Ethical business conduct

X5 Group is committed to ensuring that the actions of the Company and its employees are in line with the Group’s corporate values, standards of ethical business conduct and applicable regulatory requirements.

X5 adheres to employment practices that promote integrity within the Company and help create long-term value. X5 has by-laws in place that set out the corporate values and policies in terms of ethical business conduct that the Company expects all employees to comply with. These by-laws include the following:

X5 also welcomes the commitment of its business partners to comply with the Company’s values and applicable rules of ethical business conduct. X5 Group operates a direct line to the CEO on corruption, a hotline to the Security Director, an ethics hotline, an Ethics Committee, and other ways to report violations and prevent possible abuses.