Code of Conduct

1 INTRODUCTION

• 1.1 Purpose
  The purpose of this Code of Conduct (hereinafter referred to as the "Code") is to remind all employees, auditors (hereinafter referred to as "relevant persons"), customers, suppliers, and public and private institutions (hereinafter referred to as "third parties") of the unwavering commitment of Embega S.Coop. ((hereinafter referred to as Embega) to comply with the laws and regulations in force and with the provisions of this Code.

  Compliance with the Code is mandatory for Managers, members of the Board of Directors, as well as for auditors.

2 SCOPE OF APPLICATION

• 2.1 Persons to whom this Code applies
  All persons at Embega regardless of their position. This code must also be made known to suppliers, customers, auditors, or those acting on their behalf or representation.
• 2.2 Control structure responsible for monitoring
  Monitoring compliance with the Code is the responsibility of the Process Committee, whose tasks are summarized as follows:
  • a) Ensuring proper communication of the Code to everyone at Embega and to anyone else to whom it is of interest.
  • b) Reviewing the Code.
  • c) Maintaining confidentiality.
• 2.3 Communication of the Code
  This code of conduct will be communicated to all Embega employees through the established onboarding manual.

  Regular Embega employees will be informed of the Code through general communication via email or communication at the General Assembly. A copy is available on the internal network.

  The Code of Conduct is available to interested parties on the Embega website.

  Whenever there are relevant changes, communications to external or internal interested parties will be updated following communication to the Board of Directors.

• 2.4 Contractual value of the Code for employees
  Compliance with the Code is mandatory for Embega consultants and suppliers. Embega reserves the right to terminate any contract with consultants or suppliers who do not comply with this Code.

3 GENERAL RULES OF CONDUCT

• 3.1 Registration and manufacturing license
  In carrying out professional activities, any person at Embega or third party must be up to date and comply with current legislation.
• 3.2 General Principle: compliance with current legislation
  In carrying out professional activities, any person at Embega or third party must be up to date and comply with current legislation.

  Any person at Embega or third party who is forced or instigated to violate the law must immediately report the matter to their Manager or HR Manager.

• 3.3 Against corruption and bribery
  At Embega, we are committed to combating any form of corruption and bribery, expecting the same commitment from employees and collaborators.

  Corruption shall be understood as the act of a person offering and/or giving directly or indirectly, gifts, promises, or advantages of any kind, for their own benefit or that of a third party, to another person to perform or refrain from performing an act within their function.

  It is strictly prohibited to offer third parties any gift that, due to its value, may be interpreted as a present exceeding courtesy and is made in order to obtain favorable treatment for Embega.

  Embega may not finance candidates or political parties.

  It is strictly prohibited to access public funds and credits without prior authorization from the Finance Department.

  Bribery shall be understood as anything of value that is offered, promised, paid, or delivered to a third party with the purpose of influencing their decision-making or obtaining an unjustified benefit in the course of business. It is one of the forms in which corruption materializes.

  Any violation may be reported by any interested party through Embega's Whistleblowing Channel available on the website.

• 3.4 Reporting inappropriate conduct. Ethical escalation procedure.
  Any person belonging to Embega who observes bad practices or practices not in accordance with this Code of Conduct may report it to their Manager or HR through the usual communication channels or through the Whistleblowing Channel.

  Every complaint submitted will be subject to an objective investigation by the company through internal procedures. In accordance with legal requirements, information will be treated confidentially. Whistleblowers shall not suffer any unjustified disadvantage as a result of their complaints.

• 3.5 Action against moral harassment or harassment based on sex
  The harassment action protocol is defined in document P9DOC14 integrated into the People Management Process available on Embega's internal network for interested parties.

  HARASSMENT:

  Any conduct, statement, or request that, carried out repeatedly and systematically, may be considered offensive, humiliating, violent, or intimidating, provided it occurs in the workplace or on the occasion thereof and involves insult, contempt, humiliation, discrimination, or coercion of the protected person in the psychological, sexual, and/or ideological sphere, potentially harming their integrity through the degradation of working conditions, whatever the reason for such conduct.

