ZAYER and the organisation of companies that comprises it, and especially its Administration and Senior Management Body are fully committed to fostering a truly ethical business culture and reaffirming their commitment and demand that all the members of its Organisation comply with and respect current legislation in its broadest sense and specifically as regards criminal activity, as set forth in its Corporate Compliance Program. This also applies to all individuals who take part in the Group’s business activities, to prevent any type of criminal deed from being committed.

To achieve this, the Company has implemented technical, organisational, personnel, surveillance and control measures throughout the Organisation encompassed within the Group’s commitment to ensure continuous improvement of these measures and to establish an appropriate penalty scheme for non-compliance with the Criminal and Anti-bribery Compliance Policy.

ZAYER’s Criminal and Anti-bribery Compliance Policy has been promoted, approved and agreed to by the Administration Body and Senior Management and included in the Criminal Compliance Manual, with the following aims:

• To encourage all employees to act at all times to preserve ZAYERs’ integrity and good reputation by complying strictly with the Law and the provisions of the Spanish Criminal Code, as set forth in the Regulatory Compliance Program, which prohibits committing any crime at any time.
• To identify the activities susceptible to the commission of crimes in accordance with Art. 31 bis of the Criminal Code, prohibit these explicitly and take the necessary measures to prevent them.
• To minimise the exposure of the Organisation to criminal risks and bribery by establishing appropriate control mechanisms for effective risk management.
• To set up and spread an ethical business culture at all levels of the Organisation with a suitable framework to define, review and achieve the crime prevention goals.
• To ensure that all the professionals at ZAYER, as well as third parties, partake in the obligation to comply with the contents of the Corporate Compliance program and this Criminal and Anti-bribery Compliance Policy, as well as the obligation to report in good faith events and behaviour objectively suspected of constituting criminal deeds or that may involve a risk of criminal penalty and to immediately follow the instructions received from the Internal Compliance Body (Legal Security Committee) in the exercise of their functions.
• ZAYER has provided appropriate communication channels to guarantee both confidentiality and the absence of reprisals for informers. The access to the information and addresses of these channels can be found in the websites of the Group's companies and other means used by these to provide information.
• To establish a Central Internal Corporate Compliance Body provided with independent initiative and control powers to exercise their functions.
• To audit and assess the degree of compliance with crime-related regulations and make decisions on the results, gradually updating and improving the Corporate Compliance Program and adapting it to the changes in external and internal factors that affect the Organisation’s activities.
• To apply the corresponding penalties derived from non-compliance with the obligations and requirements set forth in the Corporate Compliance Program or that are contrary to the Organisation’s values and the Criminal and Anti-bribery Compliance Policy.
• The Board of Directors hereby informs all the interested parties of this Criminal and Anti-bribery Compliance Policy and trusts that the entire Organisation understands the transcendence of this document and will incorporate it in their daily activities and working methods.

Signed The Chairman of the Board of Directors.