2024 MILESTONES

Compliance

Aciturri is strongly committed to the highest standards of integrity, ethics, and compliance in its corporate strategies and management processes.

To ensure compliance with these standards, the company has implemented a comprehensive, structured, robust, and effective Ethics and Compliance Management System (SGEC) that is continuously reviewed. The SGEC aims to integrate ethics and compliance into the organization's management processes to ensure compliance with applicable legal (hard law) and voluntary (soft law) obligations, detect and prevent risks of noncompliance, and take appropriate corrective measures. Aciturri takes action against any act, attitude, or behavior that violates its fundamental ethical values and principles, regardless of whether it constitutes a crime.

Aciturri's E&C Management System is based on international norms and standards: ISO 19600, ISO 37001, and UNE 19601, as well as their developments. It includes all companies located in Spain within its scope of action.

In 2024, Aciturri and Alestis integrated their Ethics and Compliance Management Systems, which involved reviewing many Policies, Procedures, and Guidelines and adapting the wording where necessary.

This integration covers the following documents:

Aciturri's E&C Management System is based on international norms and standards: ISO 19600, ISO 37001, and UNE 19601, as well as their developments. It includes all companies located in Spain within its scope of action.

E&C Policy

A fundamental element of the SGEC. Initially approved in June 2017, it has since been amended. The current version was approved by the Aciturri Aeronáutica Board of Directors on June 26, 2024. The policy details the essential principles of the SGEC, as well as the values enshrined in the organization's Code of Ethics.
Code of Ethics and Conduct

With new wording (Initial Edition, June 2017). It was approved by the Aciturri Aeronáutica Board of Directors on June 26, 2024. From a formal standpoint, it is a set of binding rules governing the conduct expected of all company members, establishing an ethical framework of reference. The Code of Ethics and Conduct is accessible internally on the intranet and externally on the website . All members of the governing bodies were personally notified at the time of its approval and undertook to comply with it in writing.
Supplier Code of Conduct

Also with new wording (initial version from 2022). It was approved by the Executive Committee of Aciturri Aeronáutica on September 8, 2024. This code establishes the minimum standards of conduct that Aciturri expects from all members of its value chain.
Anti-Corruption Sub-Policy

With new wording. Approved by the Aciturri Aeronáutica Board of Directors on June 26, 2024.
Human Rights Sub-Policy

Formalized in 2020 and based on the International Bill of Human Rights, the fundamental conventions of the International Labor Organization, the United Nations Global Compact, and the European Convention on Human Rights (HR). Revised to extend its scope of application. Approved by the Chief Compliance Officer on July 8, 2024. The sub-policy includes Aciturri's commitment to respecting human rights in its own activities and throughout the value chain.
Sub-Policy on Conflict Minerals

Extension of scope. Approved by the Chief Compliance Officer on July 8, 2024. This sub-policy strengthens the due diligence process to contribute to the responsible global management of supply chains, especially with regard to minerals and metals from regions frequently affected by armed conflict and/or widespread and systematic violations of international law. External access
The E&C Channel Sub-Policy

Establishes the general principles and premises governing Aciturri's E&C Channel in accordance with the "Internal Information System" legislation. In the version resulting from the integration, its scope has been extended to apply to the aforementioned Aciturri companies. Approved by the Aciturri Aeronáutica Board of Directors on June 26, 2024.
The Export Control Sub-Policy

Formalizes Aciturri's commitment to complying with foreign trade regulations in the broadest sense. In the version resulting from the integration, its scope of application has been extended. Approved by the Board of Directors on April 24, 2024.
The Privacy and Personal Data Protection Sub-Policy

Provides a minimum and consistent standard of conduct that must govern Aciturri in matters of personal data protection. Following integration, its scope of application has been extended to adapt to new circumstances. Approved by the Chief Compliance Officer on July 8, 2024.
The Gifts and Hospitality Guide

Establishes the general principles and guidelines that Aciturri members must follow when receiving or offering gifts or hospitality from or to third parties. Following integration, it is applicable to the aforementioned companies. Approved by the Chief Compliance Officer on September 26, 2024.
The On-Site Service Provision Procedure/Guide

Defines the basic rules governing the contracting and subsequent management of services provided by suppliers on an on-site basis at Aciturri's facilities. The revision, approved by the Chief Compliance Officer on September 26, 2024, extends the scope of the document.
Donations and Sponsorship Procedure

This procedure defines the criteria and principles governing donations and sponsorships at Aciturri, as well as the process for implementing them. This revision extends its scope and adapts its content. Approved by the Chief Compliance Officer on September 23, 2024.

