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KESTREL ROW LOGISTICS B.V. - GIFTS AND HOSPITALITY POLICY (version 3, effective 1 January 2026)

1. Purpose. Staff may not offer or accept anything that could influence a business decision.
2. Limits. Gifts to or from a third party must not exceed EUR 75 in value per person per year. Meals with a business purpose must not exceed EUR 120 per person.
3. Public officials. No gift, meal or hospitality may be offered to a public official without written approval of the Compliance Officer.
4. Tenders. During an open tender no gift or hospitality of any value may be exchanged with a bidder or the contracting party.
5. Register. Every gift or meal above EUR 25 is recorded in the register within 5 working days.
6. Approval. Anything above the limits needs the Compliance Officer's prior written approval.