Management Commitment

Top management of READ! Ltd.:

1) Taking accountability for the effectiveness of the quality management system.

2) Ensuring the quality policy and quality objectives are established for the quality
management system and are compatible with the context and strategic direction of READ!
Ltd.
3) Ensuring the integration of the quality management system requirements into the READ!
Ltd.’s business processes.
4) Promoting the use of the process approach and risk-based thinking.
5) Ensuring the resources needed for the quality management system are available.
6) Communicating the importance of effective quality management and of conforming to the
quality management system requirements.
7) Ensuring the quality management system achieves its intended results.
8) Engaging, directing and supporting persons to contribute to the effectiveness of the quality
management system
9) Promoting improvement.
10) Supporting other relevant management roles to demonstrate their leadership as it applies to
their areas of responsibility.
11) Ensuring customer and applicable statutory and regulatory requirements are determined,
understood and consistently met.
12) Ensuring the risks and opportunities that can affect conformity of products and the ability to
enhance customer satisfaction are determined and addressed.
13) Ensuring the focus on enhancing customer satisfaction is maintained.

Top Management
President and CEO
READ! Ltd.
May 8th, 2025

Quality Policy

Referring to the company purpose and strategic direction, our commitment is executed by:

 Identifying, understanding and meeting the requirements from our customers and other
relevant stake holders.
 Monitoring and continuously improving our processes and management system to support
our value chain from innovation through delivery to customer.
 Assessing and mitigating risks to ensure the safe, reliable and effective processes, products
and services.
 Building a strong partnership with our customers, employees and suppliers based on
cooperation and accountability
Each employee is accountable to deploy this Quality Policy through its relevant responsibilities and
authorities.

Top Management
President and CEO
READ! Ltd.
May 8th, 2025

Anti-bribery and Anti-corruption Policy

Applicability
Global

Scope
This Anti-bribery and Anti-Corruption Policy (herein after refer to as ‘Policy’) applies to READ! Ltd.
and all of its consolidated subsidiaries, to READ! Ltd.’s workforce (meaning its officers, employees –
whether full-time, part-time or temporary – and contractors). READ! Ltd.’s workforce shall take
steps to ensure that anyone doing business with or on behalf of READ! Ltd. including contractors,
consultants, advisors, agents, lobbyists, distributors, resellers, suppliers and business associates, as
well as their respective officers, employees and subcontractors (collectively ‘READ! Ltd. Business
Partners’) comply with the terms of this Policy.

Objective
To ensure that READ! Ltd. remains in compliance with all anti-bribery and anti-corruption laws in
effect in all parts of the world in which it does business, as well as to demonstrate READ! Ltd.’s firm
commitment to acting with integrity at all times and to conducting business globally in an ethical
and legal manner.

Background
Corruption is now recognized as an important issue around the world and most countries or regions
have enacted some form of legislation to outlaw bribery and other forms of unethical and corrupt
behavior, in both the public and private sectors. READ! Ltd. has always prided itself on conducting
its business ethically, but it is more important than ever that we make sure that we avoid even the
perception of corruption or other illegal dealings. While jail time and individual and corporate fines
are well-publicized penalties, reputational damage and huge costs are other major problems faced
by companies found guilty of bribery or other illegal behavior.

This Policy reflects and expands on the provisions of the READ! Ltd.’s Codes of Conduct.

Statement of Principle
1) READ! Ltd., its workforce and READ! Ltd. Business Partner shall never engage in bribery,
meaning that they shall not offer, promise or give anything of value to anyone, directly or
indirectly, with the intent to obtain or retain business or otherwise to gain an improper
advantage for READ! Ltd.
2) READ! Ltd.’s workforce shall never solicit or accept money or anything else of value from
any person or organization while conducting READ! Ltd. business.
 3) Accurate and complete accounting records, including expense reports, must be kept of all
transactions entered into the course of READ! Ltd.’s business dealings.

Meaning in the Statements of Principle of “Offer, Promise or Give”

A crime is not just committed if a bribe is given to someone. Anti-bribery laws also prohibit merely
offering or promising a bribe, even if it is either refused or is not in fact paid or given, or even if it is
being given to a third party that is not part of the business transaction, such as a designated
charity.