E&C Policy

A fundamental element of the SGEC. Initially approved in June 2017, it has since been amended. The current version was approved by the Aciturri Aeronáutica Board of Directors on June 26, 2024. The policy details the essential principles of the SGEC, as well as the values enshrined in the organization's Code of Ethics.
Code of Ethics and Conduct

With new wording (Initial Edition, June 2017). It was approved by the Aciturri Aeronáutica Board of Directors on June 26, 2024. From a formal standpoint, it is a set of binding rules governing the conduct expected of all company members, establishing an ethical framework of reference. The Code of Ethics and Conduct is accessible internally on the intranet and externally on the website . All members of the governing bodies were personally notified at the time of its approval and undertook to comply with it in writing.
Supplier Code of Conduct

Also with new wording (initial version from 2022). It was approved by the Executive Committee of Aciturri Aeronáutica on September 8, 2024. This code establishes the minimum standards of conduct that Aciturri expects from all members of its value chain.
Anti-Corruption Sub-Policy

With new wording. Approved by the Aciturri Aeronáutica Board of Directors on June 26, 2024.
Human Rights Sub-Policy

Formalized in 2020 and based on the International Bill of Human Rights, the fundamental conventions of the International Labor Organization, the United Nations Global Compact, and the European Convention on Human Rights (HR). Revised to extend its scope of application. Approved by the Chief Compliance Officer on July 8, 2024. The sub-policy includes Aciturri's commitment to respecting human rights in its own activities and throughout the value chain.
Sub-Policy on Conflict Minerals

Extension of scope. Approved by the Chief Compliance Officer on July 8, 2024. This sub-policy strengthens the due diligence process to contribute to the responsible global management of supply chains, especially with regard to minerals and metals from regions frequently affected by armed conflict and/or widespread and systematic violations of international law. External access
The E&C Channel Sub-Policy

Establishes the general principles and premises governing Aciturri's E&C Channel in accordance with the "Internal Information System" legislation. In the version resulting from the integration, its scope has been extended to apply to the aforementioned Aciturri companies. Approved by the Aciturri Aeronáutica Board of Directors on June 26, 2024.
The Export Control Sub-Policy

Formalizes Aciturri's commitment to complying with foreign trade regulations in the broadest sense. In the version resulting from the integration, its scope of application has been extended. Approved by the Board of Directors on April 24, 2024.
The Privacy and Personal Data Protection Sub-Policy

Provides a minimum and consistent standard of conduct that must govern Aciturri in matters of personal data protection. Following integration, its scope of application has been extended to adapt to new circumstances. Approved by the Chief Compliance Officer on July 8, 2024.
The Gifts and Hospitality Guide

Establishes the general principles and guidelines that Aciturri members must follow when receiving or offering gifts or hospitality from or to third parties. Following integration, it is applicable to the aforementioned companies. Approved by the Chief Compliance Officer on September 26, 2024.
The On-Site Service Provision Procedure/Guide

Defines the basic rules governing the contracting and subsequent management of services provided by suppliers on an on-site basis at Aciturri's facilities. The revision, approved by the Chief Compliance Officer on September 26, 2024, extends the scope of the document.
Donations and Sponsorship Procedure

This procedure defines the criteria and principles governing donations and sponsorships at Aciturri, as well as the process for implementing them. This revision extends its scope and adapts its content. Approved by the Chief Compliance Officer on September 23, 2024.

New for 2024 is the Sub-Policy on Ethics in Artificial Intelligence, which applies to all Aciturri-linked companies.

At the Brazilian headquarters there are different versions of some of these documents in force, due to regulatory differences.

New for 2024 is the Sub-Policy on Ethics in Artificial Intelligence, which applies to all Aciturri-linked companies. Approved by the Aciturri Aeronáutica Board of Directors on June 26, 2024, it is based on the Artificial Intelligence Regulations. Recognizing the advancement of AI in all areas, including the professional sphere, the Sub-Policy aims to establish the foundation for using and developing tools that incorporate AI at Aciturri. The policy has been made public internally through the corporate communication portal (SAP Jam).

The SGEC also includes a Crime Prevention Model, which was approved in its initial version in 2017. It is designed to establish appropriate monitoring and control measures to prevent the commission of crimes and significantly reduce the risk of their occurrence. The model is based on the principle that "no benefit or advantage to the organization justifies the commission of acts classified as criminal by the criminal justice system," i.e., a "zero tolerance" policy towards criminal acts.

Due to changes in the company's internal and external context, new legislation, processes, and controls, the Crime Prevention Manual was revised in 2024. The manual is therefore fully adapted to the new circumstances, thus maintaining its effectiveness and robustness.

In addition, in line with the methodology used in previous financial years, the annual review of the criminal risk analysis, which is part of the aforementioned crime prevention model, has been carried out. The analysis examined all Aciturri companies in Spain within the scope of the SGEC and all Aciturri business areas, representing 100% of operations. In addition to assessing criminal risks, the analysis incorporates specific issues regarding the robustness of Aciturri's internal controls to mitigate these risks. The analysis's conclusions are documented and signed by the Chief Compliance Officer, in compliance with Article 31 bis 5.6 of the Criminal Code's regulatory mandate.

