Anti-Corruption and Anti-Bribery Policy

This Anti-Corruption and Anti-Bribery Policy (the "Policy") is issued by Premium Logistics SHPK, a limited liability company (shoqëri me përgjegjësi të kufizuar) registered in the Republic of Albania with NUIS/NIPT M53004202C at the National Business Center (Qendra Kombëtare e Biznesit, QKB), with its registered office at Rruga "Dubai", Lagjia nr. 2, cadastral zone 2066, property no. 89/38, 4-storey building, 2nd floor, Entrance 1, Kamëz, Tirana, Albania (the "Company", "we", "us" or "our"). The Company operates the independent vehicle sourcing, real-time bidding and import-support platform marketed under the trading brand "Premium Auto Bid" (the "Platform").

This Policy is effective from 4 June 2026 and was last updated on 4 June 2026. It states the standards of conduct that the Company requires in order to prevent, detect and respond to bribery and corruption, and it forms part of the Company's broader compliance framework alongside its Member Terms, Terms of Use, Privacy Policy, Anti-Money-Laundering Policy, Know-Your-Customer Policy and Sanctions Compliance Policy. Where there is any conflict between this Policy and a specific contract, the stricter anti-corruption standard applies.

This Policy applies to all directors and the administrator of the Company, to all employees (whether permanent, fixed-term or temporary), to operators who confirm customer payments, and to agents, intermediaries, consultants, contractors, suppliers, transport and customs partners, advisers and any other third party who performs work, services or functions for or on behalf of the Company (together, "Personnel" and "Business Partners"). Where this Policy refers to "you", it means any such person to the extent that they act in connection with the Company or the Platform.

The Company serves customers located in Albania, Kosovo, North Macedonia and Montenegro and assists them in discovering Copart auction vehicles, in placing bids that Premium Auto Bid submits to Copart in real time through the Copart API after identity verification and deposit approval, and in coordinating purchase, transport, customs and import support. Because these activities involve cross-border dealings, third-party intermediaries and interaction with public authorities (for example customs, registration and tax bodies), strict anti-corruption discipline is essential and is treated as a serious operational control rather than a formality.

Premium Auto Bid is an independent platform. It is not owned by, operated by, endorsed by, or affiliated with Copart, Inc. Premium Auto Bid places customer bids on Copart in real time through the Copart API; it is not an official Copart partner. Copart and the Copart logo are trademarks of Copart, Inc. The specific sample listings shown on the Platform are clearly-labelled demonstration samples only; they do not represent real Copart lots and are not biddable.

The Company has a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all of our business dealings and relationships, wherever we operate, and to implementing and enforcing effective systems to counter bribery and corruption throughout our supply chain.

Bribery and corruption damage trust, distort competition, harm the communities and markets we serve, expose the Company and individuals to criminal and civil liability, and are wholly incompatible with our commitment to maintaining lawful, approved commercial relationships with reputable auction sources. No business objective, customer relationship, deadline, commercial advantage, cost saving or instruction from any person, however senior, can ever justify giving, offering, promising, requesting, agreeing to receive or accepting a bribe.

• We conduct all business honestly, ethically and transparently.
• We do not engage in any form of bribery or corruption, whether direct or indirect, and whether in the public or the private sector.
• We do not make, offer or authorise facilitation payments of any kind.
• We do not tolerate bribery or corruption by anyone working for us or on our behalf.
• We keep accurate books and records and maintain adequate internal controls.
• We encourage the raising of concerns and protect those who report suspected wrongdoing in good faith.

This commitment is owned at the most senior level of the Company. The administrator is responsible for ensuring that this Policy is implemented, that adequate procedures exist to prevent bribery, and that the Policy is reviewed and kept up to date as the business and the applicable law evolve.

The following terms are used throughout this Policy. They are intended to be read broadly and purposively, consistent with applicable anti-corruption law.

Bribe

A "bribe" is a financial or other advantage offered, promised, given, requested, agreed to be received or accepted with the intention of inducing or rewarding the improper performance of a function or activity, or otherwise in circumstances where acceptance would itself be improper. A bribe need not be money; it can take the form of gifts, hospitality, entertainment, fees, commissions, discounts, charitable or political contributions, employment, services, the use of assets, or any other benefit of any value.

Corruption

"Corruption" means the abuse of entrusted power or position for private gain. It includes bribery but also extends to extortion, embezzlement, trading in influence, abuse of functions, collusion and other dishonest conduct that undermines fair and lawful dealing.

