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2021 INTEGRATED MANAGEMENT REPORT

The 'Code of Ethics and Conduct' is our professional touchstone, reflecting applicable best practices and Cepsa s values. It sets out the basic principles, ethical commitments and behaviours expected of our professionals. All employees must be familiar with the content of the code, so the company ensures continuous training and awareness-raising. We also recommend our professionals to adhere to it as an example of commitment, acceptance having reached a very high level.

We extend this commitment to our partners and collaborators by asking them to adhere to both our 'Code of Ethics and Conduct' and our 'Supplier Code of Ethics and Conduct'.

ETHICS AND COMPLIANCE CHANNEL

Cepsa has an Ethics and Compliance Channel in which any employee or third party can report behaviour that is irregular or conflicts with the Code of Ethics and Conduct, current legislation or Cepsa's internal regulations. This channel is accessed via a form on Cepsa s corporate website and over the telephone. It is managed by an independent company and available in multiple languages, 24 hours a day, 365 days a year.

The channel is managed by the Ethics and Compliance Office, which reports functionally to the Audit, Compliance, Ethics and Risk Committee. All stakeholders with whom we have a contractual or commercial relationship are informed and trained to use this channel.

All comments received are treated confidentially and can be made anonymously. The Ethics and Compliance Channel policy in- cludes a processing procedure. Cepsa has zero tolerance for retaliation against whistleblowers and establishes the appropriate protection measures for each case in accordance with legislation on the protection of whistleblowers reporting corruption and in line with Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law.

3.8.1 Day-to-day ethics

UPDATING THE CODE OF ETHICS AND CONDUCT

The 'Code of Ethics and Conduct' is regularly updated and reviewed to reflect changes in society and the company. This year we have brought in the following new features to align the code with our ESG commitments and the 2030 Agenda Sustainable Development Goals:

The concept of "energy transition and the reaffirmation of our commitment to ESG issues.

Stronger condemnation of harassment and our commitment to diversity and inclusion.

Introduction of the concept of "digital disconnection .

Content on artificial intelligence technology.

More rigorous information management.

We have also updated the 'Supplier Code of Ethics and Conduct', which aims to set minimum expectations for supplier conduct.