Meaning of “Anything of Value”

Anti-bribery laws interpret “anything of value” very broadly. So, it means anything that is
considered to be of value by the intended recipient. While it might be cash, it could just as easily be
tickets, a job offers or internship (even unpaid) for a family member, an electronic device, meals,
alcohol, a fishing or golf trip, sexual favors, and so on. Or it could be a commission, an extra
discount, sponsorship, travel, etc.

Meaning of “Directly or Indirectly”

The term “directly” means doing it yourself, while “indirectly” means arranging for or allowing
someone else to do it on your behalf. If a third-party bribe someone for you, you are just as liable as
if you hand done it in person. In fact, far from insulating you from responsibility for a bribe,
deliberately using an intermediary would increase your exposure to fines and/or jail time. It is no
defense to claim that you didn’t know about a bribe, if you should know – meaning, for example,
that you looked the other way, that you chose not to do background checks or other due diligence,
or that it was likely that a bribe would be paid.

Meaning of “An Improper Advantage for READ! Ltd.”

What makes an advantage improper is that it influences someone to do something that they
otherwise would not do in the course of a business relationship. For example, entertaining the
procurement director of a government or commercial customer could be perceived as bribery, if it
is seen as influencing in READ! Ltd.’s favor for the selection of the winner of the customer’s
upcoming contract award.

Anti-bribery/Anti-corruption Laws
Most countries and international institutions now have laws or conventions that address bribery and
corruption, but the ones you will probably hear most about are the Japanese Penal Code and Unfair
Competition Prevention Act, the U.S. Foreign Corrupt Practices Act, the Criminal Law of the People’s
Republic of China, the U.K. Bribery Act, the Swiss Penal Code, the French Loi Sapin II, the OECD
Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,
and the Inter-American Convention against Corruption. Each of these laws has extra-territorial
effect, meaning that a breach resulting in a penalty can occur anywhere in the world.

Government or Public Officers

While bribery of anyone is unacceptable, the consequences of bribing government or public officers
are particularly severe.
Regardless of whether domestic or foreign, government or public officers include:
a) Any person who provides services for national or local governments.
b) Any person who provides services for an agency or organization affiliated with a government
entity.
c) Any person who provides services for a public enterprise or state-owned entity.
d) Any person who is an employee or agent of an international public organization (for
example, the United Nations, World Trade Organization or World Bank).
e) Any political party, party official, or candidate for political office.
f) Any person authorized by a government entity to exercise a public function.
g) Active or reserve members of police and armed forces.
h) Educational and medical employees of state-owned entities, including professors and
doctors.
i) Journalists and representatives of state-controlled media.
j) Members of ruling or royal families.

Facilitation or “Grease” Payments

Meaning of facilitation or “grease” payments:
Such payments are made for routine administrative activities that a government or public officer is
already supposed to perform and they are considered bribery. Common examples include visas,
customs’ clearance, cargo handling, permit or license issuance, utility hook-ups, and building or
safety inspections.

READ! Ltd. does not allow facilitation or “grease” payments to be made, even if they are culturally
acceptable in some countries. They may in rare instances be permitted, when there is an
immediate threat to life, safety, security or freedom, or if public officers can provide a formal
receipt or written confirmation of their legality. However, you must promptly report such payments
to Legal and Compliance and record them accurately in finance and accounting records.

Gifts, Travel and Entertainment

Lavish or extravagant gifts, travel and entertainment (“GTE”) are a major area of enforcement
focus by anti-corruption authorities, notably if the GTE led to favorable treatment by or improper
influence from the recipient or other party. In particular, there is a growing push-back against all
cash or cash-equivalent gifts, including red envelopes and gift, restaurant and store cards, even in
countries in which they were previously an integral part of the culture. READ! Ltd. prohibits the
giving of any cash or cash-equivalent gifts.

