CODE OF CONDUCT

MESSAGE FROM THE BOARD OF DIRECTORS

At Grupo Lacrem, we are committed to operating with integrity and professional ethics, which means that all of the members of the organisation and those who collaborate with it should be capable of generating an optimal work atmosphere. Transparency, respect for legality and quality standards and the quest for sustainability, safety and dignity at work all form part of our corporate culture.

At Grupo Lacrem we work towards becoming a national and international leader in food products, specifically ice creams, through our own brands (Farggi, La Menorquina and Frigécrème), co-brands, co-manufacturing companies and private brands, and this also implies being a leader on an ethical level.

It is our duty to ensure that we treat our colleagues, partners, suppliers, employees, competitor entities, communications media, the public authorities and other stakeholders in a fair, loyal, honest and dignified manner, every single day.

This Code of Conduct has been revised with the aim of unifying and reinforcing the group’s identity and behaviour guidelines. Which is why we must respect and apply the code, as well as the regulations applicable to us in all of our areas of action. All of the group’s personnel are therefore obliged to comply with the behavioural principles established in the Code of Conduct, and to use the reporting channel Grupo Lacrem has made available to us to report any irregularities or inappropriate behaviour we may observe, or to consult the Compliance Committee on any queries we may have.

Respecting - and making others respect - the values enshrined in this Code of Conduct is crucial for the growth and success of our organisation, and we are convinced that with your collaboration, Grupo Lacrem will continue to deserve the trust and recognition of our sector, as we have done until now, ensuring these principles and values last over time.

Thank you in advance for joining us in embracing this spirit and way of working. Warm regards,

The Board of Directors of LACREM, S.A.U.

1. OBJECTIVE SCOPE

The aim of this Code of Conduct (“the Code”) is to establish the standards of ethical behaviour and principles of action that should be applied in all the areas of activity of Grupo Lacrem (hereinafter also referred to as the “Group”), with the aim of implementing a culture of compliance among its members, by promoting good practice, principles and values. To achieve this any policy, procedure or internal regulation developed will be interpreted in accordance with the spirit of this Code.

This Code also responds to the desire to have a compliance risk management system, in line with regulatory demands in the area of criminal liability of legal persons. However, the Code does not replace internal regulations and policies, as its aim is to provide a series of principles and rules that inspire and reflect the spirit of Grupo Lacrem, serving as a guide for action and comprising the essential standard of reference.

Regulatory compliance should not be limited solely to obeying the law. Ethical behaviour is the basis of all the organisation’s decisions and actions, to ensure that they are made with integrity. And this integrity will also be required from third parties linked to the organisation, seeking to form a relationship with them that is clean and transparent.

A compliance culture can only be implanted with the firm commitment of all.  The success of this project therefore depends on everyone, which is why this Code, coupled with existing policies and regulations, or those which will be developed and/or revised by virtue of it, must be known, understood and respected by everyone associated to Grupo Lacrem, whatever the commercial or employment relationship that binds them.

The conducts included in this Code are not intended to cover all of the situations or circumstances we may encounter as members of Grupo Lacrem, but rather features general rules of conduct that will serve as a guide to how to act as we carry out our professional activity.

The application of this Code and the Penal Compliance Programme it forms part of will be monitored by Grupo Lacrem’s Compliance Committee.

2. SUBJECTIVE SCOPE

This Code is applicable, and compliance with it is mandatory, for all present and future members of Grupo Lacrem, regardless of their position in the hierarchy or geographical location, and as such including members of the management

body, shareholders, executives, employees and collaborators in general, with employment, commercial, training, conventional or other kinds of contracts, provided they act on behalf of Grupo Lacrem and under the organisation's guidelines (“the Personnel”).

The Personnel acting as representatives of Grupo Lacrem in trading companies, associations, foundations or other entities shall observe this Code in the exercise of such activity, and promote the application of its principles and values.

The principles and values of this Code are extensive to all the organisations in which the group has holdings or over which a Grupo Lacrem company may have effective control, or hold positions on the management and governing bodies. Moreover, the Personnel must promote the principles and values with all individuals or legal entities related to Grupo Lacrem, such as suppliers, customers, communications media, subcontracted companies or others, in the expectation that they comply with these principles and participate in our corporate culture (hereinafter “the Third Parties”).

3. PRINCIPLES AND VALUES

This Code is based on the following principles and values which the persons indicated in section 2 above must display in each of their activities, encouraging the development thereof within their respective area of responsibility.

3.1 THE 3 “S’s”: CORPORATE VALUES

Spirit of progress, Spirit of service and team Spirit: these are the three S’s that guide Grupo Lacrem’s way of acting.

 

• Progress is optimism and quality in our response and in all of our projects.
• Service is cooperation and commitment to our customers and the company.
• Team is trust and flexibility in the relationships between our members, on all levels.

 

3.2 INTEGRITY

Integrity in business means that in all of the activities carried out by Grupo Lacrem, high ethical standards should prevail, working with honesty and inspiring confidence, with behaviour that is coherent and unswerving, protecting the organisation's good reputation.

