752019 ANNUAL AND CORPORATE RESPONSIBILITY REPORT

During 2019 we have evaluated the effectiveness of the control framework established in 16 companies, having de- termined an average risk level in the fo- llowing: Cepsa Química S.A.; Compañía Española de Petróleos, S.A.; Compañía Española Distribuidora de Petróleos, S.A.; Atlas, S.A. Combustibles y Lubrificantes; Cepsa Bioenergía San Roque, S.L.U.; Cep-

sa Colombia, S.A.; Cepsa Aviación S.A.; Red Española de Servicios S.A.U.; Cepsa Gas y Electricidad, S.A.U. and CMD Aero- puertos Canarios, S.L. These analyses reflect the evaluation of the risks from a criminal point of view and, within this, the risks linked to corrup- tion in both the private and public spheres have been taken into account.

At Cepsa we have a Human and Workers' Rights Policy that is compulsory for our professionals, including the directors and employees of the subsidiaries over which we have effective control, as well as for third parties with whom we have rela- tions, such as suppliers and customers.

The purpose of this policy is to promote the eradication of discrimination due to any factor of diversity (gender, age, race, or any other personal distinction), so that all types of conduct contrary to human dignity and in breach of universal rights are sanctioned, and measures are imple- mented to encourage ethical behaviour in an environment of equality and to favour an environment of diversity. During 2019, there was only one accredited instance of harassment, which was immediate- ly remedied, as well as no resolution of breaches in our operations regarding freedom of association and collective bargaining.

Our commitment to Human Rights is closely linked to internationally recog- nised laws and practices, such as the United Nations Universal Declaration of Human Rights, the Declaration on Fun- damental Principles and Rights at Work established by the International Labour Organisation, the Guidelines for Multi- national Enterprises of the Organisation for Economic Co-operation and Develop- ment, and takes into account the provi- sions of the National Action Plan on Busi- ness and Human Rights approved by the Spanish government on 28 July 2017.

During 2019 we were not made aware of any incidents infringing the rights of the indigenous communities in the areas in which we operate, or any significant risks of breaches of labour and human rights during the risk assessments of our su- ppliers.

HUMAN AND WORKERS' RIGHTS