Through which procedures are estab- lished that must be followed to prevent or, where applicable, deal with conflicts of interest that could involve the share- holder, members of the Board of

Directors or Cepsa staff in their dealings with the company, and with respect to conflicts that could arise with customers, suppliers or other stakeholders.

Intended to establish the criteria that our staff must adhere to if breaches of the Code of Ethics and Conduct are report- ed or external and internal regulations governing the Cepsa Group are not com-

plied with. It also prohibits any reprisals against anyone who, in good faith, raises concerns about a potential breach of the Code.

Setting out the guiding principles that Cepsa Group directors and staff and third parties with whom we do business must adhere to whenever, in the course of our duties, we have to offer or receive gifts or courtesies or attend or organize events

in our dealings with customers, suppli- ers, public employees or other stakehold- er groups.

We continued developing our internal regulations throughout 2018 to adapt them to the new needs and requirements

arising in our operations, with the Board of Directors approving the following pol- icies:

Setting out the basic guidelines for our behavior concerning the fulfilment

of the pledges made by Cepsa to act re- sponsibly.

Defining the basic guidelines that must define our conduct in relation to comply- ing with human and workers rights for all our different stakeholders (employees, suppliers, customers, local and indige-

nous communities) and including oth- er principles such as equal opportunities and non-discrimination.

Covering the key features of Cepsa s Crime Prevention Model and the process

for overseeing, evaluating, reviewing and approving it.

Setting out the framework for dealing with anyone involved in Cepsa s opera- tions whose duty is to ensure their own safety and protect the environment,

adhering to prevailing laws and internal rules, to prevent or minimize hazards, workplace accidents and environment impacts.

Conflict of Interest Policy

Ethics and Compliance Channel Policy

Policy against Bribery and Corruption in the Public and Private Spheres

Corporate Responsibility Policy

Human and Workers Rights Policy

CRIME PREVENTION MANUAL

Policy on Health and Safety, Environmental Protection and Quality

412018 ANNUAL AND CORPORATE RESPONSIBILITY REPORT

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