Legislation varies over time, which is why it we need to constantly re-assess the behaviour required in business, with corporate ethics at the forefront at all times. Adjusting to criteria of integrity is essential for the success of Grupo Lacrem and each member and employee must contribute to this.  Grupo Lacrem works intensely to provide its

members the information, training, guidance and support they need to comply with the rules regarding integrity in business.

3.3 TRANSPARENCY

Transmitting transparency is a way of achieving a climate of trust, veracity and security. Transparency must be the central tenet that governs the competitiveness of Grupo Lacrem.

The group’s relationships with its customers, suppliers, employees, competitors, communications media, public authorities and other stakeholders will take place under the principles of cooperation and transparency.

Grupo Lacrem will provide truthful, appropriate, useful and consistent information on its aims, activities and projects, in accordance with the internal communication policy and the decisions made by the governing bodies. Transparency in information is a basic principle which must govern the action of all the Personnel of Grupo Lacrem.

Grupo Lacrem declares its unshakeable repudiation of any practices that may be deemed irregular in the development of its relationships with - by way of example but not limited to - suppliers, customers and civil servants.

3.4 REGULATORY COMPLIANCE

Grupo Lacrem undertakes to act in compliance with current and applicable regulations at all times. By the same token, all of the members and employees of the organisation will commit to the internal procedures and policies, and it is the duty of the shareholders, advisers, executives and heads of department to make these obligations and internal regulations known to all the Personnel, ensuring compliance with the corporate ethics principles and regulations that govern the organisation. The Compliance Committee shall coordinate and promote the appropriate verification and review mechanisms in this field.

3.5 PRIVACY AND CONFIDENCIALITY OF INFORMATION

Grupo Lacrem respects and guarantees compliance with current regulations in matters of protection of personal data and its obligation to protect said data regarding all the Personnel and the Third Parties it interacts with. To do so, it undertakes to not disclose personal data, except with specific consent and in cases of legal obligation or for fulfilment of court or administrative decisions; and it commits to adopting the necessary measures to ensure that the information is stored in a secure place, whatever its format - physical or electronic - and protected against any internal or external risk of unauthorised access, manipulation or destruction, both intentional and accidental. 

The non-public information owned by Grupo Lacrem is considered reserved and confidential. Commercial secrets, business, marketing and service plans, market and consumer studies, engineering and manufacturing ideas,

process formulas, designs, databases, registers, information on salaries and any other unpublished financial information, or of a different nature, are examples of such information.  As a result, the Personnel of Grupo Lacrem are obliged to protect said legal, technical, commercial and financial information, and the confidential information and personal data of Third Parties, undertaking the commitment to maintain the confidentiality of the information that is accessed lawfully and rejecting and sanctioning the unlawful accessing, use or transfer of confidential or personal information not owned by Grupo Lacrem or for which they have no right of access or consent from the owner.

In the event of cessation of the employment or professional relationship, the relevant Personnel or Third Parties must return any confidential information they have, including documents and storage mechanisms or media, as well as the information stored on their computer terminal, mobile telephone or any other medium.

All obligations regarding confidentiality and treatment of personal data will persist after the employment relationship has ended.

Grupo Lacrem periodically monitors the telematic and physical media available to the Personnel, accessing any information stored on the media that is owned by the organisation, under the principles of proportionality and respect for privacy, with the aim of verifying compliance with current legislation.

3.6 INDEPENDENCE

Independence is a basic quality principle within our professional activity. Consistent with this, the Personnel of Grupo Lacrem shall abstain from participating in matters in which their personal or family interests, or those of people belonging to their circle of friends, may be directly or indirectly affected. In the event of conflict of interests, the procedures set forth in the provisions of section 7 of this Code will be followed.

3.7 PROFESSIONALISM AND TECHNICAL RIGOUR

In all of their actions the Personnel of Grupo Lacrem shall apply objective professional criteria, with the diligence and quality necessary to guarantee excellence in the business of production of foodstuffs - confectionery and ice cream sector Technical quality, professionalism, rigour and excellence are the qualities the Personnel of Grupo Lacrem must have in order to perform their activity in the most productive, competitive and sustainable manner possible.

3.8 FAIR COMPETITION AND CONSUMER PROTECTION

Grupo Lacrem seeks to ensure respect for competitors, observing the applicable laws in the area of competition and consumer rights. The Personnel and Third Parties that Grupo Lacrem interacts with shall avoid unfair actions, such as abuse of confidential information, collusive agreements on price fixing, sharing of markets, participation

in monopolies or abuse of a dominant position, as well as any other conduct that undermines free and fair competition.