Due to changes in the company's internal and external context, new legislation, processes, and controls, the Crime Prevention Manual was revised in 2024. The manual is therefore fully adapted to the new circumstances, thus maintaining its effectiveness and robustness.

Progress in the regulatory development of the compliance area, ordinary management actions carried out during the year, training provided, and strategic objectives established are reported periodically to the Ethics and Compliance Committee and the board of directors. This closes the vertical involvement of the organization and facilitates proper coordination and alignment of principles through the well-known "tone from the top."

To ensure proper control in Brazil, a Compliance function representative has been appointed for this purpose (known internally as the BCR, or Business Compliance Representative). This representative is responsible for coordinating and ensuring the implementation of company policies.

As mentioned above, Aciturri has an Anti-Corruption Sub-Policy which reaffirms and reinforces the requirement of honesty, integrity, and transparency as essential principles of conduct when performing its activities. These standards apply both internally and to any business partner and are based on a commitment to strict compliance with the principle of "zero tolerance" toward any practice that could be classified as corruption or bribery, understood in the broadest sense.

Within this framework, Aciturri continues to reinforce the requirement for integrity in the supply chain by ensuring that third parties have a culture of regulatory compliance. Aciturri achieves this by including specific contractual clauses in commercial contracts that require business partners to implement management systems based on principles and a framework of ethics and compliance similar to those advocated by Aciturri. These clauses also provide for the termination of the contract in the event of a breach of any of the established obligations.

To strengthen due diligence in the supply chain, Aciturri has a Code of Conduct for Suppliers. Compliance with the Code is contractually required through its incorporation as an annex. Additionally, communication and enforcement of compliance have been strengthened in 2024 with a mass rollout to all suppliers in the supply chain through the document management platform.

The due diligence process is completed by the Sub-Policy on Purchasing and Subcontracting for Suppliers, which contains the principles required of all suppliers and details the conditions and requirements imposed by local, national, and international regulations, as well as those that the company assumes and incorporates as a requirement for maintaining a business relationship.

In accordance with the provisions of Article 2 of Law 10/2010 of April 28 on the prevention of money laundering and terrorist financing, Aciturri is not subject to money laundering prevention obligations. However, Aciturri demonstrates its commitment to regulatory compliance by maintaining measures such as the following:

Require identification from anyone who wishes to establish a relationship with the organization by providing the relevant documentation.

Not accepting or making cash payments.

Refusing to use or possess goods originating from criminal activity.

Controlling so-called "triangular transactions" when a customer or supplier informs us that an invoice will be paid by a third party.

Daily recording and justification of all company expenses and payments, as well as reporting of suspicious transactions to the Ethics and Compliance Department.

Identification and recording of all financial transfers in the accounting books.

Verify the beneficial owner in cases where there are indications that the entity wishing to contract with the organization is involved in money laundering operations.

The company has an Internal Information System that not only complies with the requirements of Law 2/2023, which regulates the protection of persons who report regulatory violations and fight corruption, but also exceeds them. For example, it addresses not only breaches of the mandatory rules set out in the aforementioned law but also any rule that could undermine Aciturri's general principles of conduct, internal rules, and procedures, thus ensuring a strict framework of ethics and compliance.

Known internally as the E&C Channel, this system has several communication channels, including the digital platform. It is accessible 24/7. Hosted on external servers, it allows any employee or third party to communicate directly and confidentially with the Ethics and Compliance department.

The rights and guarantees of those who use the E&C Channel, as well as its operating principles, are regulated in the E&C Channel Regulations. The regulations contain the E&C Channel sub-policy, the channel's organizational procedure and principles, the procedure for handling inquiries and reports, and the non-retaliation protocol. The competent authority has also been notified of the appointment of a Channel Manager.

During 2024, 125 inquiries were received (50 fewer than in 2023), as well as seven suspected reports (seven fewer than in 2023). Most of the inquiries were about privacy and personal data protection, video surveillance, export control, and managed donations and sponsorships.

All suspected cases were analyzed and closed after the possibility of a crime was ruled out. Following their resolution, it can be stated that:

No disciplinary proceedings have been initiated in any of the cases.

No complaints have been received regarding any kind of corruption (e.g., bribery, influence peddling, money laundering).

No complaints have been received regarding human rights, including conflict minerals.

None of the complaints fall within a category that could result in criminal liability for the company.

Finally, in terms of training, various initiatives have been carried out in 2024:

Internal Knowledge Sharing Session, open to all staff, in which the content of the Code of Ethics and Conduct, the E&C Channel and the main Aciturri Guidelines were presented in detail, with a total of 103 participants.

Session at the Brazil headquarters on general E&C and data protection aimed at the management team.

Intra-departmental training on E&C, covering all the main aspects of the Management System, with 3 participants.

Several training sessions on privacy and personal data protection in video surveillance at Aciturri's various production plants, aimed at a total of 30 people.

Training on the Crime Prevention Model, attended by 182 people (1,552 people trained since its launch).

Training on confidentiality, information protection, and personal data protection, aimed at 12 people.

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