Page 30 - EINF2022

NON-FINANCIAL INFORMATION STATEMENT

3.3.
Anti-Corruption, Bribery and Money

Laundering

TWG does not under any circumstances accept these practices internally or in
its dealings with customers, suppliers and all our stakeholders. To combat them, Description TWG Management
we have various internal procedures in place to ensure that we do not engage
in corruption, bribery and money laundering, and these are included in our
Code of Conduct. External audit of the financial statements reflecting a true and fair view of
our performance.

Performing bank reconciliations.
We also act with complete political neutrality and are not affiliated with or
contribute to any political party or political representative. We express our Approval mechanisms with different levels of authorisation.
firm rejection of those practices, prohibiting for example the receipt, delivery,
promise or offer of any kind of payment, commission or gift to authorities or Monthly monitoring of financial reporting.
public officials, or those practices that involve the avoidance of the payment Anti-Corruption,
of taxes or duties to the detriment of the Tax Authorities, the Social Security Bribery and Money Analysis and planning of direct investments or necessary improvements.
or any other administrative body of the local or regional administrations. In Laundering
addition, we do not do business with entities that do not comply with these Purchasing management procedures where purchases over ¤ 15,000 must
guidelines or that give rise to doubt or cannot demonstrate compliance with be approved by the CEO, subject to authorisation by the Plant Manager and
these guidelines. Purchasing Manager in the case of TWA and ¤ 5,000 at TWL.
Non-use of banks in tax havens, non-use of cash except for the company’s
petty cash or the use of provisions for personnel funds, among others.
In order to comply with these premises, we have the corresponding controls,
among which we would like to highlight some, as many have already been Training for our staff based on our Code of Conduct.
described in the corresponding Risks Section:

During the reporting period of this NFIS there have been no non-compliance
situations or incidences with regard to corruption, bribery and money
laundering.

Non-Financial Information Statement — 2022 TWGroup 30