Culture of Compliance and Integrity

GRI 2-23, 2-24, 2-25, 2-26, 2-27, 205-2; NIS C.6

Integrity is a non-negotiable value for Grupo Lamosa. The company’s culture of compliance is structured through a robust framework led by the Ethics Committee. This committee is composed of the Chief Executive Officer, the Human Resources Vice President, the Chief Financial and Administrative Officer, and the Chief Internal Auditor. The Ethics Committee reports to the Audit Committee, which in turn reports to the Board of Directors.

The Ethics Committee’s key responsibilities include:

  • Analyzing, investigating and ensuring appropriate resolution of all reports received through the Transparency Hotline.
  • Periodically reviewing the Code of Ethics.
  • Conducting training sessions on the Code of Ethics and administering perception surveys regarding the reporting channel.

The work of Grupo Lamosa’s Ethics Committee is supported by the following mechanisms:

Code of Ethics

This governing document establishes the expected standards of conduct and the core values applicable to Board members, executives, employees and business partners. Its extensive availability ensures that all operations, transactions and stakeholder relationships are conducted in a responsible and transparent manner.

The Code of Ethics is complemented by diverse policies that form the company’s regulatory framework, including:

  • Anti-Corruption and Anti-Money Laundering Policy
  • Confidentiality Policy
  • Conflict of Interest Policy
  • Diversity Policy

Transparency Hotline

The company provides employees and third parties with a secure, confidential and anonymous reporting channel (managed by an independent third party) to report potential violations.

Every two years, the company conducts a survey among employees to assess the effectiveness of the reporting channel. The most recent evaluation was carried out in 2025, and the results are publicly available on Grupo Lamosa’s website.

View the latest Transparency Hotline evaluation results

Anti-Corruption

The company maintains a zero-tolerance policy toward corruption. All employees receive periodic training on ethics and regulatory compliance. Additionally, all new employees receive training in the Code of Ethics during the onboarding process and sign a commitment letter agreeing to comply with its provisions. They must also submit a conflict-of-interest declaration, which is renewed at least every two years.

During 2025, efforts were intensified to ensure full adoption of Grupo Lamosa’s culture and Code of Ethics across recently acquired operations, such as Baldocer, through awareness and communication sessions.

As part of its ethical commitment, Grupo Lamosa makes no financial contributions to any political party or government entity. Furthermore, as a result of its compliance efforts, based on internal criteria (including economic magnitude, nature and level of authority involved, reputational risk, potential operational impact and personnel involved), no significant cases of non-compliance, legal action or material monetary losses related to unfair competition, monopolistic practices or anti-competitive behavior were recorded during the reporting period.

Cases of non-compliance identified through the reporting channel during 2025 are detailed in Appendix 1.7: Key ESG Indicators.