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Legal

The backbone of the ECMS continues to be the Code of Ethics and Conduct, a binding document that sets forth the values, principles, and rules of conduct that Aciturri expects of all its members.

The backbone of the ECMS continues to be the Code of Ethics and Conduct, a binding document that sets forth the values, principles, and rules of conduct that Aciturri expects of all its members.

The Company prepared Aciturri’s Responsible Advertising Policy, which was approved in 2012 by the CEO and covers matters relating to the commitment to respect legality, good faith, non-incitement to violence, illegal conduct or discrimination, and respect for good taste, the environment and truthfulness. It applies to all stakeholders, with particular attention to customers.

There is no record of any breach of this policy, nor of any regulation related to marketing communications during the 2025 fiscal year.

In 2025, at least one legal action related to the authorization request submitted by the Belgian company Sonaca S.A. to the European Commission for the acquisition of Aciturri Aeronáutica's control and shareholding was carried out. It should be noted, however, that this was a request for approval, not an investigation or infringement. In the first half of 2025, the European Commission authorized Sonaca S.A.'s acquisition of joint control over Aciturri.

There were also no legal actions or investigations relating to unfair competition or monopolistic practices during 2025.

As part of crime prevention efforts, the annual review of the criminal risk analysis has been conducted for 100% of the companies’ operations within the scope of the ECMS under the Spanish regulatory framework.

As part of crime prevention efforts, the annual review of the criminal risk analysis has been conducted for 100% of the companies’ operations within the scope of the ECMS under the Spanish regulatory framework.

Regarding data privacy, no substantiated claim was identified in 2025. Nor is there any record of any case of leaks, theft or loss of customer data during 2025.

Even so, Aciturri enters into confidentiality agreements with all suppliers or third parties before they may have access to any confidential or sensitive information, in order to comply with confidentiality obligations towards customers and with the intention of protecting its own confidential information (more than one hundred NDAs —Non-Disclosure Agreements— with suppliers and other third parties).

It should also be added that all employment contracts to which the people working at Aciturri are subject include specific clauses relating to confidentiality.

Throughout the 2025 fiscal year, the Company incurred monetary sanctions or surcharges mainly corresponding to late filing of tax forms, primarily in companies located in Spain. The total amount was €235,962.6560.

In the case of Alestis, the total amount was €128,119.05, mainly relating likewise to sanctions or surcharges for late filing with the tax authority.

There is no record of cases that resulted in non-monetary sanctions.

60. This total amount refers to the sanctions or surcharges corresponding to Aciturri Aeronáutica, S.L.U., Aciturri Aerostructures, S.L.U., Aciturri Engineering, S.L.U. and Aciturri Corporate, S.L.U. for the full fiscal year, and to Aciturri Aeroengines, S.L.U. for the period from 1 January to 30 September.

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