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CHAPTER 4 Responsible management

We are committed to a policy of zero to- lerance to corruption, fraud and bribery.

This firm commitment to the best natio- nal and international practices in terms of compliance was materialised with the obtainment, in 2018, of certification of our Anti-Bribery Management System under the ISO 37001 standard, which places us at the forefront of the industry. This certification was updated in 2019 with AENOR. We also implemented cer- tain measures to prevent possible cases of corruption and bribery during the year, including most notably the following:

Conducting audits on the use of Cor- porate Credit Cards and the Manage- ment Fuel Card.

Actions to communicate to our em- ployees and suppliers our policy against bribery and corruption, with the aim of making them aware of the conduct they should have in giving

and receiving gifts, and invitations to events or meals.

Launch of an online training space on crime prevention, which includes an exclusive module on the prevention of corruption-based crimes.

Implementation of the counterparty analysis procedure by centralising all the Group's third-party integrity analyses in the Ethics & Compliance Office.

In turn, work was also performed to strengthen the anti-money laundering programme by extending the scope of the Payment Seizure Function and centrali- sing all Know Your Counterparty analy- ses in the Ethics and Compliance Office, which ensures consistency in the analy- ses and efficiency of the compliance pro- cesses. Also, in 2019 the board of trus- tees of the Cepsa Foundation approved the Manual for the Prevention of Money Laundering and Terrorist Financing.

ANTI-CORRUPTION AND BRIBERY

2019

Number of internal audit projects with an anti-corruption and anti-bribery component 8

Number of Crime Prevention Model (CPM) controls that mitigate the risk of corruption within CPM controls 207

Number of SCIIF controls aimed at mitigating fraud risk within SCIIF controls 408

Number of audit projects on non-operated assets 5

Number of reviews of investment agreements and significant anti-corruption contracts (Know Your Third Party/KYTP analysis) 8