Our Code of Ethics (hereinafter also referred to as the “Code”) describes the values and principles that all employees of MEROIL S.A., hereinafter “MEROIL”, must respect and comply with.

Our Code describes how we act as employees and how we do business.

It is the responsibility of all MEROIL employees to know the content of the Code.

OUR PRINCIPLES

In MEROIL, ethical principles form a significant part of the way we do our work.

In our trade and labour relations:

• We take on our role with interest and responsibility.
• We comply with the applicable laws.
• We avoid conflicts of interest.
• There is no room for discriminatory attitudes for any reason.

Compliance with the laws is an indispensable obligation for MEROIL. All staff affected by the Code must comply with the law in force, avoiding conducts which, although not in breach of legality, are contrary to the values, principles and ethical behaviour laid down in this Code.

AT WORK

People working in MEROIL are one of our basic pillars.

• Place of work:

MEROIL offers its employees a safe and healthy working environment. Each employee is responsible for contributing to this.

• Professional development:

MEROIL promotes the personal and professional development of its employees and ensures the reconciliation of their personal and working life.

We always act in a manner that respects everyone we interact with at work.

• Anti-discrimination:

We ensure that there are no discriminatory attitudes in the working environment based on sex, ethnicity, religion, age or sexual orientation, as well as harassment.

• Safety and health:

We comply with existing occupational safety and health legislation.

• Assets of the company:

All staff affected by this Code are obliged to use the goods made available to them for the purpose of carrying out their professional activities in an appropriate and diligent manner, avoiding any misuse which could cause damage to them.

This applies both to physical assets (such as computers, mobile phones and vehicles) and to intellectual or industrial property.

• Records and books:

All our financial/accounting records are accurate and transactions are recorded transparently in accordance with MEROIL’s accounting practices.

• Privacy:

We guarantee the right to intimacy and privacy of all our employees.

• Social networks:

All employees shall make appropriate use of social media by refraining from disseminating information, making demonstrations, using expressions or displaying images through them which may in any way affect the prestige and reputation of MEROIL, or which may undermine or damage the honour of their professionals or third parties in general.

• Confidentiality and data protection:

Persons covered by this Code shall refrain from disclosing inside information to third parties, including their friends and relatives.

Confidential information is whatever it is not public. We must proactively protect confidential information.

It shall be prohibited to disclose, communicate, reveal or use for our own benefit or otherwise any data or information obtained in the course of our professional activity.

• Travel:

During business trips, we represent MEROIL and therefore we cannot engage in illegal or inappropriate activities that could damage MEROIL’s reputation.

When travelling, we will protect the assets and information of MEROIL in our possession, taking appropriate precautions when working in public areas.

RELATIONS WITH THE MARKET

• Fair competition:

MEROIL shall promote free market and competition between the various operators in the sector as provided for in the applicable legislation by establishing internal controls with the aim of preventing anti-competitive practices.

Violation of antitrust laws and regulations can seriously damage MEROIL’s reputation, lead to substantial fines and lead to civil and criminal liability against the employees involved.

• Products:

MEROIL ensures that the products it supplies meet all the requirements of the legislation on quality, conservation and distribution.

MEROIL has implemented a number of external and internal control procedures, which must be complied with by all employees and constantly updated by those responsible.

• Marketing:

We respect the applicable product regulations and marketing laws.

Our marketing, advertising, sales and promotion activities are honest.

• Conflicts of interest:

Our employees act and make their decisions with the only and best interest of MEROIL.

Any scenario involving a conflict between the responsibilities arising from the work carried out in MEROIL and personal interests must be avoided, and the persons affected by this Code must refrain from intervening in decision-making in situations in which they are directly or indirectly affected.

• Anti-bribery and corruption:

Our employees will not seek or offer any unjustified personal advantage.

• Suppliers:

MEROIL shall engage with suppliers of goods and services in an ethical and lawful manner.

As a sign of their commitment, mechanisms have been put in place to promote objectivity in their selection and are monitored so that they meet the required quality standards.

IN SOCIETY

• Human rights:

We support and respect internationally recognised human rights.

We do not tolerate any form of forced labour.

• Child Labour:

MEROIL does not accept child labour and shares the objective of effectively abolishing child labour, it being understood as work that is dangerous for children’s health, safety or morality, or work that interferes with compulsory education or for which children are simply too young.

