Anti-Corruption and Anti-Bribery Policy

Version 1.0 · October 2026

Statement

Muculo Retail has zero tolerance for corruption and bribery, active or passive, direct or through third parties, in the public or private sector.

Framework

This policy takes into account, among others, the criminal and public-integrity legislation of Angola (including the Penal Code, Law No. 38/20, and the Public Probity Law, Law No. 3/10), the Portuguese Penal Code and General Regime for the Prevention of Corruption (Decree-Law No. 109-E/2021), and the applicable laws of other jurisdictions in which we operate.

Prohibited conduct

• Offering, promising, giving, requesting or accepting any improper advantage.
• Facilitation payments to public officials, including in customs and port processes.
• Using third parties to do what the company cannot do directly.
• Political contributions or donations used in exchange for benefits.

Gifts and hospitality

Only occasional, transparent gifts and hospitality of symbolic value, with no intention to influence a decision, are allowed. When in doubt, prior advice is mandatory.

Third parties

Before engaging customs brokers, agents and intermediaries, we carry out risk-proportionate due diligence and include anti-corruption clauses in contracts.

Records and controls

All transactions are recorded accurately and completely. Creating funds or records that conceal the true nature of operations is prohibited.

Reporting and non-retaliation

Any suspicion must be reported to the Whistleblowing Channel. No one will suffer retaliation for reporting in good faith or for refusing unlawful conduct, even if it means losing business.