Code of Ethics

• I. Grupo Lamosa values
• II. Objectives of the code
• III. Scope of the code
• IV. Ethical standards
• V. Code management and enforcement
• Appendix (Letter of Commitment)

• GRUPO LAMOSA VALUES
  The basic values of Grupo Lamosa are the guiding principles that define our daily actions within the organization, bringing congruence to our lives and setting the standards that everyone who works at Grupo Lamosa must follow.
  
  RESPONSIBILITY
  Responsibility is a value that measures the extent to which we fulfill the goals and objectives we have set for ourselves. Being responsible requires effort and concentration and generates credibility and respect.
  
  HONESTY
  Honesty is the capacity to tell the truth and act accordingly, guiding our behavior and elevating our human dignity.
  
  SPIRIT OF SERVICE
  A spirit of service is a voluntary, customer-orientated mindset that encourages us to collaborate in our quest to solve our own problems, as well as those of others.
  
  TEAMWORK
  Teamwork is an attitude that helps us to share responsibilities and commitments to achieve a common goal, ensuring that we obtain results and take advantage of the strengths and qualities of all members of the organization, while respecting everyone’s human dignity. When we work as a team, we all win!
  
  CONTINUOUS IMPROVEMENT
  Through continuous improvement, we maintain our desire and commitment to constantly do our job better. When continuous improvement forms part of our way of being, we evaluate ourselves against the highest international standards so that our customers always see us as a market-leading company, while at the same time maintaining our focus on results and seeking to be the best option for our stockholders.
• OBJECTIVES OF THE CODE
  • Since its founding, Grupo Lamosa has constantly instilled in its people the values and principles that should govern their personal and professional lives. Through the Code of Ethics, Grupo Lamosa seeks to inform its personnel of the standards of behavior and ethics that they should observe at all times while performing their work at the company, guiding them to always act in a congruent, responsible and honest manner.
  • The Code also seeks to inform customers, suppliers, investors, competitors, the authorities and third parties who are interested in the company of the values and ethical behavior to which the people of Grupo Lamosa have committed, thereby pursuing the highest standards of business conduct and professional ethics while protecting Grupo Lamosa’s image and prestige.
• SCOPE OF THE CODE
  • The provisions of the Code of Ethics are obligatory for all Grupo Lamosa stakeholders, including the members of the Board of Directors, and company officers, managers, employees and workers.
  • Any situation beyond those addressed in this Code that might give rise to doubts about how to behave will be resolved by the Ethics Committee on the basis of objective criteria.
• ETHICAL STANDARDS
  • Respect for the Individual
    • At Grupo Lamosa, we respect people’s dignity and acknowledge their freedom and privacy, rejecting every type of discrimination on the basis of gender, marital status, religion, social class, political affiliation, ethnicity, nationality, handicap, sickness or any other condition protected by the Law.
    • The people who belong to the Grupo Lamosa team undertake to:
      • Comply with applicable laws and regulations, the provisions of this Code of Ethics, and the internal control policies, regulations and procedures stipulated by the company.
      • Act with honesty, respect and solidarity.
      • Refrain from divulging the company’s confidential information, including, but not limited to, information related to processes, methods, strategies, plans, projects, and technical and market data.
      • Avoid carrying out external activities that might affect their performance and responsibilities in the company.
      • Abstain from involving the company when participating in political activities, clearly stating that they are acting in a personal capacity.
      • Be respectful and treat colleagues and all other people with dignity.
      • Avoid all forms of pressure, verbal or physical intimidation, or sexual harassment toward other employees or colleagues.
      • Use, while performing their work, the systems, telephone, e-mail and any other communication media appropriately.
      • Comply with working hours, using them effectively and efficiently.
    • It is the duty of all members of the Grupo Lamosa team to report in good faith any act or omission that constitutes a violation of the provisions of this Code of Ethics. Therefore, any reprisal against, or affectation of the right of employment of, anyone who is collaborating in an investigation of a possible non-compliance with this Code is strictly prohibited.
  • Customer and Supplier Relations
    • Relationship with customers
      • Employees who, by reason of their duties, have contact with customers must undertake to consistently treat them with professionalism, honesty and excellence, providing the products and services agreed upon with the greatest possible quality and expeditiousness, and adhering to applicable laws and the company’s internal rules and regulations.
      • Sales promotions and arguments used by Grupo Lamosa employees must be free from false or deceptive information concerning the availability, appropriateness or quality of the products and services that we offer, as well as regarding the terms of sale. Moreover, Lamosa employees must act in accordance with the company’s growth and profitability goals.
    • Relationship with suppliers
      • In keeping with our values, we must endeavor at all times to ensure that our supplier portfolio only includes those suppliers who share the ethical values of our organization and possess a solid reputation for fairness and integrity in their dealings.
      • Employees who are responsible for negotiating the acquisition of goods and services must offer to, and demand from, suppliers professional, honest treatment, always seeking the best interests of the company within the framework of the Law.
      • Processes for the acquisition of goods and services must be conducted with transparency, ensuring the fair, unbiased participation of suppliers on the basis of objective criteria of quality, solvency, specialization, timeliness, cost effectiveness and service, and adhering at all times to established internal control guidelines.
  • Relations with the Authorities and the Community
    • We at Grupo Lamosa must fully comply with all applicable laws and regulations when performing our activities.
    • We must always collaborate with any relevant authorities, acting according to the Law and defending the legitimate interests of Grupo Lamosa at all times.
    • We must recognize the position of the authorities as such and always treat them with respect.
    • Any transactions, procedures and relations conducted on behalf of the company with government departments or officials must adhere to the applicable laws.
    • Social norms and good habits that promote healthy relations with the communities where we operate must be observed and respected by all those who are employed by Grupo Lamosa, and employees must always seek to promote the good image and prestige of the Company.
  • Conflicts of Interest
    • Grupo Lamosa employees must abstain from having an interest in businesses that buy from, or sell or provide products or services to, the companies of Grupo Lamosa, or that compete with such companies, without the prior authorization of the Ethics Committee.
    • Grupo Lamosa employees must abstain from participating in, or influencing the company to participate in, buying and/or selling operations or service provision transactions with family members or with companies in which they have an interest, unless such persons or companies are outside their area of responsibility or the situation has been previously justified before the Ethics Committee so that compliance with said requirements can be validated. The Corporate Internal Audit Department will monitor all cases reported
    • Grupo Lamosa employees must abstain from working with, or being directly in charge of, family members or people with whom they have a close personal relationship (e.g. close friends or boy/girlfriends). Therefore, family members should not work in the same business or company unless they have the prior authorization of the Ethics Committee.
    • When Grupo Lamosa personnel have to execute surveillance, supervision, or audit or control tasks in an area headed by a family member or a person with whom they have a close personal relationship, they must inform their superior so that they can be relieved of this responsibility.
    • When employees feel that they are being influenced in their capacity to fulfill their responsibilities objectively, through pressure from third parties who are using their position, authority or influence in the organization, they must immediately report the situation through the Transparency Line complaints system that is described later in this document.
    • Employees must avoid interceding in order to satisfy the demands of superiors, subordinates, colleagues, family members or friends if this adversely affects the companies of Grupo Lamosa.
    • Grupo Lamosa employees must not receive or accept any gifts, advantageous conditions, trips, social gatherings (meals, breakfast, etc.) or similar events, commissions or any other benefit from the customers, suppliers, financial institutions, contractors, or firms or persons with whom they deal, except for institutional or general cases, or promotional items.
      