Public official

A "public official" means any officer, employee or representative of, or any person otherwise acting in an official capacity for or on behalf of, a national, regional or local government, a public agency or authority (including customs, registration, licensing, police and tax authorities), a state-owned or state-controlled enterprise, a public international organisation, or a political party, party official or candidate for public office.

Facilitation payment

A "facilitation payment" (sometimes called a "grease" or "speed" payment) is a typically small, unofficial payment made to secure or expedite a routine governmental action to which the payer is already entitled, such as processing paperwork or clearing goods. The Company prohibits facilitation payments in all circumstances.

Personnel and Business Partners

"Personnel" means the Company's directors, administrator, employees and operators. "Business Partners" means any third party who performs work, services or functions for or on behalf of the Company, including agents, intermediaries, consultants, contractors, suppliers, and transport and customs providers.

You must never engage, directly or through any third party, in any of the conduct described below, whether the other person is a public official or a private party, and whether the conduct takes place in Albania or abroad.

• Giving, promising or offering a payment, gift, hospitality or other advantage with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
• Requesting, agreeing to receive or accepting a payment, gift, hospitality or other advantage from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them.
• Offering or accepting an advantage to or from a public official, or any close family member or associate of a public official, in order to influence any act or decision.
• Making any facilitation payment, or any payment dressed up as a fee, commission, donation or expense that is in substance a bribe.
• Threatening or retaliating against another person who has refused to commit a bribery offence or who has raised concerns under this Policy.
• Engaging in any activity that would cause the Company or any person associated with it to breach applicable anti-corruption laws.

It is also prohibited to use intermediaries, agents, consultants or any other Business Partner to do indirectly anything that this Policy prohibits the Company or its Personnel from doing directly. Wilful blindness to how a Business Partner uses funds the Company provides is not a defence.

Bribery offences can be committed without any payment ever changing hands. A mere offer, promise or request can be a criminal offence. If in doubt, do not proceed and seek guidance through the reporting channel set out in this Policy.

The Company does not make, and will not accept, facilitation payments or kickbacks of any kind, in any country, regardless of local custom or the apparent smallness of the amount. This prohibition is absolute and applies to Personnel and Business Partners alike.

Facilitation payments are a particular risk in import, customs and registration processes that are central to the Company's logistics and import-support activities. Personnel and Business Partners must be especially vigilant in any interaction with customs officers, port and terminal staff, registration and licensing officials, inspectors and similar persons. Routine government actions must be obtained only through lawful, official channels and against official receipts.

• If you are asked to make a facilitation payment, you must refuse, make clear that the Company prohibits such payments, and report the request through the reporting channel.
• Where a refusal could give rise to a genuine and imminent threat to a person's life, limb or liberty (duress), your immediate safety comes first; any payment made under such duress must be reported as soon as it is safe to do so and recorded accurately.
• Payments to expedite or guarantee an outcome to which the Company or a customer is not lawfully entitled are never permitted.

A "kickback" is the return of a portion of a payment as a reward for awarding or facilitating business. The Company prohibits offering, soliciting, paying or receiving kickbacks in connection with the sourcing of vehicles, the selection of suppliers or transport and customs providers, or any other aspect of its business.

This Policy does not prohibit normal and appropriate hospitality given to or received from third parties where the purpose is to build or maintain legitimate business relationships, to present the Company's services, or to mark a customary courtesy. It does prohibit any gift or hospitality that is, or could reasonably be perceived to be, intended to influence improperly a business decision or to secure an improper advantage.

A gift or item of hospitality is acceptable only if all of the following conditions are met:

• It is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, and it does not place the recipient under any obligation.
• It is not made in secret; it is given openly, transparently and in the Company's name where appropriate.
• It is of an appropriate type and reasonable value, taking account of the reason for it, and it is given at an appropriate time.
• It complies with local law and with the rules of the recipient's own organisation.
• It is not cash or a cash equivalent (such as vouchers, gift cards, loans, securities or similar).
• It is properly recorded in the Company's books and records.

Public officials

Particular caution applies to public officials. Personnel must not offer or give any gift or hospitality to a public official, or to a family member or associate of a public official, without prior written approval from the administrator or a person the administrator designates for this purpose. What is acceptable in dealings with private parties may be unacceptable, or unlawful, when a public official is involved.

Where any doubt exists about whether a gift or item of hospitality is appropriate, you must seek approval in advance. When in doubt, decline. All gifts and hospitality given or received above any threshold set by the Company must be recorded in a gifts and hospitality register maintained for that purpose.

A conflict of interest arises where your personal, financial, family or other interests could, or could reasonably be perceived to, interfere with your duty to act in the best interests of the Company and its customers. Conflicts of interest are a recognised gateway to corruption and must be managed proactively and transparently.

