CODE OF ETHICS

The ethical behaviour defines the principles and values to which CARAGUM International® adheres and which must guide each employee in the daily practice of his or her profession. Ethics, respect for the individual, proximity, loyalty, social responsibility, transparency and responsiveness are fundamental values of CARAGUM International® in the conduct of its business.

This Code of Ethics applies to all employees (officers, directors, managers, employees, etc.) as well as to all persons with whom the Company is associated, such as its customers, suppliers, advisors, auditors, consultants, subcontractors, agents and other intermediaries representing the Company.

ANTI-CORRUPTION CODE OF CONDUCT

Corruption is the act of a person invested with a specific function (public or private) soliciting or accepting a gift or an advantage of any kind with a view to performing, or refraining from performing, an act within the scope of his or her functions. A distinction is made between active bribery (offering the gift or advantage to the person in charge of the specific function) and passive bribery (acceptance of the gift or advantage by the person in charge of the specific function).

ENVIRONMENTAL POLICY

CARAGUM International® is aware that respect for the environment is an essential way of governing its business. For this reason, we strive to manage and control the environmental aspects and impacts generated by our company. The executive board is therefore committed, through the following environmental policy, to carry out its activities in two main areas.