As a result, the Personnel of Grupo Lacrem must at all times respect the following rules:

 

• The commercial policy and prices will be established independently and will never be formally or informally agreed on with competitors or other parties that are unrelated, either directly or indirectly.
• The customers, territories or product markets will never be distributed or shared between Grupo Lacrem and its competitors, but will always be the result of fair competition.
• The Personnel of Grupo Lacrem, and in particular those devoted to selling and buying activities, or those in frequent contact with customers, suppliers or competitors, must guarantee that they are familiar with the applicable laws in the area of competition and/or ask for advice from Grupo Lacrem’s legal department or the Compliance Committee.

 

3.9 COMMITMENT TO CONSTITUTIONAL RIGHTS

Grupo Lacrem declares its commitment and attachment to constitutional rights such as the right of opinion, association, expression, privacy, image, secrecy of communications and dignity of its employees, with the scope and content the Constitutional Court confers on them in the work environment. These principles are applicable to all aspects of the employment relationship, from contracting, adjudication of tasks and postings, promotion, remuneration, disciplinary measures until the end of the contract.

3.10 EQUAL OPPORTUNITIES

Grupo Lacrem promotes justice and equality of conditions and treatment between men and women with regards to access to employment, training, remuneration, mobility and all other working conditions.

A culture of merit and effort, objectivity and personal betterment is proclaimed.

One of Grupo Lacrem’s primordial values is the talent and professionalism of the Personnel, and as a result it undertakes to select personnel based on training, experience and personal merit.

3.11 NON-DISCRIMINATION

Grupo Lacrem promotes the principles of non-discrimination for reasons of race, nationality, age, gender, civil status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of its members, as well as equal opportunities for all of them. Grupo Lacrem rejects any manifestation of violence, of physical, sexual or psychological harassment and bullying, or other behaviours which generate an intimidating or offensive environment for the

personal rights of the Personnel and adopts the necessary measures to prevent this kind of conduct or end it once detected.

3.12 POLITICAL AND RELIGIOUS NEUTRALITY

Grupo Lacrem does not adhere to any political or religious ideology or tendency, as a result of which, without detriment to the respect of the constitutional rights of the Personnel, their freedom of expression and ideological and religious freedom, any conduct or practice that associates or may associate Grupo Lacrem with a specific political or religious trend will be rejected. Any connection, membership or collaboration of the Personnel with political parties or other types of organisations, institutions or associations for public purposes will be carried out in a manner that makes the personal nature thereof clear, thus avoiding any relationship with Grupo Lacrem. It is absolutely forbidden to finance, either directly or indirectly, any political party or organisation of the kind that is linked to a political party or to a member of a local, regional, autonomous community, national or international political party, in the name and on behalf of Grupo Lacrem.

3.13 WORK-LIFE BALANCE

Grupo Lacrem respects the personal and family life of its Personnel and undertakes to promote the harmonisation of work and family responsibilities for members of the organisation. By virtue of this, the group promotes equal opportunities and treatment of men and women, implementing measures that are effective and which meet the real needs of its members, in line with applicable regulations.

4. RELATIONAL DOMAIN

4.1 RELATIONSHIP WITH ITS MEMBERS AND EMPLOYEES

The hiring of personnel at Grupo Lacrem takes place in accordance with the principles of merit and ability.

Any engagement, appointment, remuneration, promotion or transfer will be based on the candidate's qualifications, performance, skills, experience and general suitability.

Grupo Lacrem considers people to be its fundamental pillar and as a result, it defends and guarantees the fulfilment of human and labour rights, and commits to applying current regulations and good practice in the area of working conditions, health and safety at work.

At Grupo Lacrem, all Personnel are guaranteed the rights set forth in the applicable collective bargaining agreement and the Statute of Workers, as well as all of the rights emanating from the specific contract of employment.  The group also guarantees a safe, healthy work environment, providing the personal protective equipment (PPE) required by regulations.

In their employment or professional relationships with other employees and members, all of the Personnel of Grupo Lacrem must act with respect for their dignity, values and culture, avoiding

circumstances of violence, harassment, abuse or other situations of discrimination due to race, religion, age, nationality, gender or other personal or social conditions. By the same token, steps must be taken to ensure the workplace integration of Personnel with any kind of disability.

Moreover, and with the aim of promoting the ethical culture, the senior managers must guide the actions of the Personnel under them through honest, exemplary behaviour in the professional environment, and must set clear, ambitious and realistic goals, striving to grant the greatest possible individual responsibility and freedom of action to those who depend on them.

Finally, the organisation values any individual or collective initiative, even when promoted from the organisation itself, which foments and develops any personal relationship between members, including outside of its installations and working hours, which may result in a better working atmosphere and increased team spirit. However, all staff members must have a sufficient degree of maturity to ensure that personal relationships never impair the normal performance of their respective duties and tasks, prioritising professional appearance within interpersonal relationships at all times in the workplace.

4.2 RELATIONSHIP WITH SUPPLIERS AND CUSTOMERS

Operations with suppliers and customers must be carried out with objective, impartial criteria in mind, guaranteeing equal opportunities and avoiding favourable treatment or interference of conflicts in selection processes.

Grupo Lacrem demands a level of appropriate commitment from its suppliers, with socially-responsible practice that is compatible with this Code.

