Suppliers’ action principles

1. INTRODUCTION

Grupo CACAOLAT, S.L. (hereinafter “the Company“), committed to compliance with the laws in all its areas of activity, has a Code of Conduct which establishes a set of principles and guidelines for conduct aimed at guaranteeing the upright, professional and service-oriented behaviour of all its partners in the performance of their activities and in their relations and interactions with other partners, customers, suppliers, competitors in the market, Public Administrations and the environment in general.

In this regard, the Company is aware of the importance of its suppliers (hereinafter “Supplier” or “Suppliers”) being committed to the principles of integrity, professional competence and dedication to service, as set out herein.

2. PRINCIPLES OF ACTION

2.1 Compliance with the laws in force

The Company conducts its business in strict compliance with the laws in force and observes the rules and principles set out in its Code of Conduct.

Likewise, all Suppliers must undertake to comply with the laws and observe the rules and principles contained in this document.

2.2 Integrity and honesty

The Company does not accept any form of corruption, extortion or misappropriation.

The Company’s Suppliers, in their relation with the Company, shall neither, directly or through a third party, promise, offer or grant, nor request or accept, unreasonable or excessive advantages, gifts or benefits of any kind whatsoever aimed at obtaining an advantage for the Company or themselves.

Bribery, which is expressly prohibited, includes the direct or indirect offer or promise of any kind of improper advantage and any instrument for covering it as well as influence peddling.

Suppliers may not give or accept hospitality that influences, could influence or could be construed as influencing the decision making of the Company‘s partners

2.3 Respect for persons

The Company respects the principles of the Universal Declaration of Human Rights of the United Nations and the declarations of the International Labour Organization, and is committed to non- discrimination on the grounds of race, colour, nationality, social origin, age, sex, marital status, disability, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of its partners, as well as to equal opportunities.

In particular, Suppliers must recognise the rights of their partners and treat them with dignity and respect, committing to:

• Not use or tolerate the use of children, forced, compulsory or undeclared labour;
  • Not implement or tolerate any form of discrimination based on nationality, gender, ethnic and racial origins, religious beliefs, political opinions, age, sexuality, disability or health in recruitment policies;
  • Avoid any kind of discrimination (damage, harassment, mobbing) and facilitate respectful treatment;
  • Reject any act of violence, physical, sexual, psychological, moral or other harassment, abuse of authority at work and any other conduct that intimidates or offends the rights of individuals;
  • Grant workers the right to set up and join employers’ and workers’ trade unions of their choice; and
  • Ensure a safe and healthy working environment and take appropriate measures to prevent any accident or harm to the health of employees.

In this respect, Suppliers are expected, both from their employees and in their relations with the Company, to respect these principles and to take the necessary measures to guarantee and promote them.

2.4 Transparency and impartiality

Suppliers’ selection processes conform to criteria of objectivity and impartiality, avoiding any conflict of interest, influence or bias in their selection.

2.5 Avoidance of conflicts of interest

Relations between the Company and its Suppliers are governed by objective criteria, avoiding any conflict of interest, influence or bias.

Suppliers shall avoid situations that may give rise to a conflict between their personal interests or those of their employees and those of the Company‘s employees.

Suppliers shall not offer any gift, offering, present, benefit or advantage, in cash or in kind, to any employee of the Company.

2.6 Market and Competitors

The Company respects the rules of competition law, promoting fair competition in the market.

The Company undertakes to compete fairly in the markets and not to make misleading or derogatory statements about its competitors or third parties, nor make false or misleading claims on its products or services.

Likewise, Suppliers must respect the rules of competition law and refrain from participating in agreements or any unfair practice that may hinder or prevent the free exercise of competition. Specifically, all Suppliers must avoid participating in price-fixing agreements, agreements to control production or sales quotas and, in general, any unfair practice that affects the exercise of free competition.

2.7 Public Administration

The Company‘s relations with Public Administrations and authorities shall be based on the principle of maximum transparency and prohibit practices that may be considered irregular.

Suppliers must assume this commitment as their own in the exercise of their activity.

2.8 Prevention of money laundering and control of payments

The Company is committed to preventing money laundering and irregularities in payments made by and to third parties, and, particularly, avoiding actions that may be considered irregular in its relations with customers, suppliers, competitors and authorities.

In this regard, the Company expects its Suppliers to take the necessary measures to prevent money laundering and payment irregularities.

2.9 Confidentiality and personal data protection

The Company maintains the confidentiality of information concerning its business relationship with Suppliers. In this sense, any information disclosed by the Company to Suppliers shall be considered confidential and its disclosure to third parties is strictly forbidden.

Grupo CACAOLAT, S.L. undertakes not to disclose any personal data of its Suppliers, except with the consent of the parties and in the event of a statutory obligation or the compliance with a court or administrative order. It also undertakes to comply with the laws on personal data protection in force with regard to security measures.

Likewise, Suppliers are expected to undertake not to disclose personal data of both their employees and the partners with whom they collaborate and to comply with the security measures required by the regulations relating to personal data protection, applicable from time to time.

2.10 Health and Safety

Suppliers must comply with and know health and safety regulations that affect them and those of the Company when accessing its facilities, in order to prevent and minimise occupational risks, and to ensure their own safety and that of any person who may be affected in the course of their activities.

2.11 Environment Protection

The Company carries out its activities with respect and preservation of the environment, complying with the standards established in the applicable environmental regulations and minimising the impact of its activities on the environment.

Likewise, the Company‘s suppliers must comply with the standards established in the applicable environmental regulations and minimise the impact of their activities on the environment.

2.12 Intellectual and Industrial Property

The Company is committed to the protection of its own and third parties’ intellectual and industrial property, including but not limited to patents, trademarks, domain names, copyrights, software and designs.

Likewise, the same commitment to respect the intellectual and industrial property of third parties is expected from Suppliers to avoid infringing their rights, as well as to comply with national and international laws in force with regard to intellectual and industrial property.

2.13 Reporting of incidents

The Company has implemented a communication channel available to all suppliers through which they must report any conduct that may imply the commission of any irregularity or any act contrary to the law or contrary to these principles of conduct in their relations with the Company.

3. SCOPE

This document is mandatory for all of the Company‘s Suppliers and is understood to be without prejudice to any additional obligations that may be established in the laws in force and in the relevant contract with each Supplier.

Suppliers undertake to inform their partners, in general, of the contents of this document.

Failure to comply with any of the obligations undertaken by Suppliers in this document shall be cause for the exclusion of a Supplier from the contracting processes, as well as for the termination of any contractual relationship in force with the Company.