3. Anti-corruption

S&P expects its Suppliers to have a zero-tolerance approach to corruption and all other forms of prohibited and unethical business practices.

The Supplier is committed to exert reasonable due diligence and have reasonable policies and processes in place to prevent, detect avoid and tackle financial crime, including but not limited to corruption, em- bezzlement, fraud, extortion, tax evasion, sanctions violations and money laundering in all its business arrangements.

In all of its operations and activities, the Supplier must refrain from bribery or any other unfair influence that could lead to business advantages or give the impression of such unfair influence.

4. Conflict of Interest

The Supplier must avoid interaction with any S&P employee that might, or appears to, conflict with the employee acting in the best interests of S&P. The Supplier should not offer any improper advantage to an S&P employee or their family members in order to gain business.

Supplier should seek to avoid conflicts of interest and timely disclose to S&P both actual and potential conflicts.

The Supplier shall comply with all competition and anti-trust laws. This includes agreeing not to enter into discussions or agreements with competitors regarding price fixing, market sharing, bid rigging or other similar activities.

5. Reporting misconduct

S&P expects its Suppliers to promote a culture of high standards of ethics, integrity and openness. S&P has established a channel to report actual, planned or potential misconduct on the part of employees, Suppliers or subcontractors.

Suppliers can report relevant cases by sending a notification to apenhetsloven@soderbergpartners.com.