Anti-Corruption Policy

of KrambergAI GmbH

Status: May 2026

Preamble

KrambergAI GmbH is committed to conducting all business activities with integrity, responsibility and in full compliance with applicable laws. Trust, transparency, fairness and professional independence form the basis of our cooperation with customers, partners, suppliers, public institutions and all other business stakeholders.

This Anti-Corruption Policy defines the principles and expectations regarding the prevention of corruption, improper influence and unethical business conduct. It applies to all employees, executives, partner companies, suppliers, subcontractors, freelancers and any individuals or organizations acting on behalf of or in the interest of KrambergAI GmbH.

Our objective is to promote a transparent and trustworthy corporate culture in which decisions are made objectively, transparently and free from improper influence.

1. Zero-Tolerance Principle

KrambergAI GmbH maintains a strict zero-tolerance approach towards all forms of corruption, bribery, improper advantages or unethical influence.

Business decisions must be based exclusively on objective, economically justifiable and lawful criteria. Any conduct intended to improperly influence decisions or obtain unjustified advantages is prohibited.

This applies regardless of whether advantages are granted or accepted directly or indirectly.

2. Prohibition of Improper Advantages

The following are prohibited in particular:

  • monetary payments or cash equivalents,
  • inappropriate gifts,
  • hidden commissions or kickback payments,
  • excessive invitations or hospitality,
  • personal favors,
  • private benefits,
  • concealed intermediary compensation,
  • manipulative influence on procurement or decision-making processes.

It is also prohibited to engage in conduct intended to accelerate decisions, secure preferential treatment or circumvent objective procedures.

Indirect benefits provided through third parties, consultants, intermediaries or affiliated entities are equally prohibited if intended to improperly influence decisions.

3. Gifts, Invitations and Business Courtesies

Reasonable business courtesies and customary hospitality are generally permissible provided that they are:

  • appropriate,
  • transparent,
  • socially customary,
  • legally permissible,
  • properly documentable,
    and not intended to influence business decisions.

Gifts, invitations or other benefits must never create the impression that they are intended to improperly influence decisions.

Particular caution must be exercised when dealing with:

  • public authorities,
  • public institutions,
  • municipalities,
  • schools,
  • educational institutions,
  • state-owned enterprises,
  • political organizations,
  • entities governed by public law.

In cases of doubt, the principles of restraint and transparency shall apply.

4. Cooperation with Public Sector Entities

Interactions with public authorities and public sector clients require particularly high standards of transparency and integrity.

Any advantages, payments or benefits intended to influence public decisions are strictly prohibited. This also applies to so-called facilitation payments and indirect influence through third parties.

Applicable procurement, competition and public budget regulations must be strictly observed.

5. Conflicts of Interest

Conflicts of interest must be identified, disclosed and managed transparently at an early stage.

A conflict of interest exists in particular where personal, family-related, financial or other private interests may influence business decisions or create the appearance of impaired objectivity.

Business decisions must always be made independently, objectively and transparently.

6. Transparent Processes and Documentation

KrambergAI GmbH values transparent and traceable decision-making processes.

Procurement procedures, purchasing decisions, project evaluations, contractual commitments and financial decisions should be transparent, reviewable and objectively justifiable.

Clear responsibilities, documented approvals and traceable decision paths help minimize the risks of manipulation, conflicts of interest and improper influence.

7. Selection of Partners and Service Providers

When selecting partners, suppliers, consultants and service providers, integrity, professionalism and compliance conduct are considered alongside technical and commercial qualifications.

We expect our business partners to comply with applicable anti-corruption laws and comparable ethical standards.

Partners and suppliers are required to implement appropriate measures to prevent corruption, bribery and improper influence within their own organizations.

8. Reporting and Whistleblowing

All employees, partners and business stakeholders are expected to report suspicious activities, unusual conduct or potential corruption risks without undue delay.

Reports will be treated confidentially and reviewed objectively. Individuals reporting concerns in good faith shall not suffer disadvantages as a result.

The objective is the early identification and prevention of legal, financial and reputational risks.

9. Training and Awareness

Integrity and compliance require a shared understanding of responsible conduct.

Employees should receive regular information regarding relevant risks, behavioral expectations, warning signs and reporting procedures.

Where appropriate, partners and suppliers should also be informed about relevant compliance expectations and standards.

10. Consequences of Violations

Violations of this Anti-Corruption Policy are taken seriously.

Depending on the nature and severity of the violation, appropriate measures may be taken, including:

  • internal investigations,
  • discussions and corrective actions,
  • restrictions of cooperation,
  • termination of contractual relationships,
  • claims for damages,
  • legal action.

Our primary objective is prevention, transparency and responsible cooperation.

11. Final Provisions

This Anti-Corruption Policy forms part of our commitment to responsible, transparent and law-abiding business conduct.

We expect all individuals and organizations working with or on behalf of KrambergAI GmbH to acknowledge and actively support these principles.

Integrity, fairness and transparent conduct are essential foundations for sustainable and trustworthy business relationships.