1. VELUX Anti-corruption – training course You’ll be presented with situations and dilemmas – and are to decide, how the VELUX employee Martin should act.. 1 Title/Department/Archive/Author

2. Content Introduction The VELUX Anti-Corruption Policy – in short Anti-Corruption Compass Dilemmas Meet our employee 1 st Scenario: A costly connection 2 nd Scenario: At the development site 3 rd Scenario: A request for a donation 4 th Scenario: A sports event 5 th Scenario: A suspect payment 6 th Scenario: A family connection Feedback 1 st, 2 nd, 3 rd, 4 th, 5 th, 6 th Scenario Summing up 2

3. Introduction Sometimes you can find yourself in a position where you need to make a choice. And if you choose wrong, it may have unintended consequences for you, a customer, a business partner or your workplace. During this course, you will be presented with a number of situations and dilemmas and are to decide how the VELUX employee should act. When finished, you will have acquired some guidelines and tools that can help you make the right choices in such everyday dilemmas. 3

4. The VELUX Anti-Corruption Policy – in short In short, the policy give the following instructions: Conflicts of interest: We always inform the immediate manager whenever business involves family, friends or other persons related to the decision- maker. Bribery: We neither offer nor accept payment to secure an undue advantage. Extortion: We work against extortion and always resist giving in to illegal coercion. Facilitation payments: We are opposed to paying additional charges to public authorities to speed up routine duties. Money laundering: We reject money laundering, whichever illegal activities are involved, observe all rules on that subject and cooperate with the authorities. Gifts and entertainment: We neither give nor accept large gifts or excessive forms of entertainment. Charity: It must always be ascertained that any kind of charity is not a cover for bribery or could be perceived as such. 4

5. Anti-Corruption Compass The anti-corruption compass can help you deal with difficult decisions. When faced with a dilemma, ask yourself the following questions: Is it legal and ethical? Is it consistent with the VELUX Anti-Corruption Policy, Core Values and Model Company Objective? How would I feel if it was reported in a newspaper headline? Would I feel comfortable telling my family and friends? 5

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24. Feedback Feedback according to your answers + a general feedback 24

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31. Summing up Questions? 31