

The Group strives for ensuring a working environment free of harassment and mobbing, including an environment free of prejudices, in which people with different views, convictions, nationalities, races, religions can find their place, as well as requires that the whole Personnel demonstrate ethical behaviour towards their associates.

This Policy also aims at building positive relations amongst Staff Members and Associates, based on respect and consideration for dignity.

This Policy is part of the Compliance Policy comprising, inter alia, the Code of Conduct and Ethics, Compliance Policy along with a guide, as well as Policy for the Prevention of Money Laundering Practices.

Apart from the obligation to observe this Policy and to immediately report suspicions of its breach, all members of the Personnel will have to confirm that they have familiarised themselves herewith and to comply with this Policy during commencement of employment or cooperation, and afterwards - on a periodic basis.

II. Definitions

a. Manager card - each and every person directly subordinate to a member of the Management Staff.

b. Management Staff - each and every member of the Management Board of any of the Companies, and persons performing the managerial functions directly subordinate to members of the Management Board of any of the Companies.

c. Personnel - all Staff Members and Associates of the Company.

d. Employee - a natural person employed by the Company on the basis of an employment contract, regardless of whether he / she is employed on a full-time or part-time basis, as well as a temporary worker.

e. Associate - a natural person cooperating in person with the Company based on a civil law contract, regardless of whether such a contract has been concluded with the Associate as a natural person carrying out an economic activity, or a natural person not conducing an economic activity (the civil law contract shall mean, e.g. a cooperation contract, contract of mandate, contract for a specific task).

f. Mobbing - means an activity or behaviour concerning or targeted at a given person that consist of a persistent and long-term harassment or intimidation of the given person, which results in his / her perception of decreased occupational usefulness, which causes or is aimed at humiliation, ridicule or isolation of the given person or his / her exclusion from the team of associates.

g. Harassment - means behaviour which is vexatious, offensive, violates personal dignity or personal immunity or is undesired in the eyes of his / her recipient, which may be targeted at a given person or group of people.

h. Discrimination - means unlawful deprivation or restriction of rights arising from the employment relationship or unequal treatment of employees, due to their sex, age, disability, race, religion, nationality, political beliefs, trade union membership, as well as ethnic origin, denomination, sexual orientation, employment for a definite or indefinite period of time, employment on a full-time or part-time basis, as well as granting to some employees, for these reasons, fewer rights than the rights enjoyed by other employees in the same factual and legal situation.

III. Scope and essence

The Group does not accept Harassment, Discrimination, Mobbing or any other forms of psychical and physical violence, as well as counteracts such behaviour.

This Policy is binding on the entire Personnel of the Group.

Exemplary forms of Harassment include:

• Unwanted physical contact (starting with redundant touch to a serious physical attack), • Verbal or written harassment in the form of jokes, offensive language, glances, gestures, rumours and slanders or blackmail, • Visual presentations (calendars with “naked” photos, pictures insulting religious feelings), • Isolation and lack of cooperation in the workplace, • Exerting pressure to generate particular behaviour unacceptable by a given person (e.g. sexual), • Violation of privacy by imposing oneself on someone, spying, following/investigating.

If at least one of the foregoing activities occurs on a persistent basis or long-term basis, we have to do with Mobbing.

Harassment shall not include constructive criticism and negative assessment of work performed if it is based on facts, and the manner of handing it over is consistent with the generally adopted social coexistence and personal culture standards.

Harassment shall not include a one-off contact between two persons, consisting in mutual exchange of contradictory views, while maintaining the basic standards on social coexistence and personal culture. Harassment shall not include stress related to difficult working conditions (temperature, noise, vibrations), time pressure connected with the necessity to perform a given task on time or excessive workload if it does not result from malicious and intentional activities of superiors.

Harassment shall not include a demand to comply with the principles and procedures of conduct in force in the Group under any circumstances.

The Group prevents the Harassment, Discrimination, Mobbing and other forms of psychical violence in particular:

• by obligating the Management Staff and Managers to promote behaviours consistent with the social coexistence principles, as well as by ensuring proper communication relations in teams functioning within the framework of the Group, • by training the Management Staff and Managers, as well as by disseminating knowledge about the Harassment, Mobbing and Discrimination, methods of prevention of occurrence thereof and consequences of occurrence thereof, • by means of preventive measures as part of the ongoing Employee management, connected in particular with applying open communication with Employees, • by disseminating the mutual respect principle, • by condemning symptoms of psychical violence or physical violence, or behaviours which may lead to such violence, • by means of activities integrating the Personnel including, e.g. integration meetings.

IV. Procedures in the case of occurrence of Harassment, Discrimination or Mobbing

The Group undertakes that any and all charges of the Harassment, Discrimination or Mobbing shall be examined in a confidential, reliable/accurate and objective manner. An informant shall not be exposed to repressions.

The Harassment, Discrimination and Mobbing in all forms shall be subject to disciplinary consequences stipulated in the Labour Code - starting from an admonition, through a reprimand to termination of employment relationship.

Any and all reported cases of the Harassment, Discrimination or Mobbing shall be addressed to the HR Office Director or President of the Management Board of the Group. The reported cases may also be sent to the following email address: [email protected]. Next to the office of the Group Management Board President in Warsaw and Kraków, there are also boxes dedicated to reported cases of this type of behaviours.

The role of the HR Office Director or President of the Management Board includes: • confidential hearing the Employee who considers himself / herself to be a victim of the Harassment, Discrimination or Mobbing,

• assistance in establishing whether the behaviour forming the subject matter of a complaint constitutes the Harassment, Discrimination or Mobbing, • mediation if there is a conflict but it cannot be considered a symptom of the Mobbing, Discrimination or Harassment, • assistance for the victims in establishing activities that they intend to undertake and in explaining the procedure for considering a complaint if they decide to benefit from it.

In case of submitting a complaint, the President of the Management Board of the Group or a person dedicated to this by the President of the Management Board shall conduct an investigation. At each and every stage of the investigation, both persons have the right to act in another person’s company. Concrete charges shall be levelled against a person suspected of unethical behaviour and he / she will be able to take an attitude towards them. All the time the principle of confidentiality, objectivism and reliability / accuracy shall be observed, and any and all findings shall be recorded.

As a result of the investigation, a decision about further procedure of conduct shall be made. If charges of unethical behaviour are confirmed, a disciplinary procedure shall be instituted, corresponding to the importance of the charges.

Imputing unfairly someone to unethical behaviour and reporting a given case in bad faith shall be prohibited and constitute a breach of the basic employee obligations. This may form the basis for the Group to apply the sanctions stipulated in the labour law, in particular to apply penalties for breach of order or to terminate a contract being the basis of employment, also without notice.

V. Systemic activities preventing the occurrence of the Mobbing, Harassment and Discrimination - monitoring of employee relations

In order to prevent the occurrence of unethical behaviours, the Group undertakes to monitor employee relations.

This monitoring may consist, in particular, in: • an analysis of the cases reported, • conducting anonymous questionnaires, • an analysis of the Group’s organisational structure to eliminate undesired incidents.

VI. Final Provisions

Questions about this Procedure shall be addressed to the HR Office Director or Legal Department Coordinator.

The Group may introduce amendments hereto at all times and for any reason whatsoever, with the reservation that such an amendment shall be communicated to the Personnel each and every time.

This Policy replaces any and all current internal regulations in the Group pertaining to the Harassment, Mobbing and Discrimination.