      Grupo Lamosa employees must report any attempted case of bribery to the Ethics Committee.
      
      Queries in this regard must be submitted to the Ethics Committee or the person appointed by this panel for their resolution.
    • During the investigation and resolution of a “Conflict of Interest” case, the employee(s) involved must abstain from making decisions in this respect and their immediate boss must intervene.
  • Information Management
    • Altering accounting information and/or records or falsifying accounting operations, either to simulate the fulfillment of goals or objectives or to obtain personal benefit, is strictly forbidden.
    • People who have access to information that is private or that is by nature or by classification considered to be confidential must take the necessary measures and use extreme care to maintain its absolute confidentiality, and refrain from divulging or filtering such information to unauthorized persons. When employees become aware of the loss or disclosure of information, for any reason, they must report it immediately to their superior.
    • Employees must collaborate professionally, truthfully and objectively with the company’s internal and external auditors when they are carrying out their work in the company.
    • Employees, such as teachers, lecturers, students, specialists and/or technicians, who conduct complementary external activities at events related to their field must abstain from using confidential information pertaining to Grupo Lamosa and may only use public information.
  • Use and Protection of Assets
    • Grupo Lamosa employees are responsible for the care, safekeeping and proper use of the company assets that are under their control.
    • Assets that are the property of Grupo Lamosa, as well as services available to the personnel who work at the company, are to be used for the performance of their duties and for the benefit of the company itself. Under no circumstances may they be used for other purposes, unless the Ethics Committee has authorized such use.
  • Environment and Ecology
    • Grupo Lamosa recognizes that environmental protection forms part of our corporate social responsibility. This commitment is shared by everyone, and nobody at Grupo Lamosa can assume that environmental protection is somebody else’s job.
    • Grupo Lamosa employees must perform the actions necessary, within their respective fields of responsibility, to ensure that the environment is respected and energy used efficiently in the work areas.
  • Industrial Safety and Occupational Health
    
    At Grupo Lamosa, we believe that the health and safety of our employees and the safeguarding of the company’s production equipment and facilities are the most important components of our daily activities, which is why under no circumstances can taking unnecessary risks be justified. If an employee were to receive an order from a superior to execute an activity that is contrary to the related Safety Rules and Regulations, he or she must not obey this order and must report it through the Transparency Line, which is explained later in this document.
    
