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Corruption prevention At Cepsa, an Anti-Bribery and Corrup- tion Policy is in place that establishes the procedural guidelines relating to fraud, transparency and the fight against cor- ruption. Furthermore, mechanisms have been rolled out to prevent, detect and investigate possible cases of corrup- tion. Should a potential instance of cor- ruption need to be examined, we would proceed with an investigation and inform the corresponding parties of the relevant disciplinary measures to be taken, in ad- dition to any remedial action required to resolve internal control issues. This anti- corruption model applies to the entire value chain, with audits performed on non-operated assets. In 2017, no com- plaints were received through the ethics and Compliance Channel related to cor- ruption matters.

Following the reform of the Spanish Pe- nal Code and international regulatory changes in terms of the criminal liability of legal persons, Cepsa is progressively rolling out crime prevention models in

the different countries in which we op- erate, prioritising compliance with the corresponding local regulations. The main objectives of the Crime Prevention Model is to prevent and, where appropri- ate, discover criminal conduct on the part of directors and employees of Cepsa s Spanish companies. In 2017, we contin- ued to adapt the Crime Prevention Model applicable to Spanish trading companies to the guidelines established in Circular 1/2016 of the Public Prosecutor and ISo 19600 on Compliance Management Sys- tems.

In turn, we have implemented a system for ensuring knowledge of our counter- parties with a view to protecting Cepsa in terms of any regulatory breaches deriv- ing from the regulation of sanctions and international embargoes, as part of which sanctions apply to all companies that have business relations with countries or physical or legal third parties sanctioned by the regulation.

CHAPTER 4 efficient and responsible management