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CoMPLIANCe MANAGeMeNT SySTeM

At Cepsa, we are implementing a com- prehensive methodology to set up a Cor- porate Compliance Model that allows us to identify compliance risks and imple- ment preventive and detective measures and sanction conduct that may result in company or employee liability, including commitments acquired by Cepsa under its Code of ethics and Conduct, and their commitment to Corporate Responsibility.

The Cepsa Board of directors is responsi- ble for ensuring the existence of an effec-

tive ethics and compliance programme, via the Board s Audit, Compliance and ethics Committee. oversight of the ethics and compliance programme is delegated to the ethics and Compliance operating Committee.

The ethics and Compliance office takes charge of setting up, defining and moni- toring the ethic and compliance pro- grammes, as part of the Audit, Compli- ance and Corporate Risks department.

Analysis of businesses/regulations/risks. Policies and processes. Training. Communications. Complaints channels. Integration of management processes.

Investigations. Checks. Controls.

Plan for fines. Traceability. effective supervision.

Continuous ImprovementPreventing detecting Mitigating

2017 ANNuAL ANd CoRPoRATe ReSPoNSIBILITy REPORT