1. OBJECT

The Code of Ethics and Conduct contains a systematized compilation of the guiding principles and standards regulating the behavior of ENERDEALERS, as well as the people who comprise them within the framework of their professional activity and the relationships that, as a result of that activity. , maintain among themselves or with third parties, all with the aim that their actions not only comply with current legislation, but also respond to demanding standards of professionalism, integrity and sense of responsibility. Its content is complemented by ENERDEALERS' internal policies, standards and procedures to which the Code itself refers.

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2. SCOPE OF APPLICATION

The Code and the rules that complement it apply to the employees and directors of the companies of ENERDEALERS or under the brand of ENERDEALERS, to the members of the administrative bodies of said companies and to those who, by maintaining a close or permanent relationship of collaboration with ENERDEALERS, adhere to it. or are subject to compliance with the regulations that affect them or that are mandatory due to the nature or purpose of their activities.

It will be ensured that suppliers, contractors and other people who maintain professional relations with ENERDEALERS are aware of the aspects of the Code that affect them and, as soon as it is necessary and depends on ENERDEALERS, they will be required to behave in accordance with the principles and standards established therein.
 

ENERDEALERS should be understood as ENERDEALERS S.L. as well as any of its franchises, subsidiaries or investees, referred to in this document generically as ENERDEALERS.

The expressions “people who are part of the company”, “employees and managers”, “employees”, “professionals who work for ENERDEALERS”, etc. used to designate the persons bound by the rules of the Code must be understood extensively, as a generic reference to all those who, in accordance with this article, are included in its subjective scope of application.

The Code will be given maximum dissemination and will be available on the ENERDEALERS website and intranet.

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3. VISION, MISSION AND VALUES

Vision

Enerdealers' mission is to create a community among our stakeholders, suppliers, intermediaries and clients, basing our relationships on long-term, transparency and trust.

Mission

Enerdealers is an energy consulting and raw materials trading company committed to a sustainable world. We work together with our partners and suppliers to ensure integrity and transparency in our relationship, we offer the best products and services, assuming common responsibility for international and local regulations.

Values

Efficiency: We make optimal use of our resources and our time, as well as that of suppliers and customers. We are agile and flexible in the way we work to obtain the best results for everyone.

Respect: We create a community of trust among our stakeholders, being aware of the impact of our decisions and actions on their businesses, personal lives, society and environment.
 

Transparency: We do what we say we are going to do, in the way we deal with our stakeholders.
 

Fair play: We identify what is truly critical and make a difference in our community of stakeholders to achieve goals and results for everyone, building a relationship of fair play and added value.
 

Innovation: We take advantage of the opportunities that arise in the context of the energy transition to create innovative solutions to build a more sustainable world.

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4. PRINCIPLES OF ETHICAL, TRANSPARENT AND SOCIALLY RESPONSIBLE ACTION

These principles, which constitute the ultimate foundation of the standards included in this Code, include the following:
Ethical, transparent and socially committed action, in recognition of the role and responsibility that corresponds to private entities in the adequate development and progress of Society. Furthermore, respect for the legitimate rights of all natural or legal persons with whom it relates and those of the Company in general must be guaranteed. This implies:

a) Strict compliance with laws and contracts and the obligations that arise from them, as well as good commercial practices and customs.

b) Respect for the rights and commitments acquired with those who participate as partners or shareholders of the different companies that make up ENERDEALERS.
 

c) Equity in relationships with directors, managers, employees and, in general, collaborators. This requires objectivity in their selection and promotion, adequate and reasonable remuneration and conditions of collaboration, and non-discrimination based on race, political ideology, religious beliefs, sex, age or social status.
 

d) Commitment to transparency and truthfulness in product and service offerings, and in the information provided to shareholders, clients and in general, as well as the search for permanent excellence in the provision of services.
 

e) Development of businesses and activities that are sustainable over time and respectful of the environment, the environment and social interest. Reciprocal respect and full consideration of human rights and values govern relationships with and between people at ENERDEALERS.

