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Ethics and integrity

The CLH Group promotes behaviour based on ethical criteria of transparency and good corporate governance.

The Code of Conduct

The CLH Group Code of Conduct outlines universally accepted guiding principles of ethics and rules of conduct inspired by the CLH Mission, Vision and Values, in order to provide all its employees, executives and directors, within the scope of their professional activities, regardless of the country they are operating in, with certain universal rules of conduct in line with the strictest ethical principles, taking into account the cultural setting in which they work and based on due compliance with local legislation.

This Code of Conduct is applicable to the members of the administrative bodies and the management of the company and to all the employees of the companies that make up the CLH Group. In addition, the CLH Group is committed to promoting this Code among all its suppliers, contractors and partners in order to establish a bond and certain guidelines for action in keeping with the principles and values of the Code.

Code of Conduct.

Ethics Committee

The Ethics Committee is a collegial body with autonomous powers of initiative and control within the CLH Group, entrusted with monitoring and updating the Code of Conduct, as well as promoting and disseminating its contents and ensuring awareness of and compliance with it, under the supervision of the Audit Committee. Particularly, the Ethics Committee is responsible for performing duties in ethics and integrity matters and criminal risk prevention for CLH. Likewise, the Committee shall assume the functions of periodically verifying and updating the established procedures in terms of ethics, integrity and criminal risk prevention, and coordinating and representing the Company in this area.

Another main responsibility of the Committee is promoting the dissemination, awareness of and compliance with the Code of Conduct among everyone in the company and other stakeholders, as well as managing the Internal Communication Channel (Code of Conduct Mailbox), a channel which aims to provide a means for reporting any potentially irregular conduct or circumstances within the Group, including, due to their serious nature, any possible criminal risk situations.

Internal Communication Channel (Code of Conduct Mailbox)

The CLH Group places the Code of Conduct Mailbox at the disposal of all its stakeholders, as an internal communication channel for reporting any suspicious or unusual behaviour that, in their opinion, may represent a potentially irregular act, including any possible criminal risk situations. Such reports may be anonymous or include the informant’s name and shall be received by the Ethics Committee, which shall analyse the required process in each case based on the nature of the reported events.

The confidentiality of the entire process is guaranteed, although it is important to emphasise the need to use this tool responsibly and to consider beforehand the far-reaching consequences of reporting an alleged breach of the Code of Conduct to the Ethics Committee without sufficient and accurate evidence or proof.

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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; both anonymous communications and communications including the sender’s identity will be accepted. There will be no retaliation for those who, in good faith, make use of 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, you are informed that COMPAÑÍA LOGÍSTICA DE HIDROCARBUROS CLH S.A., holder of Tax ID no. A-28018380, is the data controller responsible for the processing of your personal data and 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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