  Excluded are those interpersonal conflicts localized at a specific moment that may occur within the framework of human relations and affect work organization and its development, but which do not have the purpose of destroying the parties involved in the conflict personally or professionally.

4 TRANSACTIONS AND GENERAL CONTROL FRAMEWORK

• 4.1 General Principle: compliance with current legislation
  Any transaction carried out in the interest of Embega must comply with applicable current legislation and must be auditable. (General Accounting Plan approved by Royal Decree 1514/2007).
• 4.2 Authorization and copy of every transaction
  Every transaction must be recorded at the accounting level.
  Every transaction must have its corresponding copy. A copy that can be consulted at any time, allowing the identification of the authors of the transaction, those who authorized, recorded and filed it.
• 4.3 Cooperation with control agents
  All information shared from Embega with internal auditors and/or external agents must be up to date, truthful, rigorous, prepared by appropriate personnel, and must comply with current legislation.

5 HUMAN RESOURCES

• 5.1 Contracts: compliance with current legislation
  Embega employees and third parties must be contracted in accordance with current legislation; a written contract (or valid document) must be on record.
• 5.2 Salaries
  Embega must maintain records of monthly payments and management of hours worked by each employee, member, or contractor.
• 5.3 Working hours and overtime
  The working hours or calendar of Embega employees must not exceed the legal limit under any circumstances.
• 5.4 Salary conditions
  Embega must pay its employees, at minimum, the minimum interprofessional wage, in accordance with current legislation (based on the hours that the law stipulates must be worked).

  Salaries must be paid regularly according to the work performed and local legislation.

• 5.5 Payment/Compensation for Overtime
  Embega employees must be compensated for overtime in accordance with legal requirements.
• 5.6 Leave
  Employees must have a work calendar that includes the annual working hours, working days, non-working and public holidays, and annual vacation to be taken.

  They must also be guaranteed a paid leave regime according to current legislation that includes absences due to temporary disability arising from common and occupational contingencies, for care of newborns, for breastfeeding, and for any other reason contemplated in internal regulations.

• 5.7 Benefits
  Embega must provide members of its workforce with the benefits to which they are entitled under legislation such as healthcare, pension contributions, etc.
• 5.8 Child labor
  Embega and its third parties will not hire persons under 18 years of age and will maintain a register containing the date of birth of all employees.

  If the presence of any minor in the company is detected, the People department will be notified for contract termination, and the causes will be analyzed and appropriate corrective and preventive actions will be defined.

• 5.9 Forced and arduous labor (Access requirements)
  Embega and its third parties:
  • Shall not use force (1)
  • Shall not hire prisoners (2)
  • May not force their employees to perform involuntary work.

    Note 1: Forced labor is considered any task performed under threat of punishment, confiscation of belongings (such as ID, passport, etc.) and for which the person has not volunteered.
    Note 2: The use of civil or military prisoners is prohibited.

• 5.10 Discrimination and Equality
  Embega and its third parties must avoid discriminating against their employees based on their faith, sex, marital status, age, political affiliation, place of birth, sexual orientation, or any other reason prohibited by law.

  Embega will guarantee equal opportunities and treatment for all employees.

  Embega, S.Coop., through the Board of Directors and the Management Board, is committed to promoting equal opportunities between men and women and rewarding our human team based on their merits, qualifications, and performance.

• 5.11 Freedom of association
  Embega and its third parties must ensure that their employees have the possibility to associate freely.

6 RESPECT FOR THE ENVIRONMENT AND SUSTAINABILITY

Embega holds ISO 14001:2015 environmental management standard certification, carrying out its activities in accordance with the principles of its IMS Policy.

