October 7, 2021

To our stakeholders:

Corporate social responsibility has always been an integral part of the way ESSA Sales and Distribution SA operates. In recent years, we have focused on integrating CSR policies into the company's development strategy, and our main goal is for ESSA Sales and Distribution to experience long-term sustainable growth, with a positive impact on our employees and stakeholders.

To ensure that ESSA Sales and Distribution operates in a socially responsible manner, I am pleased to reaffirm our commitment to the 10 Principles of the United Nations Global Compact (UNGC) in the areas of Anticorruption, Environment, Labor and Human Rights. In this year's edition of the social responsibility report - Communication on Progress - we describe the actions we have taken in 2020 to continuously improve the integration of the largest CSR initiative at international level, the Global Compact, as well as the 10 Principles its in our business strategy, in the culture and daily operations of the company.

We are committed to disseminating the information in this report to all our stakeholders, shareholders and employees.

Eugen Saulea
General Manager

Caring for our employees has always been the focus of ESSA Sales & Distribution, and this has translated into human resources policies designed to ensure our employees a safe and healthy work environment, conducive to their optimal professional development.

As such, one of the directions we have focused on in recent years has been to provide our employees with access to quality medical services and to encourage preventive behavior, by conducting regular analyzes and investigations, starting from the idea that “it is easier to prevent rather than treat ”.

At the same time, because we want to offer our employees the best working conditions, in the manual on occupational safety and security, we have developed a chapter on the influence of stress on occupational safety and health.

We work to guard against complicity in human rights abuses, comply with applicable labour and employment laws, and draw on internationally recognised labour principles in how we do business. Our approach to human rights is already well integrated into our existing business practices, for example as part of our Human Capital, Procurement, Ethics & Compliance and Corporate Responsibility activities.

Principles:

We will:
• Seek to avoid causing or contributing to adverse human rights impacts through our own activities, and address such impacts if they do occur in a timely and appropriate manner.
• Seek to prevent or mitigate adverse human rights impacts that are directly related to our operations, products and services through our business relationships.
• If we identify that we have caused or contributed to adverse human rights impacts, provide for or cooperate in their remediation through legitimate processes.
• Continue to look for ways to support the promotion of human rights within our operations and our sphere of influence.

Sustainability Objective 3 addresses the issue of ensuring optimal health and well-being. In addition, this goal also draws attention to the fact that less than half of the world's population has access to basic health services.

As part of ensuring the well-being of employees, through a series of internal social responsibility programs (internal CSR) we mobilized, in turn, in 2020, respecting the conditions of social distancing in the context of limiting the spread of the coronavirus pandemic, groups of volunteers who participated in various volunteer activities. We initiated this approach in the context in which international studies show that volunteering has a number of advantages for employees and their professional development in a company.
Volunteering helps us connect with others and increases your social and relationship skills, bringing together both extroverts and introverts.

Volunteering also helps combat the effects of stress, anger and anxiety and improves mood.

Last but not least, volunteering can help us in our careers, as it gives us the opportunity to practice useful skills in any job, such as teamwork, communication, problem solving, project planning, task management and organization. Just because volunteer work is unpaid does not mean it does not provide opportunities for learning and personal development.

Also, in the context of the coronavirus pandemic, we initiated, through the HR department, an information and awareness campaign among employees on the importance of vaccination.

At the same time, throughout the pandemic and the restrictions imposed by local authorities on limiting the spread of SARS-CoV2 infection, all our offices and warehouses were equipped with heat-scanning instruments, disinfectants, disposable masks and gloves.

Unique access colors have also been created in office buildings and warehouses and all measures have been taken to ensure social distancing.

Sustainability Objective 5 refers to achieving gender equality as well as increasing the importance of women and girls in all economic and social aspects. At the same time, Objective 5 shows that despite the improvements recorded just before the SARS-CoV2 pandemic (several women in leadership positions), full gender equality has not yet been achieved.

At ESSA Sales and Distribution, gender equality manifests itself on two levels: within the company but also in the staff placed through the staff leasing services we offer to our customers in the retail industry.

Thus, at the level of 2020, out of the total management positions, 61% are occupied by women, and at the level of non-management positions, 47% are occupied by women.

Sustainability Objective 8 refers to promoting sustainable and inclusive growth, a high degree of employability as well as ensuring decent working conditions for all.