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4.1. Compliance with current legislation

Among the principles of ENERDEALERS is the commitment to strictly comply with laws and contracts and the obligations that arise from them, as well as good business practices and customs. The effective observance of this principle requires that all those who are part of ENERDEALERS identify with it, make an effort to know the regulations relating to their professional activities and strive to comply with them as soon as they are applicable, taking into account not only its literal wording. but also to its spirit and purpose.
In the same way, they must act with regard to customs and good commercial practices, as well as contractual obligations, considering that honoring what has been agreed and complying, in good faith and promptly, with the commitments acquired is , in addition to an elementary duty of justice, a guarantee of our credibility as a company.

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4.2. Respect and safeguard of Human Rights

ENERDEALERS adheres to the United Nations Global Compact, and, consequently, is committed to ensuring that the ten principles that comprise it are scrupulously respected within its organization.

This implies that, within its sphere of influence, it must act decisively in favor of the defense of the human rights contained in the “International Bill of Human Rights”, and ensure that none of the companies integrated into its group are responsible, by action or omission, of any form of violation of those rights.
 

Likewise, and with regard to the principles related more specifically to the protection of workers' rights, the adhesion of ENERDEALERS to the Global Compact commits us directly to the respect, defense and protection of Human Rights in the Conventions of the International Labor Organization (ILO) and in the Declaration of Fundamental Principles and Rights at Work.
Therefore, ENERDEALERS is obliged, and its members must contribute to ensure that these obligations are strictly met, to:
 

a) Avoid discriminatory practices or practices that undermine the dignity of people.
 

b) Reject child labor and forced or compulsory labor.
 

c) Respect the freedom of union, association and collective bargaining of its employees, as well as the role and responsibilities that correspond to the representation of workers in accordance with the legislation in force in each country.
 

d) Offer decent employment.
 

e) Implement supervision procedures that allow for the identification, with due diligence, of possible risk situations of violation of human rights, and establish mechanisms to prevent and mitigate said risks.

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4.3. Social responsability

Aware of the role and responsibility that corresponds to private entities in the adequate development and progress of society, ENERDEALERS tries to act in a socially responsible manner, and proposes, as a permanent aspiration, to reconcile the company's objectives with the legitimate interests of the so-called “interest groups” with which it relates (employees, shareholders, clients, suppliers, etc.) or those whose activity impacts.

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4.4. Respect for the environment

The development of businesses and activities that are sustainable over time and respectful of the environment, the environment and social interest are part of the basic principles of action of ENERDEALERS.

ENERDEALERS's criteria are the integration into the business of environmental protection policies, the development of environmental management actions and the promotion of environmental responsibility. It is the obligation of all professionals who work for ENERDEALERS to follow the company's guidelines in this matter, strive to minimize the environmental impact of their activities and use the equipment, facilities and means of work in the most efficient way possible.

Likewise, those responsible for relations with contractors or external collaborating companies will convey to them the need to align with these principles and will require compliance with the environmental procedures and requirements that apply in each case.

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4.5. Confidentiality of information and protection of personal data

Confidentiality of information
 

ENERDEALERS has an Information Security Regulation whose objective is to preserve the confidentiality, integrity and availability of information, and establish procedures for the selection and management of passwords, the treatment of documentation, and the use of email and of temporary files.

The information is the property of the company and its security is the responsibility of all professionals who work for ENERDEALERS, who are obliged to protect it and carry out their activities following the established security standards and procedures, and avoid any risk, internal or external, of unauthorized access. consent, manipulation or destruction, both intentional and accidental.
 

The professionals who work for ENERDEALERS will not use the information they have for purposes other than those that, due to their work or professional activity, justify their access to it. Failure to comply with this obligation always constitutes a violation of the duty of loyalty and is especially serious when it affects confidential information.
 

For these purposes, information that is expressly classified as such is considered confidential, that which due to its nature, significance or meaning is reasonable to understand as confidential and any other whose disclosure could cause harm to ENERDEALERS. In particular, information relating to clients, shareholders, employees, suppliers, strategic plans, financial, commercial, statistical, legal or similar information must be considered confidential and treated as such. Information relating to third parties of which the affected person has knowledge due to their relationship with ENERDEALERS must also be considered confidential. If in doubt, any information should be considered confidential unless otherwise stated.
 