Examples relevant to the Company's business include, without limitation: a personal or family interest in a supplier, transport or customs provider, or other Business Partner; an undisclosed relationship with a customer whose payments or account you confirm or administer; an outside activity that competes with the Company; and accepting benefits from a counterparty whose selection or treatment you can influence.

• You must avoid situations in which your interests conflict, or may appear to conflict, with those of the Company.
• You must promptly disclose any actual, potential or perceived conflict of interest to the administrator or to the compliance contact.
• You must not participate in any decision, review or approval that is affected by your conflict unless and until the conflict has been disclosed and appropriately managed.
• Operators must not confirm a customer payment, or influence the selection of a Business Partner, where they have an undisclosed personal interest.

Disclosing a conflict does not, by itself, resolve it. The Company will decide what safeguards are required, which may include reassigning the matter, excluding the conflicted person from a decision, or declining the relationship altogether.

The Company can be held responsible for bribery committed by Business Partners acting on its behalf. Third parties and intermediaries are therefore one of the most significant anti-corruption risks the Company faces, particularly in the sourcing, transport, customs and import-support parts of its business, which involve cross-border dealings and contact with public authorities.

Before engaging a Business Partner who may interact with public officials, handle funds or otherwise act on the Company's behalf, and on an ongoing basis thereafter, the Company will apply risk-based due diligence proportionate to the nature, scale and risk of the engagement.

• Identifying and verifying who the Business Partner is, who owns and controls it, and who will actually perform the work.
• Assessing the corruption risk presented by the country, sector, counterparties and nature of the services involved.
• Confirming that the remuneration is reasonable and commensurate with the legitimate services provided, and that payment terms are transparent.
• Screening against applicable sanctions frameworks (UN, EU and US/OFAC) and other adverse-information sources, consistent with the Company's Sanctions Compliance Policy.
• Obtaining appropriate anti-corruption commitments, including the right to audit, to obtain information, and to suspend or terminate for breach.

Business Partners are expected to maintain anti-corruption standards consistent with this Policy. Contracts with Business Partners who present a meaningful corruption risk should include anti-corruption representations and warranties, the obligation to keep accurate records, audit and information rights, and the right to suspend or terminate for breach. Payments to Business Partners must correspond to genuine services, be supported by valid documentation, be made to the contracting party in the contracting jurisdiction wherever possible, and never be routed through accounts or persons in a manner designed to disguise their nature or destination.

Premium Auto Bid places customer bids on Copart in real time through the Copart API. A customer may bid only after completing identity verification, accepting the Member Terms and obtaining deposit approval; these prerequisites are also a control against improper conduct and must never be applied or waived to obtain or confer an improper advantage.

Accurate books and records are a core anti-corruption control. The Company maintains its financial and operational records honestly, completely and in reasonable detail so that they fairly reflect the transactions and disposition of the Company's assets, and so that bribery cannot be concealed.

• All payments, receipts, expenses, gifts, hospitality, deposits, refunds and other transactions must be recorded accurately, promptly and with a clear and truthful description of their purpose.
• No undisclosed, unrecorded or off-the-books account, fund or asset may be established or maintained for any purpose.
• No false, misleading, artificial or incomplete entry may be made in any record, and no document may be backdated, altered or destroyed except in accordance with lawful retention rules.
• Customer deposits and balances are handled in USD (a standard deposit of $750, or 10% for vehicles over $7,500); inbound payments are operator-confirmed against bank statements or cash receipts, with the customer's uploaded proof retained on file.
• Supporting documentation must be retained for the periods required by applicable law and the Company's data-retention rules.

Internal controls are designed to ensure that transactions are properly authorised and recorded and that the prohibitions in this Policy are enforced. Personnel must not circumvent or override these controls, and any attempt by another person to do so must be reported.

Early reporting of suspected bribery or corruption is essential. If you are offered a bribe, are asked to make one, suspect that bribery or corruption has occurred or may occur, or are unsure whether a course of action is permitted under this Policy, you must speak up promptly.

Concerns should be reported to the Company's compliance contact at compliance@premlogistics.com. You should report as soon as possible and provide as much detail as you can, including the people involved, what was said or done, and any supporting documents. The Company will treat reports as confidentially as possible, consistent with the need to investigate and with any legal obligations.

1. Stop. Do not agree to, pay, accept or progress anything that may involve bribery or corruption.
2. Record. Note the facts accurately, including dates, amounts, people and any documents.
3. Report. Contact compliance@premlogistics.com without delay and follow any instructions given.
4. Cooperate. Assist with any investigation honestly and fully, and preserve relevant records.