Red Flags
The most common “red flags” for bribery and corruption are:
• Bribery known or suspected to occur regularly in a given location such as a high-risk country
under the Corruption Perception Index (CPI).
• High fees or discounts; “extra margin”.
• Lack of relevant expertise.
• Third party refusal to certify compliance with anti-bribery/anti-corruption laws.
• Use of unapproved third parties or consultants to conduct a transaction.
• Late addition of a previously unknown third party to a transaction.
• A party with a history or reputation of unethical behavior.

• Offshore and/or cash payment requests.

• Relationships between a party (e.g., consultant or distributor) and local public officers.
• Requests for charitable donations or political contributions.
• Requests for things of “value” (e.g., a paid trip to a resort, lavish gifts, reimbursement of a
family member’s expenses, etc.).

Measures to Prevent Bribery and Corruption

READ! Ltd. will:

1) Assign qualified staff to manage anti-corruption promotion within its organization.

2) Periodically train its workforce (meaning its officers, employees – whether full-time, part-
time or temporary - and contractors) on how to recognize and avoid bribery and corruption.
3) Ensure that human resources practices, including recruitment, promotion, training,
performance evaluation, remuneration, recognition and business ethics in general, reflect
these Rules.
4) Undertake due diligence on all entities with which it does business, including when making
investments, charitable donations and political contributions.
5) Verify the legality and appropriateness of contract terms by undertaking the laid down
procedure for “Legal Review and Approval of Contracts”.
6) Obtain management and Finance approval of payment arrangements.
7) Develop separate Policies to address the giving and receiving of GTE, as well as charitable
donations and political contributions.
8) Where applicable, include in contracts specific provisions that prevent bribery and
corruption.

Exception to this Policy

Should any READ! Ltd.’s workforce wishes to adopt stricter or more lenient principles or examples
than those outlined in this Policy, an application must be made in writing to the HRM, whose
decision on such exceptions will be final.
 READ! Ltd. Codes of Conduct
The READ! Ltd. Codes of Conduct consist of rules and principles intended to assist officers and
employees in making decisions and taking actions in accord with the READ! Ltd. Group Codes of
Conduct. All officers and employees of READ! Ltd. shall understand and follow the Codes of Conduct
and act with sincerity and fairness in a highly ethical manner.

1. Toward a Sustainable Society

1) We will contribute to resolving social issues by promoting innovative solutions, accelerating
collaborative creation with partners and stakeholders, and further integrating social and
environmental responsibility into our business activities.
2) We will strive to develop technologies that contribute to social development and use them
with due consideration of their impact on society.
3) We envision a low-carbon society, a resource efficient society, and a harmonized society with
nature. To this end, we will endeavour to reduce CO2 emissions, use water and other
resources efficiently, and minimize impacts on natural capital throughout our value chain.
4) As a corporate citizen, we will make efforts to build rapport with communities and contribute
to their development by working together to resolve social issues.

2. Sincere and Fair Business Activities

2.1 Fair Trading
1) To ensure fair and open competition, we will observe the fundamental rules of trade, including
domestic and overseas competition laws and regulations, and act in compliance with
legislation and sound corporate ethics.
2) We will have no relationship whatsoever with antisocial forces anywhere in the world, and
resolutely reject involvement in improper or antisocial transactions.
3) We will not trade shares using undisclosed information regarding the group, affiliated
companies, business partners, or customers that could affect the judgment of investors
(insider information).
4) We strictly prohibit and will have no involvement in bribery and other corrupt business
practices. We will neither give or receive gifts nor extend or accept invitations to business
entertainment beyond socially accepted limits, as we recognize that such practices can foster
corruption. When working with political entities, we will build and maintain sound and
transparent relationships.
5) We will help maintain international peace and security through compliance with all applicable
laws and regulations concerning import and export, and will operate appropriately according
to our internal rules and policies.
6) We will comply with applicable laws, respect social cultures and practices, and act sincerely
and fairly in countries and regions where we have operations. Furthermore, we will do so
guided by international norms and standards even in areas where legislation is not
adequately enforced.