ESSA SALES & DISTRIBUTION S.A. undertakes to comply with the provisions of ILO Convention no. 100 on equal pay for men and women engaged in equal work, respectively the provisions of ILO Convention no. 111 on discrimination in the workplace.

Our company treats all employees only according to their skills and qualifications in terms of employment, advancement, compensation, benefits, internships, layoffs and termination of employment contracts.

Any discriminatory treatment based on descent, color, religion, nationality, sex, sexual orientation, age, political choice or union membership is discouraged and intolerant.

At the same time, in accordance with the European Union Directives and with the Romanian legislation in force, ESSA Sales and Distribution SA. undertakes to respect the number of working hours, the fact that overtime is voluntary and to be paid extra unless otherwise agreed in flexible working commitments; employees are provided with stipulated annual leave and sick leave without any repercussions; to ensure an income corresponding to the Romanian standards; before hiring, all employees should receive explicit information about salary conditions and exact details about the pay period; to support capable employees and, as far as possible, to be considered for future management positions; all employees shall be provided with working conditions in such a way that they are appropriate, in accordance with the general working conditions created under the protection of national standards and rules.

Last but not least, ESSA Sales and Distribution offers all its employees career development programs, designed to offer them the opportunity of lifelong learning. ESSA Sales and Distribution also has clear procedures in place to protect our employees from issues such as harassment at work of any kind: verbal, moral, sexual, physical and psychological as well as any form of forced labor, as well as a ban on employment. minors.

Regarding the involvement of ESSA Sales and Distribution in the area of ​​inclusion of various vulnerable social categories in the labor market, the company was involved last year in the project Wings4Youth - Supporting young people leaving the child protection system through a multisectoral approach. The project is coordinated by the Humanitarian Organization CONCORDIA Romania and is implemented by CONCORDIA Bulgaria and the CSR Nest Association. By involving ESSA Sales and Distribution in this project, our company reaches target 8.5.
The aim of the project is to prepare young people who are about to leave the institutionalized child protection system, in the transition to a successful independent life. The project also aims to provide young people with the information and skills needed to facilitate their access to employment.
The involvement of ESSA Sales and Distribution SA in this project materialized in the offering, for a number of 42 young people aged between 16 and 21, training on how to make a CV, advice on choosing a suitable job based on personal skills, how a potential employee presents himself at the interview.
At the same time, the 42 young people participated in a presentation of the company ESSA Sales and Distribution SA and of the employment opportunities in the fields in which it operates. Last but not least, our company participated in a series of workshops organized by the implementers of the program on public awareness and the role that advocacy practices play in improving the socio-economic and legislative context to support young people leaving the child protection system.

Integrating the Sustainable Development Goals (SDGs) in ESSA Sales' social responsibility strategy and Distribution SA represented a significant step for our company. Addressing these objectives helped us in implementing a much clearer strategic business planning ours but also in the decision-making process, which a become much more transparent and oriented towards all stakeholder categories of ESSA Sales and
Distribution.
ESSA Sales and Distribution business reporting to the 17 SDGs of sustainable development and the 10 Principles of the United Nations Global Compact (UNGC) is the main engine of the development and implementation of our policy social responsability. In addition, the inclusion of these objectives and principles of sustainable development of UNGC has made us aware of the importance of which they have on the sustainable development of our company but also the impact that these have objectives on our current operations.

We evaluate the performance either on annual basis, when we develop the annual CSR report or punctually, after or during each project in part.

We believe meaningful, sustainable employment has the power to change the world. For more than 18 years, we’ve been connecting thousands of people to work and helping them develop skills to stay employable for the long term. This way they can support their families, contribute to their communities and achieve their career goals. By respecting and promoting proclaimed human rights, we can ensure that work is a source of dignity and purpose – as well as income – for the people we employ.
ESSA SALES & DISTRIBUTION respect internationally recognized human rights as expressed in the International Bill of Human Rights, consisting of the Universal Declaration on Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social & Cultural Rights and the principles and rights set out in the eight International Labour Organization Core Conventions.

We are committed to conducting our business activities based on respecting the following human and labor rights:

1. NON-DISCRIMINATION

1.1 ESSA SALES & DISTRIBUTION does not tolerate any form of discrimination against our employees based on race, color, gender, language, religion, political or other opinions, national or social origin, property birth, sexual orientation, age, disability, or other distinguishing characteristics.