    We must fulfill our objectives and goals, but do so in a safe manner. Therefore, all of us must work together to guarantee the fulfillment of the following objectives:
    • Fully adhere to the safety and hygiene standards provided in the official and company’s internal laws, regulations, statutes and standards.
    • Propose and maintain an appropriate work environment.
    • Help to make other employees aware of the importance of safety.
• CODE MANAGEMENT AND ENFORCEMENT
  In order to ensure that the commitment that we have all assumed will be fulfilled, that the provisions specified herein form part of our daily actions and that this Code of Ethics is enforced, Grupo Lamosa has implemented the following mechanisms and entities:
  • Ethics Committee
    • The Ethics Committee is a collegiate body established specifically to deal with matters related to the Code of Ethics and its application.
    • The Ethics Committee is made up of the CEO of Grupo Lamosa, the Corporate Human Resources Director, the Chief Financial Officer and the Corporate Internal Auditing Manager. If any cases that need to be analyzed were to involve a member of this Committee, such cases shall be dealt with by the Audit Committee of Grupo Lamosa’s Board of Directors. Moreover, if a case were to involve an employee of any member of the Ethics Committee, said member shall not participate in its resolution.
    • In order to fulfill its responsibilities, the Committee may consult other areas or people to assist in the execution of specific tasks.
  • Dissemination and Updating
    
    The Ethics Committee will establish a process that ensures the communication and understanding of Grupo Lamosa’s Code of Ethics.
    
    In this regard, all those who work for any Grupo Lamosa company must familiarize themselves with the content and scope of this document and, once they have received it physically and read it, sign a letter of commitment as proof of this.
    
    The experience of applying the Code on a daily basis is a source for its continuous improvement, which is why the collaboration of the members of the Ethics Committee is indispensable for its revision and updating. For this purpose, feedback mechanisms have been established to keep the document constantly up to date.
  • Compliance Commitment
    • At least once every two years, a document will be prepared and distributed to all Grupo Lamosa employees, requiring them to state in writing that, during this time, their personal actions were executed in compliance with the Code of Ethics and to indicate, where appropriate, any doubts they may have about its application. (See the “Letter of Commitment” form.)
    • The Corporate Internal Audit Department will design said document and safeguard employees’ original signed documents.
    • The Ethics Committee will ensure that the delivery of the document will be channeled to each person by his/her respective Human Resources area, which, in turn, will collect said document once the deadline for its completion has been reached and submit it to the Corporate Internal Audit Department, which, if there are any cases that need reviewing, will act in accordance with the procedures of the Transparency Line system, explained later in this document.
    • The Corporate Internal Audit Department will submit an updated report on the situation to the Ethics Committee with its observations and comments.
    • The Ethics Committee will act at all times with the strictest confidentiality.
  • Sanctions
    
    Violations of this Code will be subject to sanctions that will be applied according to the gravity of the infringement committed, ranging from a warning, suspension or dismissal to formal complaints made to the corresponding authorities.
  • Complaint System
    • All Grupo Lamosa employees must report any case that might constitute a violation of this Code of Ethics, on the understanding that all reports will be handled confidentially and objectively and will be documented in strict adherence to our Values and the Law.
    • The open communication of situations and concerns by employees, without fear of reprisal, is vital for the concordant consolidation of the provisions of this Code.
    • Complaints and concerns may be submitted through the Grupo Lamosa complaint system known as the TRANSPARENCY LINE, where employees and other stakeholders can leave anonymous, confidential messages. However, we recommend providing personal information so that the Committee can follow up on a given case better, while guaranteeing absolute privacy.
      
      Telephone: 01-800 7LAMOSA
      
      Website: www.grupolamosa.com
      
      E-mail: lineatransparencia@lamosa.com
      
      FORM TO UPLOAD YOUR COMPLAINT

APPENDIX

LETTER OF COMMITMENT
I hereby certify that I have read the entire Grupo Lamosa Code of Ethics and declare my commitment to comply with the ethical standards and provisions expressed therein. I also agree to report any real, potential or apparent situation that could constitute a violation of the said Code.

At this time, I do not have any personal conflict of interest ______ that should be reported to the Ethics Committee.

At this time, I do have a personal conflict of interest ______ that I should like to report to the Ethics Committee for their evaluation.

If you have answered in the affirmative, please describe the matter in detail below:

Date: ______________________________
Location: __________________________
Name: _____________________________
Position: ___________________________
Company: _________________________