MEROIL shall not recruit any child who has not completed the minimum compulsory education and, under no circumstances, any person under the age of 15 as provided for in Convention 138 of the International Labour Organisation (ILO).

• Environment:

MEROIL acts in an environmentally responsible manner at all times and respects the applicable legislation.

• Money laundering:

MEROIL complies with national and international anti-money laundering laws.

Our employees take the necessary measures to assess the integrity of our trading partners and ensure that they are not engaged in unlawful activities.

MONITORING OF THE CODE OF ETHICS

All MEROIL employees are obliged to know, comply and contribute to compliance with the Code.

Any non-compliance with this Code observed shall be reported, subject to confidentiality, to the management of MEROIL.

INFRINGEMENT OR FAILURE TO COMPLY WITH THE CODE

Without prejudice to any other liability that may arise, infringement or failure to comply with the Code shall be penalised in accordance with the collective agreement or labour regulations in force.

ENTRY INTO FORCE AND UPDATE

This MEROIL Code of Ethics enters into force today and shall remain in force until its repeal is approved.

This Code is subject to regular review and update.

1-Introduction

The purpose of this Code of Conduct is to reflect in writing what MEROIL, S.A. expects from you as its supplier as regards compliance in various areas such as commercial practices, conflicts of interest, human rights, labour relations and the environment.

2-Commercial practice: law enforcement

MEROIL Supplier must carry out their commercial activities in compliance with the applicable law.

The Supplier shall ensure that its subcontractors or suppliers also comply with at least the same Laws.

2.1. Competition

MEROIL Supplier must comply with competition and antitrust laws and may not exchange sensitive information with their competitors.

2.2. Conflicts of interest

MEROIL staff acts and takes their business decisions with the only and best interest of MEROIL. Suppliers must inform MEROIL if any employee of our company has any interests that could cause a conflict of interest.

The Supplier should not seek to influence the personal interests of MEROIL staff or any person related thereto.

2.3. Anti-bribery and corruption

The Supplier must comply with all anti-corruption laws applicable in all its commercial activities. MEROIL staff shall not seek or accept from the Supplier, and the Supplier must not offer any unjustified personal advantage.

2.4. Protection of data

The Supplier must comply with all applicable data protection legislation.

3-Protection of trade secrets

The Supplier is obliged to keep all MEROIL’s commercial and business secrets confidential. All information shall be considered confidential, provided that it is designated as such and in respect of which it is presumed not to be in the public domain.

The obligation to maintain confidentiality shall exist both during the term of the contract and after its termination.

4-Labour relations. Social responsibility

MEROIL expects the Supplier to comply with internationally recognised and applicable human rights laws.

4.1. Forced or compulsory labour

The Supplier shall take the necessary steps to ensure that it does not participate in or support the use of forced

work. Any work or service must be offered on a voluntary basis and without coercion under the threat of a penalty. The Supplier must not seize workers’ identity documents.

4.2. Child labour

MEROIL does not accept child labour and shares the objective of effectively abolishing child labour, it being understood as work that is dangerous for children’s health, safety or morality, or work that interferes with compulsory education or for which children are simply too young.

The Supplier shall not recruit any child who has not completed the minimum compulsory education and, under no circumstances, any person under the age of 15 as provided for in Convention 138 of the International Labour Organisation (ILO).

4.3. Fight against discrimination

The Supplier shall respect the principle of equal treatment and equal opportunities in the recruitment and employment of workers.

No worker shall be discriminated against on grounds of sex, religion, age, race, social context, caste, nationality, ethnic origin, membership of a work organisation, illness or disability, sexual orientation and political opinion or any other personal characteristic.

4.4. Safety and health at work

The Supplier shall ensure that workers have a safe and healthy working environment and shall be responsible for taking the necessary precautions and safety measures to prevent accidents, fires and injuries.

5-Environment

MEROIL acts in an environmentally responsible manner at all times and respects the applicable legislation.

MEROIL expects its Suppliers to act in the same way and requires them to implement continuous improvement measures in relation to environmental protection.

6-Failure to comply with this Code

In the event of non-compliance with any of the principles in this Code of Conduct, the Supplier shall immediately take the necessary measures to remedy such situation.

MEROIL reserves the right to terminate its commercial relations held with those suppliers that repeatedly fail to comply with this Code of Conduct.

This Code is subject to regular review and update.