COMPLIANCE STATEMENT

1. Anti-corruption, sanctions and export control

We maintain a zero-tolerance policy towards corruption, bribery and conflicts of interest. Given the size of our company and our risk profile — operations within the Netherlands and the EU, with no business relationships in high-risk countries — this policy is proportionate in design. In concrete terms: employees may not offer or accept gifts, payments or favours that could influence business decisions; all payments are made exclusively through traceable banking channels and no material cash transactions take place; management reviews every new business relationship before an agreement is entered into; and employees can report suspected irregularities directly and confidentially to management.

In addition, we operate a strict sanctions and export control policy. Business relationships are screened against the consolidated EU sanctions list, and we follow the guidelines and licensing requirements of the Dutch Central Import and Export Office (CDIU). We do not enter into transactions with sanctioned parties, entities or countries. Where export licences are required, they are applied for through the CDIU and documented. Responsibility for these controls rests with [management / role]. To date, we have had no corruption- or sanctions-related incidents.

2. Support for the UN Guiding Principles on Business and Human Rights

We endorse the principles of the UN Guiding Principles on Business and Human Rights (UNGPs): we respect human rights in our own operations and expect the same of our business partners. As a company operating within the Netherlands and the EU, without supply chains in high-risk countries, our human rights risk exposure is limited. We nevertheless recognise our responsibility to prevent adverse human rights impacts and to address them where necessary.

3. How this support is expressed

Our support for the UNGPs is expressed in our day-to-day business conduct: compliance with Dutch and European labour and human rights legislation, fair employment conditions, screening of business relationships against the EU sanctions list, and careful selection of suppliers.

4. Human rights due diligence process

Our due diligence process is proportionate to our risk profile and follows the six steps of the OECD Guidelines for Multinational Enterprises, in line with the UNGPs.

  1. Responsible business conduct is embedded in our policies: integrity and respect for human rights are part of our company policy and are actively upheld by management.
  2. We identify and assess risks by periodically reviewing our value chain. Our suppliers and customers are located within the Netherlands and the EU, where labour and human rights are safeguarded by law; we have no operations or supply chains in high-risk countries. Screening against the consolidated EU sanctions list forms part of every business relationship assessment.
  3. We prevent and mitigate adverse impacts: when selecting new suppliers and customers we assess reliability and compliance with applicable laws, and for export transactions we follow CDIU guidelines, including applying for export licences where export control regulations require. These checks take place before any transaction is entered into.
  4. We monitor implementation: management reviews annually whether the company’s risk profile has changed — for example through new suppliers, customers or markets — and whether the policy needs updating; changes to the EU sanctions list are tracked.
  5. We communicate how impacts are addressed, informing stakeholders about our approach on request, including through questionnaires and statements such as this one.
  6. Should our company nonetheless become involved in an adverse human rights impact, we will ensure appropriate remediation and apply the lessons learned to our processes.

Given our limited risk profile, we consider this process appropriate and effective. It is reviewed whenever there is a material change in our activities or value chain.