All requests for external procurement and purchases must be followed with maximum transparency, avoiding any favourable treatment.

In the case of procedure for contracting products or services from organisations or persons with which the Personnel have an economic or family connection, the member in question must raise the question with Grupo Lacrem’s Compliance Committee as soon as they become aware of it, so that the committee can grant the corresponding authorisation.

However, in exceptional cases in which it is essential that a commercial relationship or contract be entered into with a connected person (see section 7 of this Code), due to the characteristics of the customer or supplier, the Compliance Committee shall assess whether authorisation of the arrangement is appropriate, and if so, it will be assigned to a member of the organisation who does not have a personal relationship.

The transmission of values and generation of honest, transparent dialogue with customers are principles that govern the activity of Grupo Lacrem.

The Personnel shall interact with customers in a lawful, ethical and respectful manner. They must strive to have an open, empathetic attitude towards suggestions transmitted by the customer, and be permanently

willing to take any action necessary to clarify doubts and correct defects and errors, as well as to introduce the relevant improvements in the activity.

4.3 RELATIONSHIP WITH CIVIL SERVANTS, PERSONS CARRYING OUT PUBLIC, NATIONAL AND INTERNATIONAL DUTIES

Relationships with the Public Authorities, members of judiciary and regulatory bodies are contemplated under the principles of cooperation and transparency. The Personnel will interact with the authorities and public and legal institutions lawfully and ethically, abiding at all times by the procedures officially established by the public sector, respecting the rules and preventing any corrupt conduct.

It is expressly forbidden to directly or indirectly offer, grant, request or accept presents or gifts, favours or compensations, whatever their nature, to or from authorities or civil servants.

In addition, the Personnel of Grupo Lacrem will abstain from making payments to facilitate or speed up processes, consisting in the handing-over of money or other objects of value, whatever the amount, in exchange for the assurance or acceleration of an administrative or public hiring process or action, of any nature whatsoever, for any legal body, public authority or official body.

4.4 RELATIONS WITH THE COMMUNICATIONS MEDIA AND USE OF SOCIAL MEDIA

As a general rule, and unless Grupo Lacrem has appointed spokespeople or express authorisation has been given by the communication department, the Personnel shall refrain from giving confidential or sensitive information in any type of media, professional symposia, seminars or social media, on matters directly or indirectly related to Grupo Lacrem.

If applicable, when maintaining contact with media, the Personnel undertake to deploy dignified, respectful and truthful treatment towards those who carry out tasks in said media. No misleading information may be disclosed, by which we understand information that in any way misleads or may mislead the recipients thereof, and no advertising that is false or derogatory towards the competition or third parties may be undertaken.

In addition, the Personnel undertake to disseminate information that is truthful and transparent, respecting the privacy and confidentiality of the people involved.

All of the information and knowledge generated within the domain of Grupo Lacrem is the property of Grupo Lacrem, under the terms established by current legislation.

4.5 RELATIONS WITH THIRD PARTY CONTRACTORS AND SUBCONTRACTORS

The selection of contracting and subcontracting entities for the provision of services to Grupo Lacrem is governed by criteria of objectivity and transparency, reconciling the interest of the group with

the convenience of maintaining stable, responsible relationships, and with the goal of attaining quality and excellence in the goods and services reciprocally provided.

The commercial action of Grupo Lacrem is moves within the national and international field.

Grupo Lacrem expects Third Parties to act in accordance with the applicable laws, regulations, sectoral codes and contracts, and the generally accepted criteria of sustainability, such as those related to the preservation of human rights, safety and the environment and the prevention of criminal behaviour.

Before embarking on a contractual relationship of provision of services, Grupo Lacrem analyses, evaluates and contrasts the Third Party Contractor with due diligence in order to ascertain first-hand its integrity, quality and suitability.

5. FINANCIAL TRANSPARENCY AND HONEST COLLECTION OF MONEY OWED

The organisation’s information faithfully reflects the reality of its economic, financial and property situation, in accordance with generally accepted accounting principles.

Grupo Lacrem is governed by commonly accepted accounting principles and therefore prohibits the undertaking of any action which hinders or obstructs tasks related to auditing and evaluation of its financial statements.

The group guarantees that its business and financial records are accurate and complete, which is the responsibility of all of its members. To this end, Grupo Lacrem provides its members with the necessary training for them to be aware of, understand and fulfil the commitments established by the Group in the area of internal control.

The Personnel shall avoid obtaining undue advantages in fiscal terms for the Group, and ensure that the information declared to the authorities in this field is truthful and a faithful reflection of the organisation's reality.

It is forbidden to make declarations and annotations which are false or lead to error in any information, publication, document or proof of expenses.  Falsification of documents and accounts or distorted presentation of the facts may constitute fraud.

The Personnel must respect the financial estimates prepared for each customer and register the time and tasks devoted to the matter appropriately, assigning material and personnel resources to it in a reasonable and efficient manner.

Grupo Lacrem will at all times attempt to invoice reasonable amounts, in keeping with its activity.

