Corruption and bribery

Material impacts, risks, and opportunities and their interaction with strategy and business model (SBM-3)

Corruption prevention is a key sustainability-related issue for NORMA Group that is directly related to the corporate strategy and business model. The risks identified in the area of corruption and bribery can have a material impact on financial stability, reputation, and long-term business development and have therefore been classified as material. In order to manage this influence, NORMA Group has established a comprehensive compliance system with actions and control mechanisms. Strengthening integrity and fair business practices is an integral part of the corporate values and the strategic vision “We join forces to provide superior solutions for a sustainable future.”

Policies related to prevention and detection of corruption and bribery

NORMA Group has established the Anti-corruption Policy as a sub-guideline of the Code of Conduct and thus an elementary component of the Compliance Management System. The aim of the guideline is to prevent corrupt behavior and establish clear rules of conduct. It is intended to strengthen confidence in the integrity of the organization and avoid legal risks from corrupt practices. The guideline provides basic knowledge about corruption, corruption risks, and risky transactions as well as NORMA Group’s actions to reduce corruption risks. This guideline applies throughout the Group. It contains binding requirements regarding the granting and acceptance of benefits in the context of business relationships with third parties (i.e., persons who are not employed by NORMA Group). The guideline explicitly defines prohibited practices and specifies which benefits are subject to a mandatory prior check and therefore require approval. The guideline is regularly reviewed and updated in order to meet the relevant requirements. An update was carried out in financial year 2025.

NORMA Group is currently unable to state whether the Anti-corruption Policy is fully compliant with the United Nations Convention against Corruption. A detailed comparison will be carried out in the next regular review in 2026. NORMA Group has not developed a plan to revise the policy. It can be assumed that all commercial employees could, in principle, be exposed to a risk of corruption.

Processes related to prevention and detection of corruption and bribery (G1-3)

NORMA Group has implemented procedures to prevent, detect, and appropriately deal with incidents of corruption and bribery. These procedures include an Anti-corruption Policy that defines clear guidelines and behavior. This is supplemented by mandatory training for all commercial employees. In addition, violations can be reported to NORMA Group Compliance via the defined reporting channels – also anonymously. NORMA Group employees and external third parties can anonymously report any actual or alleged misconduct in relation to NORMA Group via the whistleblower system. A report must not lead to disadvantages for the reporting person. NORMA Group’s compliance organization follows up on indications of compliance violations.

Suspicious cases are handled by NORMA Group Compliance, which decides on further action on a case-by-case basis and, if necessary, with the involvement of the Compliance Committee. Where appropriate and necessary, the specific investigation of suspected cases may be delegated by NORMA Group Compliance to Internal Audit or external third parties.

If necessary, indications of compliance violations are discussed by the Compliance Committee in accordance with the criteria defined in the Compliance Committee Charter and a decision is made on how to proceed. The reporting channels are defined and fixed – irrespective of the actual implementation of an investigation. NORMA Group Compliance reports exclusively to the Management Board member responsible for this area.

In addition to defined regular reporting, the criteria for any ad hoc reporting to the Management Board member responsible for the area are also defined. The Compliance Committee decides whether ad hoc reporting is required if defined materiality thresholds are potentially exceeded.

NORMA Group ensures that the Code of Conduct and the Anti-corruption Policy are accessible and as comprehensible as possible for all relevant parties: Employees can view the guidelines at any time on the intranet. The Code of Conduct is attached to the employment contracts and is covered in the compliance training sessions. The guidelines are available in up to eleven languages to ensure global comprehensibility. Interested stakeholders can publicly view the compliance guidelines on the NORMA website. Suppliers receive the “Supplier Code of Conduct” as part of the onboarding process and updates to ensure that they understand and comply with NORMA Group’s standards, particularly with regard to the prevention and detection of corruption and bribery.

Measures related to prevention and detection of corruption and bribery

In financial year 2025, NORMA Group continued the established training and awareness programs in the area of corruption and bribery. There were no material changes or progress compared to the previous year, as the existing actions have already been fully implemented and are firmly anchored in the Company. NORMA Group’s training curriculum also covers the topics of corruption and bribery. Basic corruption topics are already covered in the e-learning course on the Code of Conduct. The “Anti-corruption” training course provides more detailed and in-depth coverage of the subject matter. The training content is closely aligned with the underlying Code of Conduct and Anti-corruption Policy. All commercial employees are obliged to complete the two training courses. Additional training and updates are offered as required to keep knowledge up to date. The “Gifts & Invitations” brochure is also available on the intranet site and contains important information on handling gifts, invitations, and other benefits.

Targets related to preventing and detecting corruption and bribery

NORMA Group pursues the clear goal of consistently preventing corruption and bribery. The Company is committed to a zero-tolerance policy toward any form of unethical or illegal behavior. Integrity, transparency, and a sense of responsibility form the basis of NORMA Group’s business activities – both internally and in its dealings with business partners.

Metrics related to preventing and detecting corruption and bribery

Completion rate of the “Corruption and bribery” training course

The existing training programs are designed to cover 100% of the employees in the functions identified by NORMA Group Compliance as being at risk with regard to corruption. In financial year 2025, 96% of the corresponding training courses were completed. NORMA employees in the “salaried” employee class were classified as high-risk functions. Training is mandatory for all employees in the “salaried” employee class, including managers and members of the Management Board. In addition, members of the compliance organization receive special onboarding training, which also includes anti-corruption content.

Confirmed incidents of corruption or bribery (G1-4)

NORMA Group takes a stand against corruption and bribery and reports transparently on confirmed incidents. In financial year 2025, there were no convictions and no fines for violations of corruption and bribery regulations. These metrics are collected by the legal department, which obtains information from the CFOs of the individual companies. These report on fines and convictions of the individual companies, which are then combined across the Group. Fines are allocated to the reporting year in which the decisions became legally binding. One limitation is that reporting persons may not fully disclose fines. NORMA Group has introduced an anti-bribery and anti-corruption policy, which contains detailed procedures and standards as described in the section CORPORATE CULTURE AND VALUES (G1).