We have approved and implemented an Anti-Bribery & Corruption (ABC) management system since 2018. Integrated alongside our Model 231, Anti-Corruption Policy, and Code of Ethics within a unified Anti-Corruption Framework, the ABC system operationalizes our strategic commitments by identifying business areas most vulnerable to corruption risk and deploying robust assessment, mitigation, and monitoring mechanisms.

The system is subject to continuous review to drive ongoing improvement.

As a core component of our Internal Control and Risk Management System (ICRMS), the ABC framework leverages and aligns existing organizational controls, optimizing operational and documentary synergies across our diverse compliance safeguards.

Beyond preventing explicit bribery offences, the ABC system functions as an active control and governance tool addressing broader integrity risks. This encompasses behaviors and malpractices—even where they do not cross the threshold of a specific criminal offence—that breach internal policies and procedures, or otherwise threaten the company’s reputation, sound management, and long-term interests (maladministration). It is designed to achieve the following overarching objectives:

• Prevent and mitigate corruption risks and equip the company with appropriate measures and tools suited to achieving this purpose.
• Promote the proper functioning of internal processes by ensuring that management and employees are fully aware of the risks associated with corrupt practices.
• Strengthen the principles of legality, integrity, fairness, and transparency in the management of corporate activities and resources.
• Enhance the progressive rationalization, simplification, optimization, and synergy of existing corporate control mechanisms, avoiding redundancies and fostering coordination among all stakeholders involved.

The recipients of the Anti-Corruption Management System are the Company’s Directors, Senior Management, Control/Oversight Bodies, employees, external consultants and collaborators in any capacity, auditors, suppliers, business partners, and, more generally, anyone who directly or indirectly, temporarily or permanently, has dealings with FS Engineering. This highlights the cross-functional nature of its operational scope and the total commitment of the Company as a whole.