6. ACCEPTANCE AND GIVING OF GIFTS AND INVITATIONS

Grupo Lacrem rejects any form of bribery or corruption, either with public entities or between private individuals. The group rejects any incentives, gifts and invitations which infringe upon this principle.

This corrupt conduct consists of accepting or offering an unjustified benefit or advantage of any nature, for oneself or for a third party, in return for unduly favouring another person in the contracting of products or services, in commercial relations or in relationships with the authorities.

Personnel acting on behalf of Grupo Lacrem will relate to public and private entities in a lawful, ethical and respectful manner.

6.1 ACCEPTANCE OF GIFTS AND INVITATIONS.

As a general rule, the Personnel must not accept gifts or presents, including cash, as a means of generating business in the group or in a third party. That is to say, in return for unduly favouring another person in the contracting of products or services, in commercial relations or in relationships with the authorities.

Grupo Lacrem will only accept gifts, gestures, invitations or benefits from members of the group or Third Parties (customers, suppliers, collaborators or others) if all of the conditions indicated below are met cumulatively:

 

• (a) They are not money.
• (b) Their value is not excessive or exorbitant.  That is to say, their value must lie within reasonable, current or ordinary limits, responding to habitual practice within the sector (by way of an example, gifts with commercial logos or flowers on special occasions). Any doubts must be resolved by the Compliance Committee of Grupo Lacrem.
• (c) They may not be seen as conditioning the independence and professionalism of Grupo Lacrem.
• (d) They should not imply any type of influence on the group’s activities, creating obligations or commitments to third parties.
• (e) They should not lead to undue economic benefits for Grupo Lacrem.
• (f) They should not cause conflicts of interest for either party.

 

If all of the circumstances set forth are not fulfilled, acceptance is prohibited and consequently, the gift must be returned in the same way as it was received. If the return of said gift may offend the giver, or the circumstances in which it was given prevent its return, it may be accepted after notifying the Compliance Committee, which will decide whether the gift will be donated to a charitable entity or, by contrast, distributed or raffled among the Personnel of the group.

The provisions herein apply to suppliers, customers, civil servants, politically exposed persons, holders of public office or people who perform public services, employees or any other individuals or legal entities linked contractually or commercially to Grupo Lacrem.

6.2 THE GIVING OF GIFTS

Gifts may be given provided they are for promotional or professional purposes related to the group’s activity.

But in either case, the gifts, presents or gestures made by Grupo Lacrem to third parties may not be of excessive or exorbitant values. That is to say, their value must lie within reasonable, current or ordinary limits, responding to habitual practice within the sector.

In the event that the gift, present or gesture may be deemed to be of excessive or exorbitant value, notification must be sent to the Compliance Committee setting forth the motives and the committee will grant the respective authorisation, provided it is in keeping with what is socially acceptable according to the group's commercial and promotional practice.

In no case may the gifts, presents or gestures conceal or have the consideration of undue compensation for securing unjustified advantages and/or undue favourable treatment. Undue favourable treatment is treatment that benefits a person or organisation without a service or asset existing in exchange for it.

Any case which gives rise to doubts must be communicated to the Compliance Committee, so that it may determine whether or not the gifts are appropriate.

The provisions herein apply to relationships with suppliers, customers, civil servants, politically exposed persons, holders of public office or people who perform public services, employees or any other individuals or legal entities linked contractually or commercially to the group.

All the products produced by Grupo Lacrem will also be considered gifts.

For the purposes of the provisions of this section, the threshold of 100 Euros is established as the maximum limit of mere courtesy.

7. CONFLICTS OF INTEREST

The Personnel of Grupo Lacrem must avoid situations which may involve a conflict between their personal interests and those of the organisation.

A conflict of interest occurs in situations in which the personal interest of the Personnel and the interests of the group collide, either directly or indirectly.

Personal interest will exist when the matter directly concerns or affects a member of the Personnel.

The Personnel have the obligation to promote the interests of Grupo Lacrem and it is forbidden for them to benefit solely personally from commercial opportunities that arise as a result of information of the group, or to benefit third parties with them.

Affected Personnel must immediately inform the Compliance Committee in the event that they are immersed in a similar situation, in order to find a suitable solution to the issue.

7.1 RELATED PERSONS

For the purposes of this Code, the following persons will be considered individuals or legal entities who are related to shareholders, advisers, executives or members of the Personnel:

 

• (a) Spouses or persons with a similar sentimental relationship with them.
• (b) Ascendants, descendants and siblings of the member of the Personnel or their spouse (or person with a similar sentimental relationship with them).
• (c) The spouses (or persons with a similar sentimental relationship) of ascendants, descendants and siblings.
• (d) Entities in which the member of the Personnel or their respective related persons are themselves, or through a third party, in any of the control situations established in the Law or in which they have maintained these control relationships during the two (2) years immediately prior to taking over their position as member.
• (e) Companies or entities in which the member of the Personnel or any of the related persons, either themselves or through a third party, hold or have held a management or executive position during the two (2) years prior to taking over their position as member, or a position from which, in the two (2) years prior to taking over their position, they receive or have received fees for any reason, provided, moreover, the executive, member or employees has, or has had, in the two (2) years immediately prior to taking over their position, significant influence on the financial and operational decisions of said companies or entities, and likewise when these situations have occurred in the two years prior to their taking over the position as executive.

