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Ethics and integrity

The CLH Group promotes conduct based on strict principles of ethics and transparency and on fulfilling its commitments, and endeavours to act in accordance with good corporate governance criteria.

The Code of Conduct

The purpose of the Code of Conduct is to lay down guidelines for conduct, integrity and ethical behaviour in the CLH Group as regards the communities in which it operates.

This document includes universally accepted ethical values and basic reference principles for the conduct to be observed by everyone in the company, and takes its inspiration from the CLH Mission, Vision and Values, the rules of Good Corporate Governance and the principles of the United Nations Global Compact, of which the company is a signatory.

This Code of Conduct is applicable to the members of the company's administrative and management bodies and to everyone employed by the companies that comprise the CLH Group. CLH also undertakes to promote the Code among all its suppliers, contractors and business associates, so as to create a bond and a guide for action that conform to the principles and values that it includes.

Code of Conduct.


Ethics Committee

The Ethics Committee is responsible for promoting, circulating and making the Code of Conduct known, besides ensuring that it is complied with, and works in association with the different areas of the Group.

As agreed by the company's Management Committee, the members of the Ethics Committee are: the Director of Communication and Institutional Relations of the CLH Group, who will also act as its Chairman, the Director of Human Resources, the Deputy Director of Legal Consultancy, and the Deputy Director of the Auditing Department.

The main activities to be carried out by this Committee include promoting the circulation of the Code of Conduct among company employees and other stakeholders, and also management of the Code of Conduct Mailbox, a specific channel of communication for handling information about possible breaches in the application of the guidelines included in the Code of Conduct, besides any queries or suggestions that may arise in connection with it.


Code of Conduct Mailbox

The CLH Group places the Code of Conduct Mailbox at the disposal of all its stakeholders as a channel of communication that is established for sending queries and clearing up any doubts concerning these regulations, and also for the direct, safe reporting of any suspected breach of the principles included in them, including, where appropriate, conduct involving workplace bullying and irregularities that are potentially far-reaching on a financial and accounting level. These communications will be received by the company's Ethics Committee which will be responsible for assessing and deciding on the procedure required for handling each case, depending on the nature of the facts that have been made known.

The CLH Group guarantees the confidentiality of the entire process, although it is important to point out the need to use this tool responsibly and think twice about the far-reaching consequences of reporting any suspected breach of the Code of Conduct unless there are sufficient and accurate indications or proof of its existence.

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DISCLAIMER: The procedure established for the use of the Code of Conduct Mailbox ensures confidentiality for the person submitting the communication, and no anonymous communications not including the sender’s identity will be accepted. There will be no retaliation for those who, in good faith, make use the Code of Conduct Mailbox; however, it is must be recalled that making accusations that are known to be false may lead to criminal or civil liability pursuant to the Law.

For the purposes of Regulation (EU) 2016/679 of 27 April 2016 (“General Data Protection Regulation”) and concordant regulations, we hereby inform you that COMPAÑÍA LOGÍSTICA DE HIDROCARBUROS, CLH S.A., with Tax Code A-28018380, is the data controller responsible for the processing of your personal data and that you may obtain all the information relative to the processing of your personal data in the Data Protection Policy of the CLH Group, available via the following link: Data Protection Policy of the CLH Group.

The personal data held by COMPAÑÍA LOGÍSTICA DE HIDROCARBUROS CLH S.A. are processed for several purposes, such as compliance with our legal obligations, management of contracts and commercial relationships, to send communications, if applicable, and to control the security of the facilities of CLH, pursuant to the terms of the privacy policy.

The legal basis for the processing is the performance of the contract and the commercial relationship, when these exist, compliance with our legal obligations, our legitimate interest and, if applicable, your consent.

Personal data may be disclosed to group companies for internal management and to those service providers that need access thereto, and when required by a legal obligation or a competent authority.

You may at any time exercise your rights of access, rectification, objection, erasure, restriction and portability, as well as your other rights, in the terms set forth in applicable regulations, by writing to the following e-mail address: infoclh@grupoclh.com or by ordinary mail to the address of the registered office at C/ Titán, 13 28045-MADRID.

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