1.2. Any employment-related decisions, from hiring to termination and retirement, must be based solely on lawful, non-discriminatory criteria.

2. FORCED LABOUR
2.1 Our company does not tolerate any form of forced labor including bonded labor, indentured labor and slave labor, or human trafficking. Workers must be allowed to move around freely and leave their place of work when their working hours end.

3. CHILD LABOUR
3.1 ESSA SALES & DISTRIBUTION does not tolerate the hiring of child labor under any circumstances. The minimum age for full-time employment must be 16, according to the Romanian national work legislation, and only activities appropriate to their physical development, skills, and knowledge. Our company does not hire employees under the age of 18 for positions requiring hazardous work that could jeopardize the health, safety, or morals.

4. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING
4.1 We respect employees’ rights to form, join or not join a labor union, or other organization of their choice, and to bargain collectively in support of their mutual interests without fear of punitive actions such as intimidation, harassment, or termination of employment.

5. HARASSMENT
5.1. ESSA SALES & DISTRIBUTION protect workers from any acts of physical, verbal, sexual, or psychological harassment, bullying, abuse, or threats in the workplace by either their fellow employees or managers.

6. WORKING HOURS, BENEFITS, AND WAGES
6.1. Our company adheres to the stricter Romanian national applicable law standards, relating to minimum wages, working hours, overtime, and benefits. We provide fair and competitive compensation commensurate with the employees’ position;

6.2. Employees must not be required to work more than 48 hours a week, including overtime, regularly.

6.3. Wages for overtime must be paid in a legal tender regularly. Wage deductions as a disciplinary measure must not be permitted unless provided for by national law. Employees must be given reasonable breaks while working and sufficient rest periods between shifts.

6.4. ESSA SALES & DISTRIBUTION is committed to continuously developing employee skills and capabilities, and to providing opportunities for career advancement.

7. EMPLOYEE CONTRACTS

7.1 All employees must be provided with a written, understandable, and legally employment contract.

All the documents related to our labour policies, labour risks or violations are availible online, on the company website: https://essagroup.ro/csr/.

Also, we have an induction training and periodically trainings organized internally, where we present the company's point of view on this topic. All employees receives the Employee hand book and the Code of Conduct - documents specifying very clear our position on labour rights. Our supplier also sign, before any agreement taking place, the Supplier Code of Conduct - with specific chapter about the labour rights.

We monitor and evaluate the performance either on a monthly basis, when we have our monthly Business Activity Report, or on an annual basis, when we develop the annual CSR report.

ESSA Sales & Distribution strategy in environmental issues is to focus on the following areas and thus contribute to their protection and improvement:

We are committed to environmental matters, which means:

• Behaving in an environmentally friendly manner, not only at ESSA Sales & Distribution’s premises but also at the premises of our clients;
• Adhering to measures that impede environmental pollution, and promoting environmental protection on an ongoing basis;
• Fulfilling all applicable environmental legislation requirements and other relevant requirements;
• Separating waste thoroughly and consistently;
• Economizing resources (water and electricity);
• Checking emissions of company cars and/or cars used for business on a regular basis;
• Seeking opportunities to improve environmental protection.

Our employees/ subcontractors are informed and educated in environmental issues

To ensure our employees/subcontractors are informed and educated in environmental issues, we:

• Inform via internal campaigns, informing e-mails, etc.;
• Educate via internal training;
• Support activities in the area of environmental protection among employees.

We are an environmentally-friendly organization, which means:

• Strengthening ESSA Sales & Distribution brand perception as a “company that cares about protecting the environment”;
• Publicly presenting compliance with requirements under ISO 14001, which demonstrates our interest in environmental issues.

Separate collection of waste for recycling

Our environmental policy focuses on the idea of ​​not causing any harm to the environment as a result of the operations carried out by our company. One of the main objectives of our environmental policy is to increase the quantities of recyclable waste collected separately (paper, cardboard, PET, plastic, metal). As such, in the second half of last year, we became beneficiaries of the Today for Tomorrow in the Community project, a project of the CSR Nest Association and funded by the Coca-Cola Foundation, through which we implemented a separate waste collection infrastructure system. on 3 fractions - paper
+ carton; PET / plastic + metal and paper. - both in our offices and outdoor bins.
In the period 2019-2021, the degree of separate waste collection within ESSA Sales & Distribution increased from 15% (2019) to 30% (2020).