2.2 Relationship with Supplier

1) With a global vision, and mindful of the long-term perspective, we will find qualified suppliers
and build fair and equal partnerships with them, working together to build mutual
understanding and trust.
 2) In selecting suppliers, we will thoroughly review the quality, reliability, delivery time, and price
of the materials they provide as well as their business stability and technological capability.
We will give due consideration to their adoption of social responsibility practices, including
areas such as the abolition of unfair discrimination, the elimination of child labor and forced
labor, and environmental conservation.
3) We will not accept any personal benefits from suppliers in procurement transactions.

2.3 Relationships with Customers

1) We will provide products and services that meet the needs and requirements of our
customers, complying with relevant laws and standards and ensuring quality and safety by
setting additional standards of our own where necessary.
2) We will communicate with customers sincerely, address defects and customer complaints
quickly and in good faith, and strive to determine causes in order to eliminate them and
prevent recurrence.

3. Respect for Human Rights

1) We will promote our understanding of internationally recognized human rights, and will
respect and not infringe on the human rights of all those involved in our business activities.
2) We will implement human rights due diligence appropriate to the social circumstances of the
countries and regions where we have operations and the nature of our businesses, products,
and services there.
3) We will assess and prevent potential violations of human rights. In the event of such a
violation, we will promptly take internal and external actions to correct and remedy the
situation.
4) We will respect individual human rights in the recruitment and treatment of employees and
during all other company activities. We will not engage in any acts that may impair individual
dignity or discriminate on bases such as sex, sexual orientation, age, nationality, race,
ethnicity, ideology, belief, religion, social status, family origin, disease, disability.
5) We will hire employees in compliance with the relevant laws and regulations in each country
and region, and in accordance with international norms and standards. We will not use child
labor that employs children below the minimum working age or forced labor that is against
the will of employees.
6) We will strive to resolve issues through sincere and constructive discussion between
management and employees, in compliance with the laws, regulations, and labor practices of
each country and region, and in accordance with international norms and standards.

4. Building a Work Environment That Brings Out Employee Strengths

1) Prioritizing health and safety above all else, we will strive to ensure the safety of employees
and the workplace. In addition, we will promote the physical and mental health of employees
and their families.

2) We will support flexible work styles and respect diverse values, creating workplaces that
provide employees with a sense of accomplishment and personal growth, and we will promote
the sustainable growth of the organization and individuals.
3) We will invest in educational programs to help employees expand their capabilities and
exercise their strengths. Supervisors will fairly and appropriately support, guide, and educate
their employees to develop their abilities.

5. Information Management and Communication

1) We will promote the ethical handling of information, so as to ensure respect for human rights
and security, through the proper management of personal information based on our Personal
Information Protection Policy.
2) We will properly manage and protect confidential information related to our business
activities in compliance with domestic and international laws and regulations as well as our
internal rules and policies.
3) In order to maintain and expand our trusting relationship with the READ! Ltd.’s diverse
stakeholders, we will disclose information openly and transparently, and respond to
stakeholders responsibly through dialogue and other means of communication.

6. Protection of Intellectual Property and Brand

 1) We will protect our own intellectual property, respect third-party intellectual property, and
use both effectively for smooth business operations.
2) We will manage our own and third-party confidential information by importance and manage
and handle it appropriately based on this ranking.
3) We will protect and enhance the value of the READ! Brand and READ! Brand, recognizing it
as an important management asset.

7. Securing Corporate Assets

We will use all our corporate assets only for business activities and other appropriate purposes, and
manage them properly to protect their value.

8. Responsibilities of Employees
Employees shall pledge to comply with the Codes of Conduct. If they become aware of any non-
compliant activity, they shall immediately report to their manager or via the internal reporting
system.

9. Responsibilities of Top Management

Top managers shall take the initiative in complying with the Codes of Conduct and make their best
efforts to conduct business based on corporate ethics and the law. In the event of violation of the
Codes of Conduct, top managers shall swiftly take corrective measures and actions to prevent the
recurrence of similar incidents, while at the same time strictly disciplining themselves as well as
those involved in the violation.

READ! Ltd. Whistle-blowing Policy

Introduction
READ! Ltd., together with its group companies, subsidiaries, and affiliates, maintains a culture of
openness and is committed to the highest standards of sincerity, accountability, and ethical
conduct.