• • 6.1 General Principle
    Embega and its third parties must have the necessary permits and comply with what the law stipulates regarding environmental matters. In particular:
    • Air pollution
    • Noise Pollution
    • Water Pollution
    • Soil Contamination
    • Chemical agents
    • Hazardous and non-hazardous waste.
  • 6.2 Requirements
    Embega and its third parties must comply with:
    • Legal environmental inspections: ensuring completion of corrective actions resulting from government environmental inspections; documenting and completing such actions on time.
  • 6.3 Continuous improvement:
    Embega and its third parties must demonstrate their commitment to continuous improvement in environmental aspects:
    • • Emissions to air
      • Emissions to soil and water
      • Noise
      • Hazardous and non-hazardous waste
      • The use of natural resources, e.g. energy, raw materials, chemicals etc. as well as the reduction of fossil fuel use.
      • The supplier shall continue to work on the substitution of hazardous chemicals with non-hazardous chemicals.

    SUSTAINABILITY
    At Embega, we see sustainability as an opportunity to innovate in the cooperative project, and we want to be leaders in adapting the cooperative project to a new era characterized by sustainability.

    • Social sustainability
      On the social level, sustainability promotes the development of people, communities, and cultures to achieve a global level of quality of life, health, and education that is adequate and equitable. The fight for gender equality, especially in developing countries, is another aspect that will shape the foundations of social sustainability in the coming years.
    • Environmental sustainability
      In its environmental dimension, sustainability maintains that nature is not an inexhaustible source of resources and advocates for its protection and rational use. Aspects such as care for the environment, investment in renewable energies, water saving, a commitment to sustainable mobility and innovation in construction and sustainable architecture contribute to achieving environmental sustainability on several fronts.
    • Economic sustainability
      Sustainability also seeks to promote economic growth that generates equitable wealth without harming natural resources. Equal investment and distribution of economic resources will enable the strengthening of the other pillars of sustainability to achieve comprehensive development.

7 OCCUPATIONAL HEALTH AND SAFETY
One of Embega's main objectives is to ensure the safety of all employees.
We will integrate quality management, commitment to the environment, health, and safety into all our operations without compromising these values for profit or production.

Occupational risk prevention must be assumed by all employees and Embega Management.

• 7.1 General Principle
  Embega and its third parties must comply with what the law stipulates regarding occupational health and safety.
• 7.2 Requirements
  Embega and its third parties must comply with:
  • Statutory occupational health and safety inspections: ensuring compliance with corrective actions resulting from government inspections; documenting and timely completion of such actions.
• 7.3 Continuous improvement:
  Embega and its third parties must ensure and demonstrate continuous improvement in areas related to health and safety, in order to improve working conditions to raise the level of protection of the safety and health of employees.

8 CONFIDENTIALITY, PROTECTION OF PERSONAL DATA

• 8.1 General Principle
  Every person at Embega has the obligation to ensure, with the utmost confidentiality, all relevant information managed in the performance of their activities, both internally and externally.

  Embega, in compliance with applicable data protection legislation, is committed to protecting all information related to its employees or third parties.

  Any person at Embega who needs to share confidential information with third parties, directly or indirectly, must share such information with their Manager or Embega's Management Board.

9 COMMUNICATION CHANNELS (INQUIRIES, COMPLAINTS, REPORTS)

Embega has enabled accessible communication channels for all employees and interested parties.

Embega has available on its website a public access ethics channel so that anyone can report personally or anonymously and confidentially any violation of this Code of Conduct.

The Ethics Channel Policy and Ethics Channel Communications Management are contained in documents P9DOC22 and P9DOC23 respectively.

10 DISCIPLINARY REGIME

• 10.1 Sanctions
  If persons at Embega do not comply with any of the articles of this Code, they will be subject to sanction, which varies according to what is established in Embega's internal regime.

11 Contributions of the code of conduct to the supplier qualification process

• 11.1 Pre-evaluation Document (Initial Requirement)
  By signing the Pre-evaluation document (which contains the Initial Requirements), Embega suppliers will accept the initial conditions. The Pre-evaluation document will consist of 4 questionnaires related to:
  • Quality System
  • Environmental Management
  • Occupational Health and Safety Management
  • Management of employees and personnel in general