 

7.2 RULES OF CONDUCT IN CASES OF CONFLICT OF INTERESTS

In relation to possible conflicts of interest, the Personnel of Grupo Lacrem shall observe the following rules of conduct:

 

• (a) Independence: act at all times with professionalism, loyalty to the group and independently of their own interests or those of third parties. As a consequence, they shall in all cases refrain from prioritising their own interests at the cost of those of the organisation.
• (b) Abstention: abstain from intervening or influencing the adoption of decisions in which there is a conflict of interest and which may affect the group, from taking part in the meetings in which such decisions are considered and from accessing confidential information that affects said conflict.
• (c) The existence or possible existence of a conflict of interest must be communicated in writing to their immediate superior in the hierarchy, who will inform the Compliance Committee.

 

In this communication, the Personnel must indicate:

 

• (a) Whether the conflict of interest affects them personally or is through a person connected to them, identifying them if applicable.
• (b) The situation giving rise to the conflict of interest, detailing the object and main conditions of the planned operation or decision, if applicable.
• (c) The measures adopted to avoid the conflict and guarantee the safeguarding of the general interest.

 

These general rules of conduct will in particular be observed in cases in which the conflict of interest circumstance is, or may reasonably be expected to be, of a nature that constitutes a structural, permanent situation and specifically, in relation to the contracting of goods and services and the recruitment and hiring of the personnel of Grupo Lacrem.

Such matters must in all cases be submitted for the consideration and decision of the Compliance Committee, whose ruling will be of a binding nature.

8. CORPORATE REPUTATION AND IMAGE

A positive image is an intangible value that is built up. This image responds to the conduct that Grupo Lacrem and its Personnel construct over time with regard to their different interest groups and the perception generated by this conduct. Because of this, Grupo Lacrem considers the organisation's image to be one of the most valuable assets for being able to retain the trust of its shareholders, customers, members, suppliers, collaborators, authorities and society in general.

The Personnel must use the name of the different companies that form part of the group for purposes that are legitimate for the group’s interests.

Members and employees who leave the institution or establish a spin-off or new company may not use factors that allude to Grupo Lacrem in their corporate image or name, unless they have the express written consent of the organisation.

The Personnel of the group will avoid publication of comments or rumours that may threaten the public image of any company in the group on their social media profiles or blogs, even in a personal capacity. Moreover, in their communications they will follow the rest of the principles listed in this Code, in particular in section 4.4 on relations with the media, which extend to communications on social media:

 

• Unless Grupo Lacrem appoints spokespeople or express authorisation has been given by the communication department, the Personnel shall refrain from maintaining relations with any type of social communication media on matters directly or indirectly related to Grupo Lacrem.
• The confidentiality of the customer-company relationship will be preserved, and no data on transactions or matters in which the group has intervened shall be disclosed without the prior consent of the customer.
• No political, religious or moral stances will be adopted, and staff must avoid giving opinions on these matters in any situation in which they identify themselves as a member or collaborator of the group as spokesperson.
• No information that is damaging to the group, customers or interests of the group will be published on social or other media, and staff will avoid issuing negative opinions or taking part in debates in which the group or its interest may be affected. Misleading information may not be disclosed, either, by which we understand information that in any way may mislead, or lead to misconception in its recipients.
• The competition will not be criticised in public, and staff will avoid criticism of its work and/or activity.

 

9. USE OF ASSETS

Grupo Lacrem undertakes to make the necessary and adequate resources for the performance of its business activity available to its Personnel.

The electronic media and systems are the property of Grupo Lacrem, and may only be used for business purposes, in relation to the business authorised by the organisation. The public or personal use thereof is not authorised. The Personnel undertake to use the resources and media employed for the performance of their activity responsibly, carrying out exclusively professional activities in the interest of the organisation with them.

If applicable, the use of equipment, systems and computer programs which the organisation makes available to the Personnel for the performance of their work, including Internet access and operations, must meet security and efficiency criteria, and any IT usage, action or function that is unlawful or in breach of the rules or instructions of Grupo Lacrem is excluded, even if personal equipment is used. Personnel who enter any kind of information in the group’s computing systems must ensure that it is rigorous and reliable.

By the same token, the Personnel will take all possible measures to avoid the use of the group's electronic systems and resources for the treatment and distribution of material that is offensive or inappropriate in its content.

Grupo Lacrem is the owner of the property and rights of usage and operation of the equipment, programs, systems and other works and rights that have been produced, improved and

exploited by its Personnel within the framework of their professional activity and/or based on the systems, programs or computer equipment owned by the organisation.

