10 Responsible business conduct We take responsibility to actively combat corruption and bribery and work according to the guidelines in our code of conduct. Countering corruption is a fundamental issue for Semper There is always a risk that corruption will spread in a business. Bribery, extortion and price cartels can be established and both individuals and entire industries can be damaged. We minimise the risk for financial impropriety in our operations and supply chain through active work against corruption and bribery. The legislation in the countries where we operate and our code of conduct form the basis of Semper's work against corruption. The group's code of conduct follows the principles of the UN Global Compact to combat corruption, extortion and bribery. Our anti-corruption policy is available to all employees via our intranet. New and existing employees in the finance and IT department, who hold positions where there is an increased risk of encountering corruption issues, received training in responsible business conduct in 2022. Hero group and thus Semper is connected to Ecovadis, a platform that rates suppliers in four di“erent sustainability areas, one of which is precisely responsible business. You can read more about Ecovadis in the section Our raw materials of this report. Rules regarding invoicing To avoid irregularities or abuse within Semper's own financial system, we have rules and procedures for how invoices should be handled and how new suppliers should be added. For example, the same person may not approve a whole series of transactions. An employee who adds a new supplier to our system must also not be able to initiate an invoice from that supplier. Once an invoice is in our business system, there is a well- developed set of routines that governs who can approve and pay the invoice. Whether an employee is allowed to approve and pay an invoice depends, among other things, on the position they have and on the invoice amount. Semper has had no case of corruption or bribery in 2022.

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