Anti-bribery Policy

BioARS Therapeutics S.A., fully recognizing the importance of combating corruption and bribery, as well as the potential reputational and operational risks associated with any involvement in such practices, has established and implements this Anti-Bribery Policy, approved by the Chairman & Chief Executive Officer of the company.

This Policy is binding on all employees, without exception, regardless of their functional role or hierarchical level, and extends to administrators, subcontractors, suppliers, consultants, all types of business partners, and any third party acting on behalf of the company.

The purpose of this Policy is to raise awareness among all employees and partners regarding bribery, reinforce the Management’s commitment to a zero-tolerance approach, and provide a structured framework of obligations and guidelines to prevent, deter, and combat bribery effectively.

Specifically, this Policy:

• Prohibits bribery both within and outside the Organization.
• Ensures compliance with applicable legal and regulatory frameworks for anti-bribery measures.
• Is aligned with the company’s purpose and business activities.
• Provides a framework for setting, reviewing, and achieving anti-bribery objectives.
• Encourages confidential reporting of any incidents or suspicions of bribery through designated communication channels, promoting vigilance among employees and partners in identifying bribery-related activities, while ensuring trust and protection from retaliation.
• Complies with the requirements of the Anti-Bribery Management System in accordance with ISO 37001:2016 and aims for continuous improvement of the system.
• Defines responsibilities and enforces the independence of the Anti-Bribery Compliance Committee.
• Non-compliance with, or refusal to adhere to, this Anti-Bribery Policy by any individual, including subcontractors, suppliers, consultants, all types of business partners, and any third party acting on behalf of the company, will result in immediate cessation, suspension, or non-initiation of any business relationship.

Stakeholders are encouraged to contact the company to report any unlawful or suspicious business activities potentially involving BioARS Therapeutics S.A. via e-mail: compliance@bioars-th.gr