CODE OF CONDUCT

All companies registered with the Securities Exchange Commission (SEC), the registry for foreign companies listed in the United States, are obliged to comply with the conditions established by the Sarbanes-Oxley Act of July 2002. Section 301 of this Act states that procedures shall be established for the confidential receipt of complaints and concerns regarding accounting, internal accounting controls and auditing matters.

The Company already has rules and codes of conduct in place that oblige all its employees to behave in an appropriate manner in their dealings with external partners
– shareholders, employees, suppliers, customers, creditors and authorities, thereby setting an ethical base for social responsibility.

In order to adapt to this legislation and provide its external partners the highest levels of satisfaction, the Company has created an ethics mailbox through which all these groups may put forward any complaints and concerns over accounting, internal accounting controls and auditing matters, among others.

The procedures established by the Company ensure confidentiality as the mail box is managed by an external company –Ethicspoint- which has extensive experience in this field. Ethicspoint will be responsible for transmitting all complaints and concerns to the appropriate channel, while ensuring complete anonymity.

However, the highest degree of responsibility must be employed when carrying out this procedure and any false or rash claims could lead to penal or civil punishment as set out by law.