The duty of secrecy does not affect the information that the affected person must make public or communicate to third parties in compliance with a legal or contractual obligation or in the performance of the functions of their position. In the event of termination of their relationship with ENERDEALERS, the affected person, without prejudice to continuing to be bound by the duty to maintain confidentiality, must return the reports, data, documents, computer files and supports of all types that are in their possession for reasons of their position or their activity at ENERDEALERS regardless of whether the information they contain is confidential or not.
 

All employees and directors of ENERDEALERS must acquire the commitment to preserve the confidentiality of the information by signing the clause established for this purpose. Anyone who has knowledge or reasonable indications that improper use of confidential information is taking place or is at risk of taking place must notify their line manager or the Ethics Committee.

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Personal data protection

ENERDEALERS complies with current legislation on data protection in each of the countries where it carries out its activity, and has established procedures and measures to protect confidentiality and guarantee the correct use of information relating to identified or identifiable natural persons (name , surnames, age, health data, image, sound, economic data, etc.).

4.6. Brand, Image and Corporate Reputation
 

Among the intangible assets of the company, the brand, image and corporate reputation occupy a prominent place. Being aware of this, all professionals who work for ENERDEALERS must avoid any conduct that may cause damage to the company's image and, consequently, refrain from using its name, brand or distinctive signs for purposes other than those authorized by the company. or allow, as a result of an action carried out in a personal capacity or without proper authorization, the reputation of ENERDEALERS to be damaged or undermined.

Employees and managers must have express authorization to intervene on behalf of ENERDEALERS or participate due to their position or relationship with ENERDEALERS in any public forum or medium (media, social networks, professional conferences, seminars and any other event that may arise). have public dissemination).

Action on social networks must be carried out through procedures that ensure adequate security measures. Registration, registration, participation or collaboration in social networks, forums or blogs on the Internet and the opinions or statements made in these media will be carried out in a way that makes it clear that they are made on an exclusively personal basis. Under no circumstances will the image, name or brands of ENERDEALERS be used.

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4.7. Intellectual and Industrial Property

The professionals who work for ENERDEALERS must respect the intellectual property and the rights or licenses of use held by the company in relation to courses, projects, computer programs and systems, manuals, videos, knowledge, processes and, in general, any work or work created or developed at ENERDEALERS, whether as a consequence of its professional activity or that of third parties, limiting its use solely and exclusively to the exercise of said professional activity.

Likewise, they will respect the intellectual and industrial property rights held by any foreign third parties. In particular, they will not use in ENERDEALERS any program, manual, documentation or information of any kind belonging to third parties without proper authorization.

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5. RULES OF CONDUCT IN RELATIONSHIPS WITH AND BETWEEN EMPLOYEES

5.1. Respect for people
 

Respect for others, the basis of understanding between human beings, must characterize the conduct of employees and managers. All of them are obliged to treat colleagues, superiors and subordinates respectfully, and must contribute to creating a work environment in which cordiality and collaboration prevail and in which intimidation or attitudes of arrogance have no place in any way.
ENERDEALERS will ensure respect for people, prohibiting any violent or offensive behavior towards the rights and dignity of people or that involves harassment, abuse of authority, intimidation or lack of respect and consideration.

5.2. Equal opportunities and non-discrimination
 

ENERDEALERS assumes the commitment to establish the precise mechanisms so that no type of discrimination occurs due to sex, race, ideology, religion, sexual orientation, age, nationality, disability, culture, due to union membership or affiliation, due to having the status as legal representative of the workers or by any other personal, physical or social characteristic.

In particular, those involved in hiring, selection or professional promotion processes must act objectively and base their decisions exclusively on the professional value and performance of the person being evaluated, avoiding behavior conditioned by prejudice or that implies discrimination or favoritism.

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5.3. Work-life balance

ENERDEALERS believes that an active and structured policy on equality and conciliation favors productivity and facilitates balance between the work environment and the personal and family life of all workers.