In a first phase, we equipped the offices in Bucharest with both indoor and outdoor infrastructure for the separate collection of waste. As a large part of 2020 took place in the form of telework, including in our offices in Bucharest and in the country, we conducted internal online information campaigns on separate waste collection and developed an internal selective collection manual for employees, which was distributed on the ESSA Sales & Distribution intranet, through the HR department.
Our goal is to reduce the amount of waste produced by our employees, starting in the middle of 2021, when we will return to the work system based on office attendance. Thus, from a separate collection rate of 15% in 2019, we aim to reach 30% by the end of 2021.
Also, within the Today for Tomorrow in the Community project, implemented by the CSR Nest Association, in 2020 I participated in a series of workshops on separate waste collection and finding solutions for better waste management, in Bucharest , Ploiești (Prahova), Pitești (Argeș county), Constanța (Constanța county). The workshops were attended in each of the counties in which we are present, employees of ESSA Sales and Distribution.

Creating green spaces for the community

The involvement of ESSA Sales & Distribution in environmental issues aims, in addition to the internal environmental policy assumed by the company, also initiatives to improve the quality of the environment, the results of which benefit entire local communities. In the context of the coronavirus pandemic, in which social distancing and spending most of your time outdoors, to avoid enclosed spaces and congestion, in October last year, we joined the pilot project of the CSR Nest Association, Green Buftea Laboratory. The community project contributed to the improvement of the urban landscape in the city of Buftea (Ilfov County), by arranging two recreational-therapeutic urban gardens.

The innovative component of the project aimed at maximizing the use of resources, according to the principles of the circular economy. Thus, in the gardens were placed containers for collecting biodegradable waste (plant debris generated in those areas), the resulting compost will be used as a natural fertilizer in these gardens. Rainwater is also collected and reused in these recreational areas.
ESSA Sales & Distribution's contribution materialized last year in providing voluntary support in landscaping and in creating a civic group among ESSA employees living in Buftea, in order to develop community projects in the local community in the city.

The company was also involved in an information campaign among the population of Buftea in regarding the importance of separate waste collection and re-use of resources according to the principles of the circular economy. This initiative addressed target 11.6 according to which, by 2030, all economic, social and political actors should contribute to reducing the impact of cities on the environment, giving increasing importance to waste management.

Business travel

Against the background of the coronavirus pandemic, in 2020 both at international and national level and at the level of ESSA Sales and Distribution, the volume of business trips decreased dramatically, so that they were replaced by the widespread use of technology, which allowed the organization professional meetings on online communication platforms.

Electricity consumption

Against the background of the coronavirus pandemic that replaced office work with either hybrid work or telework, within ESSA Sales and Distribution the energy and utilities bill decreased by an average of 40% for offices where management employees worked to coordinate projects. During the quarantine period, ESSA Sales and Distribution opted for hybrid work: either they worked in shifts, at an average capacity of maximum 30% office / shift occupancy.
However, as a measure to reduce electricity consumption, LED bulbs, motion sensors have been installed in ESSA Sales and Distribution - both in the central and regional offices - on the common access halls of the office buildings, with consumption reduced energy. In addition, electronic office equipment is energy efficient. In the future we intend to find suppliers with the support of which the purchased electricity will come from green sources.

Greenhouse gas (GHG) emissions

At Essa Sales and Distribution, one of the areas of intervention to reduce greenhouse gas emissions is the smaller-scale use of fuel-based vehicles (petrol, diesel) and the adoption of alternative means of transport.
In this sense, since 2019 we have encouraged, through human resources policies, the adoption, by our employees, of a responsible behavior towards the environment. We did this by adopting the concept of car-sharing.
At the business level, given that we cover an average of over 54,000 km per month for the implementation of POSM management programs & dramatizations at the national level, we have adopted a policy efficiency of transport routes and at the same time we included in the company's car fleet and environmentally friendly vehicles. Thus, of the 15 cars in the fleet, 2 are electric.
Compared to 2019, when the carbon footprint of ESSA Sales and Distribution was 7 metric tons of CO2 emissions, in 2020 it reached 5.8 metric tons of CO2 emissions, and for 2021 we intend to decrease to 4.5. Starting with 2022, we aim to reach the level of 3.5 metric tons of carbon emissions, given that Romania's average is 3.52 metric tons of carbon emissions.

We monitor the environmental performance either at the end of each program or once per year, when we develop our Annual CSR report.