The Company will not tolerate retaliation of any kind against a person who, in good faith, raises a concern, reports suspected wrongdoing, refuses to participate in bribery or corruption, or assists with an investigation, even if it turns out that they were mistaken. Retaliation includes dismissal, disciplinary action, threats, demotion, exclusion and any other unfavourable treatment connected to the report. Anyone who retaliates against a good-faith reporter will themselves be subject to disciplinary action. Knowingly making a false report in bad faith, however, is a breach of this Policy.

Reports may be made in Albanian or English. If you are a customer or other external party and you suspect corruption connected to the Platform, please contact compliance@premlogistics.com so that the matter can be reviewed.

This Policy is designed to ensure compliance with the anti-corruption laws that apply to the Company and to those acting on its behalf. The Company is established in, and governed by the law of, the Republic of Albania, and the competent courts of Tirana have jurisdiction over disputes relating to this Policy.

Albanian law

The Company complies with the anti-corruption provisions of the Criminal Code of the Republic of Albania, which criminalise active and passive bribery in the public and private sectors and related corruption offences, together with all other applicable Albanian laws. This Policy is also consistent with the Company's obligations under Albanian Law no. 9917 dated 19.05.2008 'On the Prevention of Money Laundering and Financing of Terrorism' (as amended), because corruption proceeds and money laundering are closely linked.

International standards

Because the Company's business involves cross-border dealings and a supply chain that includes United States vehicle auctions, the Company applies, as guiding principles for its international dealings, the standards reflected in the United States Foreign Corrupt Practices Act (FCPA) and the United Kingdom Bribery Act 2010. These principles inform our prohibition on bribing public officials, our refusal to make facilitation payments, our books-and-records discipline and our expectation of adequate procedures to prevent bribery by associated persons. The Company also has regard to the recommendations of the Financial Action Task Force (FATF) where relevant.

Where different laws or standards apply to the same situation, the Company applies the most stringent applicable requirement. Nothing in this Policy is intended to require or permit any act that is unlawful under any applicable law.

A breach of this Policy is treated as a serious matter. The Company may take action against any person who breaches this Policy, in addition to any consequences that may arise under the general law.

• For Personnel, breach may result in disciplinary action up to and including termination of employment or engagement, without prejudice to any claim the Company may have.
• For Business Partners, breach may result in suspension or termination of the relationship and of any related contracts, and in the recovery of losses.
• For customers and other users, conduct involving bribery or corruption connected to the Platform may result in suspension or closure of the relationship, refusal of service, and reporting to competent authorities.

Bribery and corruption are criminal offences. Individuals who engage in them may face prosecution, fines and imprisonment, and the Company may face prosecution, substantial financial penalties, confiscation, debarment from opportunities and serious reputational harm. Such conduct would also jeopardise the Company's lawful, approved commercial relationships with reputable auction sources. The Company will cooperate with law-enforcement and regulatory authorities and may report suspected criminal conduct to them.

Everyone to whom this Policy applies is responsible for reading, understanding and complying with it. Personnel are expected to complete any anti-corruption training the Company provides and to apply this Policy in their day-to-day work. The administrator has overall responsibility for the Policy and for ensuring that adequate procedures are in place to prevent bribery.

By acting for or on behalf of the Company, by continuing employment or engagement, or by using the Platform, you acknowledge that you have read and understood this Policy and agree to comply with it to the extent it applies to you. Where a separate contract requires written acknowledgement of this Policy, that requirement applies in addition to this acceptance.

The Company may amend this Policy from time to time to reflect changes in the law, in regulatory expectations, in the business or in good practice. The current version, with its effective and last-updated dates, is the version that applies. Material changes will be communicated through appropriate channels, and continued action for, on behalf of, or use of the Company or the Platform after a change takes effect constitutes acceptance of the updated Policy.

Questions about this Policy, requests for guidance, and reports of suspected bribery or corruption should be directed to the Company's compliance contact.

• Compliance and reporting: compliance@premlogistics.com
• General enquiries: info@premlogistics.com
• Customer support: support@premlogistics.com
• Legal: legal@premlogistics.com
• Data protection / DPO: privacy@premlogistics.com
• Website: premlogistics.com

Postal address: Premium Logistics SHPK, Rruga "Dubai", Lagjia nr. 2, cadastral zone 2066, property no. 89/38, 4-storey building, 2nd floor, Entrance 1, Kamëz, Tirana, Albania. NUIS/NIPT M53004202C, registered with the National Business Center (QKB), Republic of Albania.