To this end, he declares his commitment to promoting initiatives that, in the development of this policy, represent effective progress. All employees and, especially those who perform management functions, must ensure that the people in their teams can enjoy without restrictions the conciliation measures established in ENERDEALERS.
 

5.4. Commitment and cooperation at work, efficiency and professional development
 

ENERDEALERS aspires for all employees to know and share the company's strategic objectives and to actively collaborate in their achievement. To achieve this objective, employees and managers must receive general information about the company's strategic plans, and, in particular, about the initiatives that most directly affect the tasks they perform.
ENERDEALERS must provide the necessary means for the proper performance of tasks and for the achievement of the professional goals of those who are part of the company, and employees and managers must use these means efficiently with a spirit of collaboration and a sense of responsibility.

ENERDEALERS will promote the training of its employees. The training programs, aimed at facilitating the achievement of their objectives, will contribute to making equal opportunities effective and promote the development of employees' professional careers.
For their part, they must be involved in their professional development, strive to improve their training, constantly updating their knowledge, and contribute to others sharing and benefiting from their training and experience.

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5.5. Health, Wellbeing and Prevention of Occupational Risks

Health and safety, key elements of the well-being of workers and their families, are also essential factors that contribute decisively to improving the productivity, competitiveness and sustainability of the company.

At ENERDEALERS, the health and well-being of employees constitutes a strategic aspect within the Human Resources and Corporate Social Responsibility policies, especially with regard to:

 

• Achieve a healthy and well-being work environment that allows all employees to carry out their work in the best physical, mental and social conditions.

• Achieve an optimal level of occupational safety beyond mere compliance with regulations on occupational risk prevention.

To this end, ENERDEALERS is committed to integrating the prevention of occupational risks and the promotion of health and well-being in all of the company's activities and decisions, at all levels of the organization, and to follow a management model of “ Healthy Company”, in accordance with current international guidelines (European Network for Health Promotion at Work (ENWHP) and WHO), supported by a process of continuous improvement.

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5.6. Resources and means for the development of professional activity

Employees and managers must use the means that the company makes available to them (telephone, computer, email, Internet access, messaging services, etc.) to carry out their professional activities, and refrain from making any use of a nature individual not authorized by the company.

Likewise, they must make appropriate use of ENERDEALERS' property and assets, preserve their integrity and prevent them from suffering damage or deterioration due to causes other than ordinary wear and tear.
Travel, representation, training, use of a private vehicle and travel expenses, as well as the use of corporate credit cards, must comply with the criteria and guidelines established in the company's expense rules.
 

Unless expressly authorized, the use of ENERDEALERS facilities, resources and means is not permitted to carry out activities, paid or unpaid, that are not directly or indirectly related to the business of ENERDEALERS or the work activity of its employees.
 

Computer applications and resources must be used in accordance with safety and efficiency criteria, excluding any inappropriate, illicit or contrary use to the company's rules and instructions. Users must act with full responsibility being aware that these resources are not made available for non-professional uses, they should not be used for private communications, and that their content may be inspected or monitored by ENERDEALERS in the provided performance of its control functions, the exercise of which must not be hindered or limited by invoking expectations or rights to privacy.

If the indicated means and resources allow access to third-party computer systems, said access will be limited to what is strictly necessary for the development of the professional activity, and will be carried out by adopting the necessary security measures to avoid any damage or deterioration of the systems. as well as the deletion, alteration or suppression without proper authorization of the data, information or documents contained therein.

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6. RULES OF CONDUCT IN RELATIONSHIPS WITH THIRD PARTIES

6.1. Relationships with customers

ENERDEALERS is constantly concerned with improving the offer and quality of its products and services, as well as establishing relationships of trust and mutual respect with customers.

All people who work for ENERDEALERS must make it a priority to ensure that, in everything that depends on them, clients receive attentive and careful treatment and a service of the highest quality that is characterized by efficiency, promptness and rigor in compliance with the commitments acquired and the obligations arising from the signed contracts.