ESSA Sales & Distribution conducts its business professionally, with integrity and in compliance with the laws of those jurisdictions in which it operates. Our reputation for acting fairly is built on our values as a company and the values of our employees. As part of our commitment to ethical business practices, we will not tolerate acts of bribery or corruption.
The Policies apply to all ESSA Sales & Distribution employees (whether permanent or temporary), contractors, officers and directors of ESSA Sales & Distribution and its subsidiaries. Third parties acting on behalf of or in the name of ESSA Sales & Distribution, including agents, representatives and other intermediaries, are required to act consistently with ESSA Sales & Distribution Anti-Bribery Policy.
ESSA Sales & Distribution operates a zero tolerance approach to bribery and corruption in relation to bribes (payment, offer or promise to pay or provide anything of value), gifts and hospitality, facilitation payments (small payments or fees to speed up or facilitate the performance of routine action to which an entitlement already exists) and payments to government officials.
Third parties engaged to represent ESSA Sales & Distribution’s interests must comply with the principles set out in the Anti-Bribery Policy.
Including, but not limited to, local employment requirements, ethical practices, safe working environments, freedom from discrimination, freedom from harassment, freedom of expression and association, forced labour, child labour and human trafficking, our Code of Conduct reflects ESSA Sales & Distribution’s commitment to conduct its business professionally, with integrity and in compliance with the laws of those jurisdictions in which it operates.

Our Policy establishes the basic principles and requirements for compliance with the provisions of Applicable Anti-Corruption Laws by the Company, the Employees of the Company, and any Agents of the Company.
This Policy pursues the following goals:
• Describing the Company’s prohibitions against bribery and corruption in all of its business operations.
• Preventing any manifestations of corruption, both on behalf of and regarding the Company and/or its Employees; compliance with the requirements of applicable Anti-Corruption Laws when the Company engages in its business activities.
• Reinforcing the Company’s commitment to conduct business globally with the highest standards of honesty and integrity.
• Perfecting and developing the Company’s corporate culture, implementing the best practices and standards of responsible business conduct, including in the area of Anti-Corruption Compliance.

REQUIREMENTS

1. PROHIBITED AND RESTRICTED PAYMENTS

1.1 Offering, promising, and authorizing the giving of money, or anything else of value, to a government official to secure an improper advantage is strictly prohibited.

1.2 No employee may offer, give, promise or receive money, or anything else of value, to or from an individual or entity in the private sector to obtain an improper advantage.

1.3 Even the mere act of offering is prohibited, regardless of whether or not the item of value is accepted by the intended recipient.

1.4 The prohibition covers cash payments, benefits, and favors. In certain circumstances, it also covers otherwise legitimate business expenditures such as gifts, entertainment, travel, donations, sponsorships, or training.

1.5 The above-mentioned payments are prohibited regardless of whether or not they are made directly or indirectly through third-party intermediaries.

2. PERMISSIBLE PAYMENTS

2.1 This policy permits employees to provide modest gifts, hospitality, or certain other things of value to government officials and private individuals that are legal and directly related to the promotion or demonstration of the ESSA SALES & DISTRIBUTION’s services or the performance of a particular Company contract with a government or state-owned or state-operated entity.

2.2 When deciding whether a gift is appropriate, employees must take into account any past, pending, or future business or administrative matters that are within the recipient’s realm of influence. The timing and context of such gifting must be considered to assess whether any particular gifting could objectively be perceived as bribery.

3. TRAVEL, EDUCATION, AND RELATED EXPENSES INVOLVING GOVERNMENT OFFICIALS

3.1 ESSA SALES & DISTRIBUTION may accept requests to host government officials for training or other business-related purposes either at the company’s facilities or at training events sponsored by outside vendors. The company may also accept requests to host government officials at operational meetings, project meetings, or other events.

3.2 The payment of travel expenses to any government official, within or outside their home country, requires the prior written consent of the compliance representative to ensure consistency with this policy and any national applicable laws.

4. CHARITABLE DONATIONS AND SPONSORSHIPS

ESSA SALES & DISTRIBUTION supports the making of contributions to the communities in which it does business and permits reasonable donations to charities and sponsorships. In this respect:

4.1 Reasonable steps must be taken to verify that any such contribution does not constitute an illegal payment to a government body or official or any individual in violation of this policy.

4.2. It may be permissible to make donations directly to a government agency (rather than to an individual government official) as part of a charitable effort or to promote goodwill through actions such as providing free products for a government-sponsored celebration.

