Ethics code

This Code of Ethics sets out the body of general rules and principles of corporate governance and personal conduct applicable to all staff and management of ATENCO ENERGÍA (trading name CANALUZ), which serve to establish the guiding parameters of the company's corporate culture. Our Code of Ethics is addressed to all members of the Company, and will be distributed to them in order to enforce its observance and compliance, making use of the compliance assessments of the criminal risk prevention and management model.

All staff and management belonging to ATENCO ENERGÍA must comply with current legislation, with a commitment to acting in any corporate sphere in accordance with the values of honesty and integrity.

ATENCO ENERGÍA rejects any conduct contrary to the law, and accordingly has established a criminal risk prevention and management programme, implementing a whistleblowing channel or ethics channel, through which incidents, complaints and alerts of alleged malpractice are received, both from persons linked to the company and from external parties.

The whistleblowing channel or ethics channel is available on the ATENCO ENERGÍA corporate website.

In order to obtain information regarding the processing and monitoring of allegedly infringing conduct, confidential treatment is guaranteed for any query or complaint received through the aforementioned channel.

The staff and management of ATENCO ENERGÍA must carry out their activities in a manner fully consistent with respect for the Universal Declaration of Human Rights, being aware that they represent the public image of the company.

ATENCO ENERGÍA is committed to the labour rights recognised in current legislation, respecting freedom of association and collective bargaining, and no coercive measures of any kind will be permitted to prevent the exercise thereof.

At ATENCO ENERGÍA we care about the occupational safety of our staff, employing strategies to promote a preventive culture within the framework of mandatory regulations across all our facilities and activities, applying the protection of the life, physical integrity and health of the people who make up our company.

We are committed to striving to achieve the highest occupational health and safety standards, beyond mere compliance with current legislation, allocating all necessary resources in order to raise the level of protection.

As a key element of maximum efficiency, we provide our workers with information relating to the risks inherent to their professional duties, promoting participation and awareness of issues related to occupational health and safety.

In this regard, ATENCO ENERGÍA commits to creating the safest possible working conditions, reducing and eliminating risk factors, training its staff and allocating the necessary human and material resources to achieve this objective.

Within the ATENCO ENERGÍA environment, non-discrimination on grounds of race, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of its staff and management is promoted, as well as the encouragement of equal opportunities among them.

ATENCO ENERGÍA will promote equal treatment between women and men with regard to access to employment, professional training and advancement, and working conditions.

ATENCO ENERGÍA prohibits abuse of authority and any form of harassment, whether physical, psychological or moral, as well as any other conduct that may create an intimidating, offensive or hostile working environment for individuals. Should anyone experience a situation of harassment, or become aware of its existence, this must be immediately reported through the ethics channel or whistleblowing channel.

As a demonstration of this commitment, our company has an equality plan in accordance with current legislation, thus making effective the right to equal treatment and opportunities between women and men, in particular through the elimination of discrimination against women, whatever their circumstances or condition, facilitating access to and advancement in employment and improving the balance between personal, professional and family life.

ATENCO ENERGÍA maintains a firm stance against corruption. Our company is opposed to conditioning the free will of third parties in order to obtain any benefit through the use of unethical practices. Under no circumstances will other natural or legal persons be permitted to make use of such practices with our staff and management.

Our staff and management may not give or accept gifts or presents in the course of their professional activities. In particular, they may not give or receive any form of bribe or commission, from or made by any other party involved, such as public officials, whether Spanish or foreign, staff of other companies, political parties, authorities, clients, suppliers and shareholders.

Acts of bribery, which are expressly prohibited, include the offering or promise, direct or indirect, of any type of undue advantage, any instrument used to conceal it, as well as the trading of influence.

Exceptionally, the giving and acceptance of gifts and presents will be permitted when they are of negligible or symbolic economic value, reflect customary signs of courtesy or usual commercial gestures, and are not prohibited by law or generally accepted commercial practices.

ATENCO ENERGÍA declares its firm commitment to generally accepted accounting principles and to the applicable tax and fiscal regulations.

Furthermore, all daily transactions will be recorded in the accounts, with the corresponding supporting documentation kept in the appropriate file, for the period formally established by the organisation and, in any case, for the legally established periods.

Under no circumstances will the forms, means and audit and evaluation activities that may be carried out by auditing bodies be obstructed.

ATENCO ENERGÍA is aware of the increasing vulnerability of the environment and is committed to its preservation.

In our activities we ensure respect for natural spaces, unambiguously protecting any historical, artistic, cultural, monumental or natural heritage that may be affected.

In pursuit of energy efficiency, we seek to reduce emissions and pollution, endeavouring to ensure proper waste management, and promoting energy saving and the fight against climate change.

ATENCO ENERGÍA has an adequate data protection policy. Our company respects the right to privacy of its employees, in particular personal, medical and financial data, using such data in accordance with the principles of lawfulness, fairness and transparency.

Its management and processing will be carried out in accordance with the established legitimate purposes, prohibiting the transfer of personal data to third parties, except with the express consent of the data subjects, or in those cases where it is required by the fulfilment of a contractual or legal obligation, or by compliance with judicial or administrative rulings, or where another legal basis exists to justify it.

In the area of personal data, the full exercise of the rights of access, rectification, erasure, restriction of processing, portability and objection will be guaranteed, as well as the exercise of any claims that may arise from alleged malpractice.

A "conflict of interest" exists when private interests (external business, financial, family, political or personal) could interfere with the interests of our company.

The staff and management of ATENCO ENERGÍA will endeavour to avoid situations that may lead to a conflict between personal interests and those of the Company, refraining from representing the company and intervening or influencing decision-making in any situation in which they have, directly or indirectly, a personal interest. They may not use their position at ATENCO ENERGÍA in order to obtain financial or personal advantages or business opportunities of their own.

In situations that may raise any doubt, the company must first be informed through the relevant line manager, in order to avoid making a decision that could be suspected of having acted against the interests of the Company.

In the exercise of our Corporate Responsibility towards the sector and the market, at ATENCO ENERGÍA we commit to competing in the market freely, fairly and honestly, renouncing tactics that are contrary to the ethical values we uphold.

From its approval by the Governing Body, this Code of Ethics is incorporated into the company's regulations, remaining in force unless and until its annulment, revocation or update is approved.

For the approval of any updates that may take place, special consideration will be given to the recommendations and proposals made by the Compliance Body.