Ethics and compliance model

The Grupo Antolin corporate governance model comprises the set of rules and principles that ensure the proper functioning of Grupo Antolin's governing and administrative bodies.

1

Code of Ethics and Conduct

Guarantees the ethical and responsible behavior of all employees linked to Grupo Antolin, with no exceptions, in the performance of their activity and relationships with customers, shareholders, other employees, suppliers and society as a whole.

2

Transparency rule for conflicts of interest

This requires any situation that could be perceived as a conflict of interest to be brought to the attention of the Compliance Department for its review. Suspicions can be reported by any Grupo Antolin employee, regardless of their position.

3

Whistleblowing Channel

Confidential communication channel for reporting any claims or complaints within the scope of the Code of Ethics and Conduct. The channel is open both to Grupo Antolin employees and to any people external to the organization.

4

Criminal Compliance System

This brings together a series of control measures that affect practices such as influence peddling and bribery, the crime of the illegal financing of political parties and corruption in business, among others. The Criminal Compliance System is based on the ISO 19600 standard and has been updated in accordance with the ISO 19601 standard. The Crime Prevention Model (CPM) and the risk map form part of this set of measures, which complete and automate the global risk system in Compliance and allow scalability within the organization.

5

Due diligence and criminal prevention practices for business partners

Grupo Antolin’s ethical commitment goes beyond its employees and also extends to suppliers and customers. The Code of Conduct for suppliers establishes requirements and standards based on ethics, transparency, respect for human rights and the environment. These commitments affect the supply chain of the suppliers who work with Grupo Antolin. Likewise, Grupo Antolin signs up to the sustainability commitments of its customers.

6

Global Anti-Corruption Policy

Grupo Antolin is committed to the regulations on the prevention and fight against corruption and for this purpose it has drawn up, published and disseminated the Global Anti-Corruption Policy, which brings together the existing commitments, guides and policies.