5. THIRD PARTIES
5.1 ESSA SALES & DISTRIBUTION can be held liable for the actions of third parties, particularly where a third-party intermediary performs services or otherwise conducts dealings, discussions, or negotiations with public or private organizations for or on behalf of the company.
5.2 The Company may also be held accountable for failing to take sufficient steps to prevent third parties from participating in bribery or related conduct, whether or not the Company was aware of the alleged improper conduct.
5.3 Third parties must never be asked to engage in or condone any conduct that employees are prohibited from engaging in themselves under this policy.
5.4 Also, an employee must never turn a blind eye to suspected violations of this policy by third parties or disregard otherwise suspect circumstances.
5.5 All third parties conducting business with, for, or on behalf of the ESSA SALES & DISTRIBUTION are required to act with the highest level of business, professional and legal integrity.
5.6 The company must never enter into any relationship with a third-party intermediary who will have substantive interaction with government officials on behalf of the company without first inquiring into the third party’s background, qualifications and reputation.

5.7 The most important steps the ESSA SALES & DISTRIBUTION can take to protect itself from liability for improper payments made by a third party are to carefully choose its business partners, including agents and consultants, and to be aware of “red flags”.

6. BOOKS, RECORDS, ACCOUNTING, AND PAYMENT PRACTICES
6.1 To prevent the possibility of bribes and kickbacks being paid or accepted, ESSA SALES & DISTRIBUTION must fairly and accurately reflect each transaction involving the company.
6.2 Secret, unrecorded or unreported transactions are prohibited.
6.3 All expenses must be accurately accounted for, include appropriate supporting documentation, and be promptly entered into company records before they are reimbursed.
6.4 The requirement under section 7.3 includes, but is not limited to, the accurate identification (in expense reports, related business, and financial records) of all payments to third-party intermediaries acting for or on behalf of the company.

7. DISCIPLINE
7.1 The ESSA SALES & DISTRIBUTION and its employees can be investigated by government regulators and, depending on the circumstances, prosecuted administratively, under civil law or under criminal law, which could result in severe fines and penalties, debarment, and imprisonment if a violation of applicable anti-bribery and corruption laws and regulations is established.
7.2 Any employee found to violate this policy will be subject to disciplinary action, up to and including termination of employment, following applicable laws and company policies.

ESSA Sales and Distribution is committed to conducting business in an honest and fair manner, respecting the principles of business integrity. And for that to happen, each of us, the company's employees, needs to act ethically. Our anti-corruption policy applies to ESSA GROUP and its subsidiaries and applies to all employees of our company, without exception: the President and Chief Executive Officer, officials, vice-presidents, directors and other managers, all personnel employed within the Company, in associated companies and members of the Board of Directors of the Company (collectively referred to as "Employees"). ESSA Sales and Distribution takes corruption issues very seriously, and the company's management is committed to maintaining the highest standards of professional and ethical conduct. This commitment is reflected in the Company's culture and policies, which include the zero tolerance approach to all forms of corruption committed by Employees or third parties acting on behalf of ESSA Sales and Distribution. As such, all contracts concluded by our company with all business partners include business ethics clauses / anti-corruption clauses. Zero tolerance, including the code of business conduct are very well established and communicated in our CSR strategy and statement.

ESSA Sales and Distribution is committed to conducting business in an honest and fair manner, respecting the principles of business integrity. And for that to happen, each of us, the company's employees, needs to act ethically. Our anti-corruption policy applies to ESSA GROUP and its subsidiaries and applies to all employees of our company, without exception: the President and Chief Executive Officer, officials, vice-presidents, directors and other managers, all personnel employed within the Company, in associated companies and members of the Board of Directors of the Company (collectively referred to as "Employees"). ESSA Sales and Distribution takes corruption issues very seriously, and the company's management is committed to maintaining the highest standards of professional and ethical conduct. This commitment is reflected in the Company's culture and policies, which include the zero tolerance approach to all forms of corruption committed by Employees or third parties acting on behalf of ESSA Sales and Distribution. As such, all contracts concluded by our company with all business partners include business ethics clauses / anti-corruption clauses. Zero tolerance, including the code of business conduct are very well established and communicated in our CSR strategy and statement.

We monitor and evaluate the anti-corruption performance on an annual basis, when we develop the CSR Annual Report.