Anti-Corruption Policy

1. Introduction

Levelfour Belgium (hereinafter referred to as “the Company”) is firmly committed to upholding ethical and

legal conduct in all its activities. Corruption, in all its forms, is incompatible with the

values of our Company. This anti-corruption policy (the “Policy”) outlines the principles, the

responsibilities, and the measures that Levelfour Belgium has put in place to prevent, detect, and address

any corrupt behaviour.

2. Scope of Application

• This Policy applies to all employees of Levelfour Belgium, including

staff, executives, and directors.

• It also applies to third parties acting on behalf of the Company: agents,

consultants, suppliers, partners, or subcontractors.

• It concerns all operations conducted in Belgium as well as, where applicable, abroad.

3. Belgian Legal Framework

• In Belgium, legislation penalises both corruption between private agents and the corruption

of public agents.

• Legal entities (companies) can be held criminally liable for antibriberyguidance.org)

acts of corruption committed on their behalf.

acts of corruption committed on their behalf. ( antibriberyguidance.org)

• Facilitation payments are also prohibited in Belgium,

even if they are of low value. (ACE FORENSIC)

• Belgium has also strengthened the protection of whistleblowers, allowing anyone

with knowledge of potentially corrupt activities to report them safely.

(Justice Belgium)

4. Guiding Principles

Levelfour Belgium adopts a zero-tolerance policy towards corruption. The following principles

guide our commitment:

1. Integrity: All employees must act with honesty, avoiding any form

of undue advantage to obtain or retain business.

2. Transparency: Any business relationship, donation, gift, or invitation must be justified,

documented, and must not compromise impartiality.

3. Legality: Strict compliance with applicable laws and regulations, particularly regarding

corruption.

4. Responsibility: Every employee and third party associated with Levelfour Belgium has the responsibility to comply

with this Policy.

5. Reporting: Strong encouragement to report any suspicion or attempt of corruption without

fear of retaliation.

5. Key Definitions

• Corruption: Offering, promising, giving, soliciting, accepting, or receiving an undue advantage, whether

directly or indirectly, in order to obtain or retain a business advantage.

• Public official: A person holding public office (for example, a

public official).

•  Third parties: Any person or entity external to Levelfour Belgium (suppliers, consultants, etc.).

•  Whistleblower: A person who has reason to believe that an act of corruption has

occurred or could occur and who reports it in accordance with internal procedures.

6. Obligations of employees

•  Never offer, promise or give any advantage (money, gift, service, invitation, etc.) to

anyone with the aim of improperly influencing a business decision.

•  Never solicit or accept an advantage if it could be perceived as undue, in

violation of applicable rules.

•  Document and report any offer, receipt or proposal of advantage: gifts, invitations,

hospitality expenses, etc.

•  Comply with internal procedures for expenses, gifts and relationships with third parties.

•  Participate in anti-corruption training provided by the Company.

7. Relationships with third parties (suppliers, partners, agents)

•  Third parties must be informed of this Policy and commit to comply with it when they

work for or with Levelfour Belgium.

•  Anti-corruption clauses must be included in contracts with suppliers,

agents or partners.

•  Risk assessments (due diligence) must be carried out, particularly for third parties

in high-risk geographical areas or for significant transactions.

in high-risk geographical areas or for significant transactions.

8. Gifts, invitations and hospitality

• Gifts or invitations must not be excessive or inappropriate. They must be

proportionate, legitimate, transparent and in accordance with normal business practices.

normal.

• Any gift/invitation of significant value must be approved by Roxane Foucart,

compliance officer.

• Monetary gifts are prohibited.

9. Accounting and records

• Transactions must be recorded accurately, transparently and in a detailed manner.

detailed.

• No accounting entry should conceal induced payments or illicit benefits.

• All records (invoices, expense reports, receipts) must be kept for a period that complies with

internal legal requirements.

10. Reporting and protection of whistleblowers

• Levelfour Belgium establishes a secure internal channel (e.g. dedicated email address, physical

box, hotline) to report any suspicion of corrupt behaviour.

• Whistleblowers are protected: any retaliation against someone who reports in good faith a

violation or attempt at corruption will be considered a serious breach.

serious breach.

• Roxane Foucart, as Compliance Officer, will be the point of contact for receiving reports and

following up on investigations.

11. Investigation and sanctions

• Each report will be examined impartially and confidentially by the compliance department.

under the supervision of Roxane Foucart.

• If an investigation reveals a violation of this Policy, disciplinary measures will be

taken, which may include dismissal.

• In the case of a serious breach, Levelfour Belgium may also initiate criminal

or civil proceedings, and cooperate with the relevant Belgian authorities.

12. Training and Awareness

• All employees will receive initial training on this Policy upon their hiring.

• Refresher sessions will be organised at least once a year.

• Regular communications (newsletters, posters, workshops) will help maintain awareness.

awareness.

13. Risk Assessment and Audits

• Levelfour Belgium will periodically conduct a corruption risk analysis, taking into

account its sector, markets, partners, and operations.

• Internal audits (financial, operational) will verify compliance and the effectiveness of this

Policy.

• Roxane Foucart is responsible for coordinating these assessments with an

external consultant if necessary.

14. Policy Review

• This Policy will be reviewed at least once a year, or more frequently if legislative

or operational changes require it.

• Any amendments will be approved by the management of Levelfour Belgium.

15. Compliance Officer

•  Roxane Foucart is appointed as Compliance Officer for

Levelfour Belgium.

•  Her responsibilities include: overseeing the implementation of this Policy, receiving

reports, conducting investigations, coordinating training, carrying out risk assessments,

and reporting to management.

16. Conclusion

Levelfour Belgium reaffirms its commitment to fighting corruption by adopting high standards

of ethics, transparency, and legality. Every member of the company, as well as our

external partners, must adhere to these principles. By respecting this Policy, we protect not

only our reputation but also the sustainability of our activities.

Steven LECOMTE

CEO

Roxane FOUCART

Compliance Officer