Aciturri is committed to the highest standards of professional ethics and integrity in its activities and therefore has a cross-functional Ethics and Compliance Management System (ECMS), aimed at integrating ethics and compliance into its management processes, preventing compliance risks and correcting deviations. Its objective, unchanged since its creation, is to ensure compliance with legal and voluntary obligations (hard law and soft law), prevent compliance risks and establish effective prevention, detection and correction measures.

The design of the ECMS takes ISO 37301 / ISO 19600 and UNE 19601 standards as a reference, reinforcing its professionalization and continuous improvement approach.

The ECMS combines a common corporate structure with specific subsystems in regulated technical areas, such as Environment or Occupational Risk Prevention, managed by their responsible units due to their specialization.

The backbone of the ECMS continues to be the Code of Ethics and Conduct, whose latest update was on 26/06/2024. The Code is a binding document that sets out the values, principles and rules of conduct that Aciturri expects from all its members.

Its principles are developed and supplemented through Policies, including notably the General E&C Policy, Procedures and Guidelines on specific matters, all documents that are also considered mandatory. By way of example: anti-corruption, gifts and hospitality, donations and sponsorships, procurement and subcontracting, privacy, export control, human rights and conflict minerals, among others.

These same standards are required of Aciturri’s supply chain through the Supplier Code of Conduct, which is contractually binding.

The ECMS is complemented by the Crime Prevention Model, documented through the Crime Prevention Manual, which establishes a monitoring and control “subsystem” aimed at preventing the commission of offences, reducing corporate criminal risk and reinforcing the principle of zero tolerance towards any unlawful conduct, regardless of whether it results in a benefit for Aciturri.

Following the intense regulatory work carried out in the previous year, this development was consolidated in the new fiscal year, and reviews of relevant documents were approved, including notably the Crime Prevention Manual.

In addition, as a new internal communication tool, the E&C area developed and implemented the E&C Portal, which acts not only as a document repository for the area’s full body of regulations, but also as an access point to guidelines and forms and to the E&C Channel. The Portal is accessible to all employees, and its official launch and communication took place in May 2025.

With regard to crime prevention, during 2025 the annual review of the criminal risk analysis was carried out on 100% of the operations of the companies within the scope of application of the ECMS under the Spanish regulatory framework. For clarification purposes, Alestis do Brasil is excluded. In this analysis, internal controls, current procedures and existing mitigation measures were assessed. The conclusions are submitted by the CCO to the Board of Directors of the Parent Company, in accordance with Article 31 bis of the Criminal Code.

In matters of such pronounced relevance as corruption, in the broad sense, or Human Rights, following the 2025 analysis of all the aforementioned operations, no significant risks were identified.

Specifically in the field of Anti-Corruption, Aciturri has an Anti-Corruption Sub-Policy approved by the governing body, last updated in 2024, which sets out the principles and standards required internally and externally, including the supply chain, based on the principle of “zero tolerance” towards any practice constituting corruption or bribery in the broadest sense.

In line with strengthening supply chain due diligence, in addition to the Supplier Code of Conduct, in this area Aciturri has the Procurement and Subcontracting Sub-Policy for Suppliers⁶¹, publicly available, which sets out the principles, conditions and requirements arising from local, national and international standards in this field.

Pursuant to Article 2 of Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing, Aciturri is not an obliged entity in relation to money laundering prevention. Nevertheless, its commitment to regulatory compliance is evidenced through the maintenance of prevention measures such as requiring identification of any person wishing to establish a relationship with the Organization, not accepting or making cash payments, and rejecting the use or possession of any asset originating from criminal activity.

Aciturri has an Internal Reporting System (“Whistleblowing Channel”) that complies with all the requirements set forth in Law 2/2023, allowing for the confidential reporting of legal violations and internal regulatory breaches by both employees and third parties with a legitimate interest. Its scope is therefore broader than that provided for in the aforementioned legislation.

In 2025, there was no substantial change in its configuration or regulation (E&C Channel Regulations, which include the Non-Retaliation Protocol).