Grupo Lacrem shall respect the principle of confidentiality with regard to the rights, licences, programs, technological knowledge and systems the ownership or rights of operation or usage of which correspond to the organisation. Any information or disclosure regarding the organisation’s IT systems require the prior authorisation of the Compliance Committee.

The Personnel shall not exploit, reproduce, replicate or cede the group's IT systems and applications for purposes other than its own. Moreover, they shall not install or use on the group’s computer equipment programs or applications the use of which is illegal or which may damage the systems or harm its image or interests, or the interests of third parties.

Given the exposure of IT files to piracy, infection by viruses and other similar risks, the Personnel of Grupo Lacrem are obliged to respect the security regulations established for this purpose. In this regard, all the Personnel undertake to use their personal access keys  exclusively, and are not allowed to grant usage thereof to third persons, for any reason whatsoever.

10.ACCESS TO CORPORATE ASSETS

The computer resources, including e-mail, the Grupo Lacrem makes available to the Personnel are work tools owned by the organisation, both in relation to the hardware and software installed and in relation to the contents, and as such must be used strictly for professional purposes in the exercise of the work duties entrusted to them.

To this end, Grupo Lacrem may make any checks it deems appropriate on the utilisation of the resources placed at their disposal, including access to the contents of e-mails and any file the Personnel may have on the computer, since the contents will be to all intents and purposes considered documentation belonging to the organisation.

11. PROTECTION OF INTELLECTUAL OR INDUSTRIAL PROPERTY

Grupo Lacrem is committed to the protection of intellectual and industrial property, both its own and that of others.

It is forbidden for Grupo Lacrem to utilise the intellectual and industrial property rights of third parties (e.g. brands, distinguishing signs, industrial designs, patents, utility models, copyright) without proof that they have the corresponding rights and/or licences. The Personnel shall take the necessary measures to protect the intellectual and industrial property of third parties, ensuring that the processes and decisions in this area are documented and can be checked and justified.

The Personnel will at all times respect the scientific authorship of others. With regard to content, images, programs downloaded from the Internet, the appropriate licence from the owner of the intellectual or

industrial property rights is held, even if it has been obtained through search engines such as Google.

All of the programs installed in the group’s computers and mobile devices have the corresponding licence for use.

The publications and results produced by the group will always be published reliably reflecting the coefficients of real individual contribution and personal contribution of each member of the Personnel, in accordance with criteria based solely on merit and effective dedication.

No member of the Grupo Lacrem Personnel shall use, for their personal ends, or transmit to others any content, technologies, brands, methodologies, know-how or any kind of information belonging to the group even if it has been obtained or developed by that same member of the Personnel in their work environment.

12. HEALTH AND SAFETY AT WORK

As an essential part of its activity Grupo Lacrem promotes health and safety at work, and applies the preventive measures established in current legislation in this field, ensuring they are strictly observed by the Personnel.

To this end, this commitment will be implemented through programmes designed to: (i) prevent injuries and harm to property, (ii) provide safety for the Personnel and the assets of the organisation, and (iii) comply with current ethical and regulatory norms. In this order, the group has the appropriate Occupational Risk Prevention Plan in its work centres.

The Personnel who work in the organisation are also responsible for maintaining a suitable environment in terms of order and cleanliness in the installations, contributing to safe practice and the elimination of hazardous conditions in the workplace, and for complying with the pertinent laws in the area of safety, hygiene and transport, as well as for fully cooperating with any government or private investigations or audits carried out in the installations.

Furthermore, it is forbidden for Personnel to attend the workplace under the influence of any kind of drugs, toxic, psychotropic or narcotic substance or alcoholic beverages while fulfilling the duties entrusted to them.  In addition, the possession or carrying of weapons of any kind, or potentially dangerous devices, is forbidden.

13. PROTECTION OF MINORS

Grupo Lacrem will not allow any form of enforced or involuntary labour in its production and/or commercial centres, and will not collaborate with external manufacturers, suppliers and subcontractors if they allow it.

Grupo Lacrem will not hire staff who have not reached the minimum legal age for working. In addition, persons under the age of 18 may not work night shifts

or under hazardous conditions, in accordance with the provisions of the International Labour Organization.

14. QUALITY, FOOD SAFETY AND ENVIRONMENT PROTECTION

The group commits permanently to the sale and manufacture of products of the highest quality, and the protection of the health and safety of our consumers. Consequently, no deviation and/or breach of the organisation's policies and procedures relating to the handling, manufacture, sale and storage of its products will be tolerated.

The Personnel have the duty to immediately notify their immediate superior in the hierarchy of any situation that may indicate that the quality of the product does not fulfil optimal conditions for commercialisation, or is not acceptable.

If there is a safety problem with the product, all of the people who may have some responsibility for this will be made aware of it. The relevant Personnel will cooperate fully with the government regulations and, if necessary, recall the product or take any other appropriate action, in accordance with the recall procedures approved internally by the group.

Moreover, Grupo Lacrem affirms its commitment to being an environmentally responsible corporation. Nature conservation, recycling and energy use programmes that promote a clean atmosphere and water are supported, as are those aimed at the reduction of solid waste. In this order, the Personnel are required to minimise the impact the group has on the environment, via methods that are socially responsible, based on science and/or economically beneficial. This is in accordance with the organisation's Environmental Management System Manual which is available for all members and certified under the global standard ISO 14000, by a certification company.

Finally, the group has the International Featured Standards (IFS) certificate in food safety, one of the best global benchmarks in the field, and also has the appropriate legally required civil and environmental policies.

15. CORPORATE SOCIAL RESPONSIBILITY

Grupo Lacrem undertakes to maintain a ethical and responsible commitment to constant, voluntary solidarity contribution projects in favour of the community and the environment.

Within the framework of the aforementioned actions, Grupo Lacrem invites its Personnel to take part in said projects, at all times and in all cases respecting the principles and values of this Code.

All of the group’s activities will be carried out sustainably, promoting social, economical and environmental improvement, and improvement of quality of life.

16. COMPLIANCE WITH THE CODE OF CONDUCT

This Code is a set of internal regulations which are mandatory for all the Personnel of Grupo Lacrem, regardless of the position in the hierarchy, seniority or duties the different members have within the group.

The Personnel of Grupo Lacrem must comply with and apply this code - ensuring others do the same - and with the rest of the internal regulations of the group regarding the legal and ethical obligations that govern the profession or activity. In this order, all employees who join or become part of the group must accept the principles and standards of action established within it. In addition, the Third Parties that interact with Grupo Lacrem must be aware of and commit to respecting this Code in their relations with the organisation, for which it is disseminated and reading of it and commitment to it is required.

Moreover, any breach of this Code may give rise to the application of disciplinary measures, including the possibility of terminating the employment contract with the offender or, if applicable, the initiation of any legal steps or action that Grupo Lacrem deems appropriate, depending on each case.

Nobody, regardless of their level in the hierarchy, is authorised to request that a member of the Personnel contravene that which is laid down in any provision of the Code.

Neither “due obedience” nor “ignorance” will function as an excuse for liability due to breach of a provision of this Code. Consequently, no member of the Personnel may justify improper conduct relying on an order from a superior or ignorance of the Code.

17. REPORTING CHANNEL

A channel of communication is available to Personnel through which they must confidentially and anonymously, if they so wish, report any irregular activity that contravenes the principles contained in this Code, or any behaviour contrary to current regulations, including on criminal risk prevention.

Any kind of communication in this regard must be made in writing to the following e-mail:              compliance@lamenorquina.com. The e-mail must include a detailed, honest description of the fact that serve as a basis, explaining how they have become aware of the issue, identification of the persons involved and attaching all of the evidence deemed appropriate to accredit the facts of the communication.

The Personnel must report any breach or violation of the conducts described in this document. Grupo Lacrem will at all times guarantee the confidentiality of the treatment of this type of communication, and of the reporting person or employee. Likewise, Grupo Lacrem will not accept any kind of reprisals against members who report alleged breaches, provided there is good faith on the part of the reporting party.

Any behaviour which contravenes legislation or the provisions of this Code shall result in application of the disciplinary measures set forth in current applicable legislation according to whether the relationship is one of employment or commercial. With regard to external collaborators, the measures deemed necessary in every case will be applied, in accordance with the criterion of proportionality guaranteed by compliance with this Code.

Furthermore, the Personnel of Grupo Lacrem must report the initiation, evolution and result of any legal proceedings of a punitive nature, whether civil, labour, criminal or administrative, in which a member of the group's Personnel is under investigation, charged or accused, and this may affect the fulfilment of their duties in the group or damage the image or interests of the same.

Finally, it is hereby emphasized that only irregular or unlawful conduct that involves or may involve criminal behaviour or a contravention of this Code should be notified through the reporting channel. Therefore, issues that are excluded from the reporting channel include, but are not limited to, reporting matters related to human resources, complaints due to defects in work equipment, requests for office materials, complaints, personal claims which do not comprise a breach or opinions, among other suggestions of a similar nature.

18. PROHIBITION OF RETALIATION

Grupo Lacrem will ensure that no member who has in good faith reported an infraction or irregularity to the reporting channel be subject to any kind of retaliation. Moreover, any kind of retaliation is a serious ethical violation which must be reported to the Compliance Committee as soon as possible.

19. VALIDITY AND REVIEW

This Code was approved by the Board of Directors on 17 December 2020 and must be reviewed and updated periodically in accordance with possible changes or modifications in legislation, suggestions and proposals made by employees, and due to the commitments acquired by the group in matters of corporate social responsibility. In short, it may be modified with the aim of maintaining the culture of compliance within the organisation at all times, materialised in the principles of transparency, responsibility and prudence towards third parties and its own members and business partners.

Any modification or review of the Code will be suitably communicated to the members and collaborators of Grupo Lacrem and made available to any persons, entities or authorities that have a relationship with the organisation.