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CHAPTER 4 Cepsa governance Code of ethics and conduct

Cepsa Group s Code of Ethics and Con- duct, which is aligned with best practic- es in the sector, covers the principles and values that our shareholder, through the Board of Directors, aims to see through- out the organization. It sets out the core principles, standards and conduct that enable us to accomplish our goals and promote our values, outlining the rele- vant legal and ethical standards and of- fering useful practical advice on how our staff should conduct themselves.

Our Code of Ethics and Conduct is appli- cable to all directors and staff of the Cep- sa Group and of those subsidiaries the company manages, irrespective of their employment relationship or type of con- tract.

The content of the Code is regularly re- viewed and updated with the help of the

company s most senior officers and the most representative federations of trade unions in each area, to tailor it to any emerging expectations of our stakeholders.

The Code is available on our website (, and we have an Ethics and Compliance Channel through which our stakeholders can submit questions and report incidences in relation to the Code of Ethics and Conduct.

We updated the Code of Ethics and Con- duct for Suppliers in 2018, also available on, to bring it into line with Cepsa s general Code and to mini- mize the main risks that could arise in the supply chain.

Our Code of Ethics and Conduct is sup- plemented and enforced through sev- eral corporate policies that govern the behavior of our staff and any third par- ties working for or representing Cepsa.

The policies fully adhere to the regula- tions in force where we operate and are available on our corporate website. The main policies comprising our internal framework of regulations are:




Designed to inform directors, agents, staff and third parties who we work with of our total rejection of any illegal behav- ior and our commitment

to prevent and tackle any criminal breaches of the law that could damage the company s value or damage its image and reputation.

Setting out the principles we must follow when doing business with third parties; on the one hand, regarding compliance with rules on international embargoes

and sanctions, international trade rules and anti-money laundering and terrorist financing regulations, and on the other, based on the specific integrity risk.

Crime Prevention Policy

Counterparty Analysis Policy

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