CIT One Anti-Corruption Policy

Employee accountability must be an integral part of our business model. Our behavior and attitude determine how we are perceived by our clients, both individually and at the organizational level, which, from this perspective, is a reflection of us—its employees.

We are over 1,700 people, with different responsibilities, roles, and ways of thinking, but we share the common responsibility of safeguarding the integrity of the organization’s image.
Therefore, within CIT One, we maintain zero tolerance toward any act of corruption.

1. What is corruption and how do we understand it within CIT One?

Corruption represents an abuse, active or passive, direct or indirect, committed by a CIT One employee/collaborator for the purpose of obtaining financial advantages or other undue benefits (goods or services) for themselves or for third parties connected to a CIT One employee.

Corruption encompasses a range of unlawful and unethical activities/actions carried out not only by individuals but also by various groups and organizations, public or private, for the purpose of obtaining material or moral advantages or a higher social status through the use of abuse, coercion, blackmail, fraud, bribery, intimidation, threats, etc.

Within CIT One, corruption is understood as:

• The act of an employee or collaborator of promising, offering, or giving, directly or indirectly, to a person with decision-making authority, any material advantage, for themselves or for another person who may provide a benefit, with the purpose of causing that person to perform or refrain from performing an act, thereby breaching their obligations as an employee;;
• The act of an employee/collaborator or equivalent of requesting or receiving, directly or through an intermediary, an undue material advantage for themselves or for another person, or accepting the promise of such an advantage, with the purpose of performing or refraining from performing an act, thereby breaching their obligations as an employee.

2. Why the Anti-Corruption Policy is Necessary

The Anti-Corruption Policy is necessary so that all of us, the employees of the organization, understand in the same manner the principles of business conduct based on integrity, transparency, and honesty, and also to ensure that we adopt the same proactive attitude in combating corruption-related phenomena.
TWe must demonstrate zero tolerance towards any form of corruption, as the actions of a single employee may affect the reputation of the organization and the stability of all business activities carried out by CIT One.We are and represent CIT One in relation to clients, suppliers, or any other persons with whom we come into contact. Therefore, we must maintain high standards of integrity and professionalism and adopt respectful, honest, and transparent conduct in all our activities, regardless of the circumstances, even if such conduct may result in the loss of a business opportunity or may affect the reputation of our organization.

CIT One has undertaken to comply with national and international legislation regarding the prevention and combating of corruption. The rules and principles set out within our legal framework apply to all of us: employee, collaborator, supplier, legal representative, or any person acting on behalf of the organization

None of us shall request or offer bribes or any other material advantages of any kind. We expect to be treated in the same manner by our collaborators and business partners.

It is far more important to comply with the rules and principles set out in this document than to develop new business opportunities or to establish business relationships with existing or potential clients at any cost. Therefore, none of us, whether employee, collaborator, or partner of the Company, may be sanctioned, penalized, or warned for complying with the ethical considerations of the CIT One Anti-Corruption Policy.

3. Procurement Process

Any procurement process is carried out centrally, in accordance with CIT One’s internal procedures regarding internal administration and the execution of contracts.
We will immediately disqualify and permanently restrict access to future procurement processes for any supplier who attempts to corrupt an employee or a person holding a management position within CIT One in order to influence a tender/award process.

In addition, we encourage all suppliers to report any request for undue benefits made by an employee, collaborator, or a person holding a management position within CIT One, aimed at distorting or altering a tender/award process. Complaints of this type are centralized at the following email address: citone.whistleblower@citone.ro .

4. Organization’s Policy on Donations and Sponsorships

We understand the need for societal development and aim to play an important role in the development of Romanian society. We seek to participate in actions that support the cultural, social, and educational development of society.

CIT One may, each year, based on its financial results, support public, cultural, and educational institutions through sponsorships. As we place the reputation and integrity of our organization above all else, we sponsor only entities with an impeccable reputation and which, through the collaboration, will not negatively affect CIT One’s reputation or financial standing.
We are not a political organization. Therefore, we do not sponsor or provide donations, directly or indirectly, to political parties/organizations and do not directly or indirectly support any political campaign.

All donations/sponsorships shall be made exclusively by bank transfer and shall be properly recorded in the accounting records of both the sponsor/donor and the beneficiary organization. CIT One reserves the right to request reimbursement of the amounts subject to the donation/sponsorship if it determines that the beneficiary has used the funds improperly or in a manner inconsistent with the purpose of the sponsorship or donation.

5. Help Us Quickly Identify Any Form of Corruption

Inform us. Through the Whistleblower Policy (C045), we provide the following reporting channels for any suspicion or concern you may have regarding a potential case of corruption:

• Dedicated telephone line +40 723 215 205;
• Email address citone.whistleblower@citone.ro

6. How We Sanction Cases of Corruption

We maintain zero tolerance for acts of corruption. Therefore, any breach of this policy or of national legislation regarding the prevention and sanctioning of corruption is considered a serious violation of the values, rules, and principles of our organization, leading to the termination of any contractual or collaborative relationship with CIT One, both currently and in the future.

7. Definitions:

Bribery - any form of reward offered with the intention of influencing any party to act dishonestly or illegally, or to fail to perform their duties.
Bribery may take many forms, including offering or accepting direct or indirect payments, services, excessive gifts, charitable donations, sponsorships, or preferential treatment.
Facilitation payments are small payments made to secure or expedite a service to which the payer is legally entitled.

Corruption - an abuse, active or passive, committed by a CIT One employee for the purpose of obtaining financial advantages or other undue benefits for themselves or for third parties.

CIT One Employee - any employee of CIT One, for the duration of the contract concluded with the organization, regardless of its type (management contract, mandate, or administration), including temporary staff (leasing, part-time, collaborators).

CIT One Partner/Collaborator - any natural or legal person providing services to CIT One under a commercial contract (e.g., supplier of goods or services).

C0 C027.10-2025 – Anti-Corruption Policy within CIT One