CIT One Anti-Corruption Policy

Employee accountability must represent an integral part of our business model. Our behavior and attitude dictate how we are perceived by our clients, both at an individual level and at the organizational level, as the Company reflects its employees.

We are more than 1,700 individuals, each with distinct responsibilities, duties, and perspectives, yet we share the common responsibility of safeguarding the integrity of the organization’s image. Therefore, within CIT One, we uphold a zero-tolerance approach towards any act of corruption.

1. What is Corruption and how is it understood within CIT One?

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

Corruption encompasses a range of illicit and immoral activities or actions, carried out not only by individuals but also by groups and organizations, whether public or private, with the aim of obtaining material or moral benefits or a superior social status by means of abuse, coercion, blackmail, deception, bribery, intimidation, threats etc.

Within CIT One, corruption is understood as follows:

• The act of an employee or collaborator to promise, offer, or give, directly or indirectly, to a person in a decision-making position, any material advantage, for themselves or for another person who may provide a facilitation, with the purpose of influencing that person to perform or refrain from performing an act, thereby breaching their employment obligations;
• The act of an employee, collaborator, or equivalent to solicit or receive, directly or through another party, an undue material advantage for themselves or for another person, or to accept the promise of such an advantage, with the purpose of influencing that person to perform or refrain from performing an act, thereby breaching their employment obligations.

2. Why the Anti-Corruption Policy is necessary

The Anti-Corruption Policy is necessary so that all of us, as employees of the organization, share the same understanding of business conduct based on integrity, transparency, and honesty, and adopt a proactive attitude in combating corruption.

We 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 solidity of all business activities carried out by CIT One.

We are and represent CIT One before clients, suppliers, or any other persons with whom we come into contact. Therefore, we must uphold high standards of integrity and professionalism and adopt respectful, honest, and open conduct in everything we do, regardless of circumstances, even if such conduct may result in losing a business opportunity or affect the reputation of our organization.

CIT One is committed to complying with both national and international legislation regarding the fight against corruption. The rules and principles set forth in the legislative framework apply equally to all of us: employees, collaborators, suppliers, legal representatives, or any person acting on behalf of the organization.

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

It is far more important to respect the rules and principles set out in this document than to pursue new business opportunities or maintain business relationships with existing or potential clients at any cost. Therefore, no employee, collaborator, or partner of the Company shall be sanctioned, penalized, or warned for complying with the ethical considerations of CIT One’s Anti-Corruption Policy.

3. Procurement Process

All procurement processes are carried out centrally, in accordance with CIT One’s internal procedures regarding internal administration and contract execution.

Any supplier attempting to bribe an employee or a manager within CIT One in order to influence a bidding or award process shall be immediately disqualified and permanently restricted from participating in future procurement processes.

Furthermore, we encourage all suppliers to report any request for undue benefits made by an employee, collaborator, or manager within CIT One, with the intent to distort or alter a bidding or award process. Such complaints are centralized at the following email address: citone.whistleblower@citone.ro.

4. Company Policy on Donations and Sponsorships

We understand the need for societal development and aim to play an important role in the growth of Romanian society. We want to take part in initiatives that support the cultural, social, and educational development of the community.

CIT One may, on an annual basis, subject to its financial results, provide sponsorships to public, cultural, and educational institutions. As we place the reputation and integrity of our organization above all else, we only sponsor entities with an impeccable reputation and whose collaboration will not adversely affect CIT One’s reputation or financial standing.

CIT One is not a political organization. Therefore, it does not provide, directly or indirectly, sponsorships or donations to political parties or political organizations, nor does it support, directly or indirectly, 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 Identify Any Form of Corruption Quickly!

Do not remain passive when you are exposed to a situation or an individual that violates the values, rules, or principles of our organization.

Report it! We have made available to you, through the Whistleblower Policy (C045), the following channels for reporting any suspicion or concern you may have regarding a potential case of corruption:

• Dedicated phone line: +40 723 215 205
• E-mail: citone.whistleblower@citone.ro

6. How We Sanction Corruption Cases

We uphold a zero-tolerance approach to acts of corruption. Any breach of this Policy or applicable legislation is considered a serious violation and may result in the permanent termination of any contractual or collaborative relationship with CIT One.

7. How We Define

Bribery – any form of reward offered with the intent to influence a person to act dishonestly, illegally, or to fail to fulfill their duties.

Bribery may include direct or indirect payments, services, excessive gifts, charitable donations, sponsorships, or preferential treatment. Facilitation payments are small payments made to expedite a service to which the payer is already legally entitled.

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

CIT One Employee – any individual employed by CIT One, regardless of the type of contract (management, mandate, administration), including temporary employees or collaborators.

CIT One Partner/Collaborator – any natural or legal person performing activities for CIT One under a commercial contract (e.g. providers of goods or services).

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