An essential characteristic of our open culture is the availability of appropriate channels for READ!
Ltd.’s employees and other stakeholders to report concerns in good faith and the ability to do so
without fear of reprisal.

READ! Ltd.’s Code of Ethics and Business Conduct identifies various channels to report a concern.
These channels include managers, Human Resources, Legal, Ethics & Compliance departments, and
the READ! Ltd. Compliance Hotline (thereafter referred to as hotline). READ! Ltd. employees and
other stakeholders can report a concern anonymously, where permitted by law, through the hotline
if they wish to do so.

It is the responsibility of every READ! Ltd. employee to speak up and report misconduct when they
see it. Managers have a responsibility to listen to concerns and respond appropriately.

1. Scope and Exclusion

This policy applies to:
 All current and former READ! Ltd.’s employees (whether full-time or part-time).
 Those belonging or once belonged to administrative, management or supervisory boards of
READ! Ltd.
 Those who supply/supplied goods or services to READ! Ltd., including secondees, external
consultants, contractors (extended workforce) or to those working under the supervision of
such persons.
 Agency personnel.
 Customer executing sales contract with READ! Ltd.
 Those who acquire information during a recruitment process or pre-contractual discussions
with READ! Ltd.
 Shareholders of READ! Ltd.
 Civil servants.
who are seeking to report a concern about actual or suspected misconduct (in the European Union
(EU), such concerns will include the Relevant Concerns listed in Annex 1, and all such individuals
are referred to collectively as Relevant Individuals)
This policy also applies to third persons with a connection to the persons mentioned above (such as
their colleagues or relatives, persons providing them with assistance, or legal entities connected to
them).

This policy does not govern employee grievances, complaints relating to job performance, or the
terms and conditions of employment, which are not by their nature complaints which relate to a
potential malpractice / material misconduct.

If this policy indicates a requirement that is less restrictive than the local regulatory requirements
or in conflict
with the local law, the applicable regulatory requirement must be followed, and READ! Ltd.’s Chief
Compliance Officer shall be notified. Any deviation from this policy shall be requested in writing
from READ! Ltd.’s Chief Compliance Officer.

This policy may be amended from time to time and may be supplemented with additional local
measures to account for local law or local regulatory requirements.

2. Policy Requirements
3.1. Reporting a concern
3.1.1) The availability of various speak-up channels within READ! (Managers, Human Resources,
Ethics and Compliance and Legal departments, and the hotline) allows people to choose the
channel most suitable to their circumstances. Concerns can be reported in writing or orally,
including through face-to-face meetings, upon request by the reporting person, or through
the hotline (telephone or online). The hotline is available 24/7 and allows a person to remain
anonymous, where permitted by law. Where a person requests a face-to-face meeting, the
meeting shall be arranged to take place as soon as reasonably possible.
3.1.2) While READ! would like employees to feel comfortable speaking up internally and allow the
company the chance to deal with the issue, nothing in this policy prohibits employees from
reporting possible violations of laws or regulations including but not limited to any relevant
government agency or entity for the concerned jurisdiction, which may be appropriate in
certain circumstances.
3.1.3) Any concern reported by a person shall be taken seriously and addressed appropriately,
promptly, and (as far as is possible in the circumstances) confidentially, with appropriate
feedback provided to the person.

3.2. Evaluation of concerns

3.2.1) Concerns shall be evaluated promptly and effectively to determine the appropriate course of
action. Such evaluation should be completed within three business days of receiving the
concern, but no later than seven calendar days.
3.2.2) Evaluation of material misconduct shall include consultation with the READ! Ltd.’s Chief
Compliance Officer or their delegate, each business unit’s or group company’s head of
compliance or their delegate, Human Resources or Legal as appropriate.
3.2.3) Persons designated to receive and/or investigate concerns shall have the competency,
capacity, and appropriate authority to manage and follow up on the reports. These persons
shall be independent and abstain from the case if they have any conflicts of interest related
to the case and report the conflict of interest according to the Conflicts of Interest protocols.