Excellence in service requires a constant effort to serve and understand the customer, anticipate their needs and try to satisfy them, offering them, with clear and truthful information, the products and services that are most beneficial and best suited to their needs.
Commercial practices that involve providing incomplete, ambiguous or misleading information or that, by action or omission, may mislead the customer regarding the characteristics of the products or their suitability, will be avoided.

It is contrary to ENERDEALERS policy to carry out advertising activities or use marketing methods that omit relevant information for the client or that, for any other reason, could be considered misleading. The people involved in the commercial function will under no circumstances put their interests before those of the company and the client.

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6.2. Information to shareholders

ENERDEALERS will carry out a communication practice with partners and shareholders based on the following principles:
 

• Strict compliance, in a timely manner, with the legally established communication and information obligations, as well as the corporate governance recommendations in this matter.

• Veracity and transparency of the information communicated.

• Provision of appropriate communication channels for shareholders to exercise their right to information.

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6.3. Relations with suppliers and collaborating companies

ENERDEALERS proposes that suppliers and external collaborators, to the extent that they have a continuous and close relationship with the company, maintain principles and policies of action essentially analogous to those established in the Code, and will refuse to interact, even occasionally. , with those whose conduct is incompatible with those principles.

Employees and managers who participate in supplier and collaborating company selection processes must:

 

• Rigorously apply the procedures and rules established in the purchasing regulations, especially keeping in mind that the selection and contracting of products or services must be carried out through an equitable procedure and in accordance with objective technical, professional and economic criteria.

• Refuse and, under no circumstances, request incentives, commissions, gratuities, favors or advantages and avoid any behavior that may be considered inappropriate or illicit. Suppliers and collaborating companies may confidentially contact the Ethics Committee when they understand that the practices of ENERDEALERS employees do not comply with the provisions of this Code.

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6.4. Relations with competitors

The company and its employees must make every effort not to engage in any illegal or unfair competitive conduct or that breaches antitrust legislation. In relations with competing companies, any conversation, understanding or agreement that is related to services, products, prices, clients or markets must be avoided and action must always be taken in accordance with the internal regulations on the matter and with the instructions of ENERDEALERS.

Within the framework of the duties of loyalty that must govern relations with competitors, any action or commercial or advertising practice that is misleading, aggressive or denigratory of the competition and any action that is contrary to good faith or that, for any reason, is expressly prohibited. other cause, may be considered unfair or illicit.
 

6.5. Relations with governments and authorities

ENERDEALERS carries out its business activities with full respect for current regulations, regulatory bodies and all the authorities of the countries in which it operates, remaining neutral with respect to the different political options.

ENERDEALERS does not make any type of contribution in favor of political campaigns nor does it finance or make donations to political parties or their representatives or candidates. Employees who, in the exercise of their rights, participate in political activities will always do so in a strictly personal capacity and will prevent their activities in that field from being attributed to or associated with ENERDEALERS.

In order to be able to determine the existence of possible incompatibilities, ENERDEALERS employees will inform their hierarchical superiors of their acceptance of any public or political position.

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6.6. Relations with partners

ENERDEALERS' relationships with its partners must be based on the loyalty and integrity of their respective practices, transparency in information, the spirit of collaboration and obtaining mutual benefit.

Consequently, ENERDEALERS employees must act towards partners respecting these principles of respect, favorable environment and teamwork.
 

ENERDEALERS will promote among its partners knowledge of this ethical and conduct standard and the adoption of guidelines consistent with it.

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6.7. Gifts, attention and presents

The employees and directors of ENERDEALERS may not, in their capacity as such or by reason of their professional activity, request or accept, either directly or indirectly, gifts, commissions, discounts, invitations or other types of advantages or favors from suppliers, clients or of any person or entity related or seeking to relate to ENERDEALERS.

Without prejudice to the generality of the above, hospitality or gifts of mere courtesy or of symbolic or reduced value may be accepted that simultaneously meet the following requirements:
 

• They are not contrary to the principles of ethical action and transparency adopted by ENERDEALERS.

• Do not harm the image or reputation of ENERDEALERS.

