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Code oF eThICS ANd CoNduCT

4.3 eThICS

In September 2017, the Board of direc- tors approved the update of our Code of ethics and Conduct, applicable to the en- tire Group.

This Code lays down the general princi- ples, standards and conduct required to achieve our objectives and promote our values reflecting the best practices to be considered in all of our businesses with- out exception. The Code is available on our corporate website and is divided into four main blocks:

Integrity with our employees.

Integrity in business operations.

Integrity in external relations.

Integrity in safeguarding our assets and information.

To prepare the Code of ethics and Con- duct, the heads of the main departments and businesses of Cepsa, as well as the most representative Trade union Fed- erations in their field, contributed their knowledge of the business, best prac- tices and unacceptable conduct, in order

to determine how the ethical commit- ment and compliance with regulations had to be grounded in how we perform all of our activities. In order to improve accessibility and understanding by our employees and stakeholders, the code is available in Spanish, Mandarin Chinese, French, english and Portuguese.

All Cepsa employees, as well as direc- tors and Senior Management, must know the contents of the Code of ethics and Conduct, with 100% of Managers and heads of department having adhered to it in 2017. In the case of business partners and other stakeholders, such as suppli- ers, they must commit to it before signing the binding contractual document and, in the case that they provide their com- mitment to a code of their own, that code must cover similar standards to ours.

Similarly, with the purpose of promot- ing our company s ethical framework and providing instructions regarding its use, we have developed training plans for 100% of Cepsa employees both in the new Code, and in crime prevention, in- cluding the use of the ethics and Conduct Channel.

our Code strengthens our commitment to ethical conduct in every one of our business areas.

FoR MoRe INFoRMATIoN ABouT CePSA S Code oF eThICS ANd CoNduCT, CLICK heRe

CHAPTER 4 efficient and responsible management