3.2.4) Persons shall be notified of the receipt of the concern promptly and in any event within
seven business days of raising it. Appropriate lines of communication shall be maintained
with the person, and further information may be sought from them as required.
3.2.5) READ! Ltd.’s Chief Compliance Officer or each business unit’s and/or group company’s head
of the compliance shall be notified of any material misconduct including where a concern
becomes material misconduct during the investigation.

3.3. Protection
READ! has a zero-tolerance policy for retaliation of any kind against persons who report concerns.
3.3.1) This policy is designed to offer protection to persons who had reasonable grounds to believe
that a concern had arisen at the time of reporting.
3.3.2) Protection is available to persons reporting a concern anonymously if the conditions of this
policy are met.
3.3.3) Protection shall be provided against all forms of actual, threatened or attempted retaliatory
measures (in the EU, these will include the specific measures listed in Annex 1). Persons can
also consult a legal advisor to obtain advice on the procedures and remedies available to
them, their protection against retaliation and their rights as a whistleblower.
3.3.4) Protection cannot apply to those who report information already fully available in the public
domain or unsubstantiated rumors and hearsay where they do not have a reasonable belief
in a possible concern.
3.3.5) Except for cases where identifying the person who reported the concern is essential to
conduct the investigation, READ! officers/employees shall not attempt to identify the
reporter and those supporting the investigation.
3.3.6) Any act of retaliation shall be treated by READ! as a violation of its applicable rules and
policy and could result in disciplinary action up to and including dismissal.
3.3.7) Disciplinary action may be taken by the company against any employee deliberately raising
false and malicious allegations or otherwise acting in bad faith.

3.4. Confidentiality
3.4.1) Strict confidentiality shall be applied, to the extent possible, to handling concerns, including
investigation details and the identity of the person making the allegation.
3.4.2) READ! shall take all reasonable steps to maintain confidentiality as far as possible during
and after the reporting and investigations processes to ensure that the person making the
report, the reported concern, or any other persons or items mentioned in the report are not
improperly disclosed to non-authorized persons.

3.5. Investigation
3.5.1) READ! is committed to following up appropriately, promptly, and (as far as is possible in the
circumstances) confidentially, with appropriate feedback provided to the person on concerns
raised.

3.5.2) READ! officers/employees are required to cooperate with investigations conducted in

accordance with this policy.
3.5.3) The forms of malpractice/ material misconduct which could warrant an investigation and
might require formal disciplinary action (including termination of contract or dismissal in the
most serious cases) include but are not limited to:
 Breach of READ!’s internal policies and READ! Group Code of Ethics and Business
Conduct.
 Fraud or corruption, including bribery.
 Irregularities involving accounting or other financial procedures.
 Commission of any criminal offense.
 Conduct which is, or may be, in conflict with READ!’s interests, for example,
inappropriate contacts with a business competitor.
 Dishonesty or other irregularities in dealing with customers and suppliers.
 Conduct that endangers the health and safety of the public, employees and other READ!
workers and visitors.
 Failure to comply with a legal obligation.
 Environmental damage arising from READ!’s activities or those of its employees or
workers on READ! Business.
 Discrimination, bullying and harassment.
 Act or omission resulting in damage or risk of harm to human rights or the environment.
 Breach of any other legal or regulatory requirement.
3.5.4) Chief Compliance Officer (each group company’s) or each company’s head of compliance
shall appoint an investigator who will take responsibility for the investigation, including
notifying the investigator of the confidential obligations they would be bound to. The criteria
for selecting an investigator and the way of appointment (by email or in writing) are outlined
in the Concerns Management policy.

3.6. Response and timescale

It is imperative that the person making the report is informed of the investigation progress and
outcome within a reasonable timeframe -- not exceeding three months -- and as much as legally
possible without breaching confidentiality to build and maintain trust in the effectiveness of the
concerns management process, including whistleblower protection. In complex cases where this
timeframe could be longer, the person should be informed within a reasonable timeframe and given
an expected completion date for the investigation. Even where READ! might be constrained by
confidentiality, it shall still try to provide the reporter with as much information as possible about
the steps that have been taken in response to their concerns.