• They are permitted both by the applicable legislation and internal regulations of each country and by local uses and customs.

• They do not consist of amounts of money or securities and goods easily settled in cash.

• They are delivered or received in a transparent manner and on an occasional basis, by virtue of a commercial practice or generally accepted social courtesy, or consist of objects or hospitality with a symbolic or economically irrelevant value and, in any case, less than 150 euros ( or its equivalent in the applicable currency) or to the specific amount established, where applicable, in relation to a specific country, limits applicable to six-month periods and in relation to each supplier, client or related person or entity.

If an employee receives a gift that exceeds the established maximum amount, he or she must inform his or her superior, who will decide if it should be returned or, if applicable, the destination that should be given to it.
 

If you are in doubt about whether it is appropriate to accept a gift or an invitation, you should explain the situation to your superior and act in accordance with his or her instructions. If it is not possible to do so, or the person responsible also has doubts, the case may be raised before the Ethics Committee.
 

Gifts made in the name of ENERDEALERS are characterized by being intended to promote the company's brand image and will be made solely and exclusively by employees expressly authorized to do so under the conditions established in the Expense Standard.

Therefore, and outside the provisions of the aforementioned rule, in the scope of their professional activity, employees may not offer, directly or indirectly, gifts, services or any other kind of favor to clients, suppliers, partners or any other person. person or entity that maintains or may maintain relations with the company.

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6.8. Conflicts of interest

Conflicts of interest appear when the personal interests of employees or people linked to them, directly or indirectly, are contrary to or collide with the interests of ENERDEALERS, interfere with the proper fulfillment of their professional duties and responsibilities or

 

They involve them in a personal capacity in some transaction or economic operation of the company.
 

ENERDEALERS employees must act loyally in defense of the company's interests and refrain from participating in any professional or personal activity that could give rise to a conflict of interest with their work at ENERDEALERS.
In particular, they will not participate in or influence the procedures for contracting products or services with companies or people with whom they have any personal or economic relationship, nor will they give special treatment or working conditions to people with whom they have that relationship.
 

Likewise, they will refrain from representing the company or from intervening or influencing decision-making on matters in which, directly or indirectly, they themselves, or people linked to them, have a personal interest or economic link.
 

Related persons are those who have that status by virtue of the legal provisions applicable to the corresponding conflict situation. Likewise, the spouse or persons with a similar emotional relationship, the ascendants, descendants and siblings of the employee and his or her spouse or person with a similar emotional relationship, the spouses of the employee's ascendants, descendants and siblings will also be considered related persons. and companies controlled, directly or indirectly, by the employee or person related to him, by himself or through an intermediary, or in which the employee or person related to him holds an administrative or management position or receives emoluments of any type.
 

Employees who may be affected by a conflict of interest will communicate it, prior to any decision-making on the matter in question, to the Management of their company through their hierarchical superior, so that the necessary measures can be adopted. to prevent its impartiality from being compromised.
 

The employee must refrain from taking any action in this regard until they have obtained the corresponding response to their query.

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6.9. Anti-corruption and bribery

Corruption and bribery appear when employees use unethical practices to obtain some benefit or advantage for the company, for themselves or for third parties.

ENERDEALERS is against unethical practices aimed at inappropriately influencing the actions and will of people to obtain advantages or benefits. Nor does it allow other people or entities to use these practices with their employees.
 

ENERDEALERS' corruption prevention policy establishes the basic rules and framework to prevent and detect corrupt practices in operations related to the company's activities.
 

Employees may not request or accept nor promise, offer or give, directly or indirectly, gifts, payments, invitations, commissions, compensation, favors or advantages, of any kind to obtain compensation or to attempt to inappropriately influence their employees. commercial or professional relationships with public or private entities, public officials, employees, directors or administrators of companies or public organizations or private companies, organizations and political parties, politicians or candidates for public office.
In the case of courtesy gifts, the provisions of section 6.7 will apply. of this Code and in the internal regulations on the matter.
 

Employees must inform the company, through their superior or the Ethics Committee, of any case of corruption or attempted corruption that they are aware of or about which they have any reasonable indication.

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6.10. Information transparency

The trust placed in ENERDEALERS by the different interest groups is based on the transparent, truthful and complete information that the company provides in all areas of its activity.
 

All employees must ensure that the information they provide, both internally and externally, is accurate, clear and truthful, and in no case will they knowingly provide incorrect, incomplete, inaccurate or information that may mislead the recipient.
All information, financial or not, that is communicated to the shareholders, to the markets in which ENERDEALERS shares are listed, to the regulatory entities of said markets and to the Public Administrations, will be truthful and complete and communicated within the deadlines and others. requirements established in the applicable standards and general principles of market functioning and good governance that ENERDEALERS has assumed.
 

In particular, the application for any subsidies, aid or funds from the Public Administrations will be processed with application of the indicated principles of truthfulness and transparency regarding compliance with the conditions required for its granting and with strict application of the amounts received in such concept. to the purposes or activities for which the subsidy, aid or funds have been granted.
This principle of transparency and truthfulness of information will also apply to internal communication. Employees who enter any type of information into ENERDEALERS' computer systems must ensure that it is rigorous and reliable.
 

In particular, all economic transactions of ENERDEALERS must be reflected clearly and precisely in the corresponding records, systems and/or files, ensuring adequate custody and conservation of the information within the deadlines provided by law.
In particular, the annual accounts will faithfully reflect the economic, financial and equity reality of the entity to which they refer in accordance with generally accepted accounting principles and international financial reporting standards that are applicable and will be available to internal auditors and external to the entity.

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6.11. Prevention of money laundering and terrorist financing

ENERDEALERS has established appropriate policies, procedures and internal control bodies to prevent and avoid operations related to money laundering or the financing of terrorism that all ENERDEALERS employees must know and apply.

The aforementioned policies and procedures establish specific controls over those operations that are complex or of an unusual nature or amount, or that have no apparent economic or legal purpose or that present signs of simulation or fraud. For example, and among many others, those made in cash or with bearer checks, or through banking entities domiciled in tax havens or non-cooperative territories, by third parties unrelated to the contract or in which it is not possible to identify the owners.
 

All ENERDEALERS employees bound by the regulations on the prevention of money laundering and terrorist financing will receive specific training on the subject (with different degrees of depth depending on the level of risk in the matter of the activities they carry out), with detail how to proceed in the event of detecting any suspicious operation.
 

In the event that it is detected or suspected or doubted that an operation may cover up or be used as a means of money laundering or terrorist financing, they must inform their hierarchical superior.

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7. COMPLIANCE WITH THE CODE OF ETHICS AND CONDUCT

The principles and criteria of action contained in this Code of Ethics and Conduct are mandatory for all people subject to its scope of action.

To guarantee its application as well as the supervision and control of its compliance at ENERDEALERS, an ETHICS COMMITTEE has been established, with the following powers, composition, and operating regime:
 

Composition
 

The Ethics Committee is made up of a minimum of three members and a maximum of five. It will be chaired by the Senior Management Officer, the General Director of People and two employees, as well as a legal expert who will act as Secretary.
 

Competencies

The main functions of the Ethics Committee are:

 

• Advisory: resolve queries and doubts that arise in the interpretation and application of the Code; advise on how to act to address and resolve specific situations; Ensure that employees and third parties can, in good faith, inform the Committee of possible violations of its content confidentially and without fear of any retaliation.

• Resolutive: analyze and resolve complaints for non-compliance with the Code of Ethics and Conduct, and communicate, where appropriate, to the Human Resources Department the violations of the Code that may give rise to the adoption of measures in its area of ​​competence.

• Surveillance: ensure compliance with the Code of Ethics and Conduct, establish control mechanisms, and actions that promote compliance and propose updating its content to adjust it to the changes that occur in the company, the market, society and the legislation.

• Promotion: disseminate and promote among all people subject to the Code of Ethics and Conduct the values and standards of action established therein.

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Operating regime

Queries and complaints may be made through any of the following communication channels:

Through this form: