1. Introduction

Restaurantes Saona S.L. (hereinafter, "Grupo Saona") was born from a love story: love for a cove in Formentera, for a person, for a way of living, feeling and sharing gastronomy. A deep love for a culture that inspires us to enjoy life, for colors, light and a special sensitivity for details. This essence is reflected in each of our establishments, creating spaces that evoke well-being, closeness and the celebration of the present.

Grupo Saona is one of the fastest growing restaurant groups in the country. Its sustained evolution is the result of a business model based on operational excellence, a firm commitment to quality and the constant search to generate value in the customer experience. Since its creation in March 2013, the Group has developed its activity combining tradition, identity and modernity, with a firm focus on innovation and people's well-being.

In each of our restaurants we open the doors to endless opportunities to discover what gives meaning to our way of life: a way of celebrating, eating and sharing unique moments. We do this with a firm commitment to quality, ethics and integrity, principles that guide all our decisions and form an essential part of our way of understanding both life and work.

The corporate purpose of Grupo Saona, in accordance with its bylaws, includes the operation of activities related to the hospitality industry, as well as complementary and related services. Under the brands "Saona", "Quick Saona", "Tagomago" and "Turqueta", the Group operates in strategically selected locations, close to urban centers, and also in hotels, where it offers a differentiated proposal that includes special menus, breakfasts and room service.

Adapting to the new demands of the sector, we have implemented on-site pick-up and home delivery services through third-party digital platforms, expanding our responsiveness and reinforcing our commitment to accessibility, customer convenience and sustainable growth.

Beyond the operational approach, the essence of Grupo Saona lies in a corporate identity deeply rooted in its origins. Inspired by a personal story linked to a cove in Formentera, the brand represents a way of understanding life and enjoying gastronomy based on closeness, care and sensitivity.

This Code of Ethics contains the rules, commitments and criteria for action that are applicable to the Grupo Saona and must be complied with by all members of the Governing Body, Managers and employees in the performance of their duties and responsibilities, regardless of their hierarchical position, seniority, type of employment contract or geographical location in which they perform their duties, as well as stakeholders and other collaborators who are linked to the Group. Our Code of Ethics is the cornerstone of our culture.

Within the current framework of the Criminal Liability of Legal Entities (RPPJ), and with the aim of preventing the commission of criminal conduct that may be carried out voluntarily or involuntarily within the Group, a Crime Prevention Model has been developed and implemented, and this Code of Ethics has been approved, which sets out our values, principles and guidelines for action.

The recommendations contained in this Code do not replace any provision established by any applicable Agreement, Law, Regulation or Provision. In this sense, this Code does not replace other internal policies and should be applied in conjunction with other procedures and protocols that Grupo Saona has implemented in order to address the greatest number of possible scenarios.
We thank you in advance for your commitment and trust, and encourage our employees and collaborators to join us in this spirit and way of working, as well as to apply the ethical principles and conduct contained in this document in all activities carried out on a daily basis.

2. Objectives of the Code of Ethics

This Code of Ethics sets out the principles, standards of conduct, commitments and responsibilities that all Grupo Saona personnel are expected to have in the performance of their duties, both in internal relations and in their interactions with all stakeholders, managers, suppliers, customers and collaborators.

To this end, this document has the following objectives:

- Define the guidelines and procedures that Grupo Saona employeesmust follow in the event of conduct or actions of any member of the team that may negatively affect the interests of the company.

- Provide a framework of support to Grupo Saona in the exercise of its right to sanction any action performed by a team member that constitutes a failure to comply with his or her labor obligations, a lack of respect towards colleagues, a violation of internal regulations or any behavior considered unethical and moral.

- Use the Code of Ethics as a dissuasive tool against possible inappropriate behavior by Grupo Saona employees.

3. Scope of the Code of Ethics

This Code of Ethics is mandatory and shall apply to the following persons, "obligated parties", whether natural or legal persons:

- Members of the Governing Body and other entities that make up the Grupo Saona, whatever their composition, form and operating regime.

- Grupo Saona executives and middle management.

- Grupo Saona employees, regardless of the type of contract that determines their employment relationship, the position they occupy or the geographical area in which they carry out their work tasks.

- Customers, suppliers and any other stakeholders directly related to the Grupo Saona, to the extent that this document may be applicable to them.

4. Mission, Vision and Values of the Group

In Grupo Saona we take as a starting point the Mission, Vision and Purpose for the formulation of the ethical postulates that should guide the behavior of the people belonging to the Company, in their social work relationships, inside and outside the organization, with the surrounding institutions and the environment.

Grupo Saona 's mission is to create a gastronomic experience to enjoy the five senses.

Therefore, our Vision is to be the Mediterranean food restaurant group of reference, promoting a healthy lifestyle through our cuisine that bets on balanced dishes and cared spaces, through our.

In Grupo Saona we apply ethical behavior standards, and we continuously promote that each and every one of our directors, employees, collaborators, and those linked for one reason or another, develop their activities in compliance with a series of principles based on transparency, honesty and fairness.

Our values are commitment, responsibility, operational excellence, teamwork and meritocracy.

This Code responds to the criminal prevention obligations imposed in the field of criminal liability of legal persons, being an essential element of the Compliance and Criminal Risk Prevention Model adopted by the Grupo Saona

In this sense, although this Code does not contemplate all the hypotheses or situations that could arise in our day-to-day reality, it does constitute an accessible reference tool that serves to orient and guide our actions in matters of social order, corporate responsibility and, in general, in matters of ethics, integrity and legality.

Thus, the people who provide their professional services in Grupo Saona must know and comply with both the spirit and the meaning of this Code, which is the fundamental basis of the policies of good governance and corporate responsibility of Grupo Saona , which is the responsibility of the Board of Directors and the Management bodies of the Company, through the Compliance Officer.

5. Ethical and responsible behavior

1. STANDARDS RELATED TO ETHICS AND GOOD GOVERNANCE

FIGHT AGAINST CORRUPTION AND BRIBERY

Integrity, transparency and business ethics are fundamental principles for Grupo Saona. Consequently, we reject any conduct that consists of promising, offering, granting and/or receiving, requesting or accepting an unjustified benefit or advantage as consideration to unduly favor an employee or manager of Grupo Saona or a third party.

Grupo Saona expressly prohibits any conduct that may constitute corruption in the private sphere, including, but not limited to:

- Accepting or giving gifts, hospitality, travel or other types of benefits that may influence business decision-making.
- Offering or receiving bribes, undue payments or any type of compensation in order to obtain unfair business advantages.
- Altering contracting or procurement processes in order to unduly benefit certain persons or entities.
- Any conduct that may be interpreted as an attempt to unduly influence the impartiality and objectivity of business and professional relationships.

In this regard, we are not allowed to accept or facilitate bribes and we are dedicated to identifying and reporting any form of corruption, whether direct or indirect, active or passive.

Members of the Grupo Saona must act with integrity in all their business operations, avoiding soliciting or accepting personal benefits that could compromise business ethics.

Therefore, all members of the Grupo Saona must adapt their behavior to all internal and external regulations related to the prevention of corruption, participate in relevant training and education, and immediately report any suspicion or knowledge of corrupt activities to the Compliance Committee or the Compliance Officer.

GIFTS, HOSPITALITY AND OTHER COURTESIES

The Grupo Saona firmly and rigorously rejects any form of corruption, bribery or extortion, and declares its opposition to influencing the will of people outside the Group to obtain a benefit or advantage of any kind through the use of practices that contravene the law or the principles and standards of conduct contained in this Code.

In this sense, the receipt and delivery, promise or offer of any kind of payment, commission or gift to any authorities or public officials or members of private entities is prohibited, provided that due to their frequency, characteristics or circumstances they could be interpreted by an objective observer as being made with the intention of affecting the impartial judgment of the recipient. However, it is not included in this prohibition:

- Advertising objects of little value.
- Gifts that respond to signs of courtesy or usual commercial attentions.
- Occasional attentions for specific and exceptional causes, provided that they are not in cash and
are within reasonable and modest limits.

PREVENTION OF CONFLICTS OF INTEREST

A conflict of interest is understood as any situation in which the personal, professional or family interests of a member of the Grupo Saona may collide with the interests of the company, either directly or indirectly, affecting or giving the appearance of affecting his or her judgment, decision-making or performance of functions to the detriment of the Grupo Saona.

In this regard, all Covered Persons must disclose, at the time they are hired and during the performance of their duties, any situation that may involve a conflict between their own interests and those of the Company. To this end, the existence or possible existence of a conflict of interest must be communicated in writing to the immediate superior and/or the Compliance Officer. Such communication may be made by e-mail to the following address: compliance@gruposaona.com.

In a situation of potential conflict of interest, Persons Subject to the Code must always act with loyalty, honesty and in defense of the interests of the Grupo Saona, refraining from prioritizing their personal interests at the expense of those of the Company, and from intervening in or influencing the making of decisions affected by the conflict of interest.

PREVENTION OF MONEY LAUNDERING

The Grupo Saona strictly complies with national and international legislation on the prevention of money laundering. We are firmly committed to the fight against this type of crime and, therefore, under no circumstances do we promote, facilitate, participate in or cover up illicit operations. In line with this commitment, we do not maintain business relationships with entities that do not comply with these guidelines or that generate reasonable doubts about their compliance and are not able to clearly prove it.

Therefore, we establish the following guidelines in the relationship with third parties:

- We identify all individuals and legal entities with which we maintain commercial or professional relationships by means of the corresponding legal identification documents.
- We refrain from maintaining commercial or professional relationships with those individuals or legal entities that have relevant indications of committing or having committed a crime.
- We stop the relationship with a natural or legal person if we observe suspicious behavior, communicating this situation to the administration or competent authority.
- We do not accept cash payments equal to or greater than the amount of €1,000 or its countervalue in foreign currency.
- We do not accept installment or structured payments that are intended to evade records or systematic communications.

Grupo Saona personnel are responsible for carefully reviewing available information, including financial information, about business partners and suppliers. This process is intended to determine their reputation and the legitimacy of their activities before establishing business relationships.

Any member of the organization must immediately report any suspicious activity in a business, commercial relationship or contract to his or her hierarchical superiors or to the Compliance Committee. This will allow the relevant manager to study, analyze and decide whether it is necessary to suspend the business relationship and/or notify the competent authorities.

RESPECT FOR THE MARKET AND CONSUMERS

At Grupo Saona we recognize the importance of preserving the trust of our customers and acting responsibly in all areas of our business. Integrity, transparency and quality are fundamental principles that guide our commitment to a dining experience that is not only excellent, but also ethical and responsible.

In this sense, all the people who are part of Grupo Saona are committed to complying with the highest standards of quality, food safety and service, established by our operational areas. Our objective is to guarantee the full satisfaction and trust of those who choose us every day.

We provide our customers with sustainable and honest gastronomic proposals, adapted to their preferences, both in the consumption in the dining room and in the pick-up and delivery services. We promote clear and transparent communication about our products and services, offering truthful and accurate information about the composition of the dishes, the ingredients used, storage conditions and any other relevant aspect that allows informed decisions.

All employees must reliably communicate the necessary information, both internally and externally, avoiding at all times transmitting erroneous, incomplete or misleading information. Honesty in communication, attention to detail and respect for the customer are an essential part of our way of understanding the restaurant business and building a relationship based on trust and mutual respect.

GOOD PROMOTIONAL PRACTICES

At Grupo Saona we understand that the promotion and communication of our products and services must always be aligned with the values that define us: honesty, transparency and respect for our customers and competitors. As part of our commitment to market integrity and consumer protection, we promote responsible practices that reinforce trust in our brand and in the foodservice industry in general.

For this reason, in all our promotional activities we are guided by the following principles:

- Truthfulness of information: We ensure that promotional and advertising messages clearly and accurately reflect the real characteristics of our products and services. We avoid any kind of ambiguous or inaccurate information that may mislead customers.
- Ethical advertising: Grupo Saona does not allow any type of misleading advertising. The dissemination of messages that may generate false expectations about our offers, prices, products or any other relevant aspect of our proposal is prohibited.
- Accessibility and understanding: All information regarding our promotions, menus or offers must be presented in a clear and understandable way, so that our customers can make informed decisions with complete confidence.
- Fair competition: We encourage ethical and respectful behavior in attracting customers and in the comparison with other brands in the sector. We pledge not to make false, unfair or disparaging claims about others and not to take unfair advantage of other companies' reputations for our own benefit.

With these practices, we reaffirm our commitment to a culture of ethical, transparent and responsible communication that respects both those who choose us and those who share the industry with us.

PROTECTION OF PERSONAL DATA

At Grupo Saona, we recognize the fundamental importance of protecting the privacy of individuals and ensuring responsible and secure processing of personal data. Therefore, we are committed to strict compliance with current data protection regulations, specifically Regulation (EU) 2016/679 of 27 April 2016 (General Data Protection Regulation RGPD) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

All Grupo Saona personnel must ensure the confidentiality, integrity and availability of personal data, avoiding any unauthorized access, alteration or loss of such data. The processing of data will be carried out only for lawful, explicit and legitimate purposes, and always within the limits established by law or contract.

It is strictly forbidden to use personal data for purposes other than those authorized, as well as to transfer or disclose them without the express consent of the persons concerned, except in legally permitted cases. In the event of requests from public bodies, requests will be dealt with exclusively in the terms provided for by law, providing only the essential information.

In Grupo Saona we promote a culture of active responsibility in data protection, encouraging continuous training of staff and the continuous improvement of technical and organizational measures to ensure compliance with our obligations.

CONFIDENTIALITY OF INFORMATION

In Grupo Saona we consider information and knowledge as one of the main and essential assets for business management, so they must be subject to special protection. The Grupo Saona declares the truthfulness of information as a basic principle in its actions, so that employees must truthfully transmit all the information they have to communicate, both internally and externally, and in no case will knowingly provide incorrect or inaccurate information that may mislead the recipient.

Non-public information that is the property of the Grupo Saona or has been obtained by the Group in the course of its business shall, in general, be considered reserved and confidential information , and shall be subject to professional secrecy, and its content may not be disclosed to third parties, unless expressly authorized by the head of the corresponding department in each case, or unless required by law, court order or administrative authority.

The obligation of confidentiality shall remain indefinitely and shall include the obligation to return any material related to Grupo Saona in the possession of the Subject Person, or member of the Board of Directors, or employee at the time of termination of their relationship with Grupo Saona. The material includes the documents and storage media or devices, as well as the information stored in its computer terminal, subsisting in any case the duty of confidentiality.

PREVENTION OF HARASSMENT AT WORK, SEXUAL HARASSMENT AND HARASSMENT BASED ON SEXUAL ORIENTATION OR IDENTITY

In order to create a safe and respectful work environment for all employees, Grupo Saona adopts a zero tolerance policy towards any form of harassment, whether it is workplace, sexual or related to sexual orientation or gender identity. We recognize and value diversity in all its forms and strive to foster an inclusive culture that promotes equality and mutual respect.

It is our duty and responsibility to ensure that all employees feel supported and free from any harassment or discrimination, therefore, we prohibit any action, conduct or behavior that could be considered humiliating or intimidating.

In this sense, we fully reject any manifestation of physical, psychological or moral harassment or abuse of authority, as well as any other conduct likely to generate an intimidating or offensive environment with the rights of individuals. We also do not accept any type of discrimination based on age, race, gender, sexual orientation or identity, ethnic origin, religion, political opinion, nationality, social origin or disability, as well as any other reason provided for in the applicable regulations.

In the event of observing or witnessing hostile, intimidating, humiliating or disrespectful behavior, it must be reported to the immediate superior and/or the Compliance Committee or the Compliance Officer.

With the aim of preventing, detecting and acting in situations of harassment, whether in the workplace, sexual or of any other kind, the welcome manual provides information on the existence of the Action Protocol against Harassment. In addition, Grupo Saona has a communication channel that allows alerting of comments and actions that violate the dignity of individuals.

COMMITMENT TO CORPORATE SOCIAL RESPONSIBILITY AND THE ENVIRONMENT

In Grupo Saona we develop our activity from the active and responsible commitment with the conservation of the environment, respecting the requirements contemplated in the applicable legislation on pollution prevention and environmental protection. That is why we prioritize the search for local suppliers to minimize our impact on the environment.

From our first measurement to date, Grupo Saona has expanded. And our growth has always gone hand in hand with our environmental management plan. Throughout the entire process that brings the dish to the table for our guests, we seek to reduce our impact on the environment. At every step of our value chain, we make decisions that contribute to strengthening our environmental commitment.

For our restaurants and production center, we purchase energy-efficient goods and products and work with companies that guarantee renewable energy sources. In addition, we hire people who live near our restaurants and promote carbon-neutral transportation, and our commercial partners in charge of delivery share our concern for climate change, incorporating vehicles with lower environmental impact into their fleets and seeking to be efficient in route planning.

In order to efficiently manage the control of environmental, social and governance risks, we have implemented a transversal management structure through a governance model consisting of a Social Responsibility Committee.

PROTECTION OF INTELLECTUAL AND INDUSTRIAL PROPERTY

At the Grupo Saona we ensure the protection and respect of intellectual and industrial property rights, both our own and those of others, and we demand the same commitment from our suppliers and collaborating companies.

Intellectual and industrial property is understood to be all patents, distinctive signs, copyrights, new creations, trademarks, industrial designs, trade secrets and any other form of property protected by the legal system. For this reason, all members of the Grupo Saona must respect intellectual and industrial property rights, both their own and those of third parties.

In this sense, the Group prohibits any action that may infringe the industrial and intellectual property rights of both Grupo Saona and third parties, and undertakes to:

- Know and respect intellectual and industrial property laws;
- Do not use copyrighted material without first obtaining or confirming permission;
- Respect all patents, trademarks, copyrights, proprietary information or trade secrets, as well as the confidentiality of anyone with whom we do business.

All Persons Subject to the Code must respect the intellectual property and the right of use that corresponds to the Grupo Saona in relation to courses, projects, computer programs and systems, equipment, manuals, knowledge, processes and in general, any work or work developed or created by the Grupo Saona, whether as a result of their professional activity or that of third parties.

RESPONSIBLE USE OF CORPORATE RESOURCES AND CYBERSECURITY

At Grupo Saona we ensure the comprehensive protection of digital assets against cyber threats and IT risks, guaranteeing the confidentiality, integrity and availability of IT systems, networks, devices, databases and applications.

In Grupo Saona we provide our staff with the necessary resources for the performance of their professional activity, and we are committed to providing the means for the protection and safeguarding of resources. The IT resources and equipment provided by the Group are intended exclusively for the fulfillment of work obligations. Employees must understand that these resources may not be used for personal or non-professional purposes, and are not for private use.

At Grupo Saona we promote a culture of responsibility and IT security, protecting both corporate resources and the Group's confidential information.

ADMINISTRATIVE, ECONOMIC AND FINANCIAL MANAGEMENT

The Grupo Saona is committed to full compliance with current regulations concerning due diligence in administrative, economic and financial management in any geographic location where it carries out its business activities.

Both the Group and its components have an obligation to ensure the accuracy of our financial statements and reports as required by applicable law and accounting principles. In this regard, all financial transactions will be accounted for in accordance with generally accepted accounting principles in a correct and not misleading manner.

In Grupo Saona we are committed to comply with any accounting, tax and financial regulations, ensuring transparency and protecting the interests of any of our economic agents. Therefore, we have several controls in the management processes on financial resources, preventing all those practices that involve the avoidance of payment of taxes or taxes to the detriment of the Treasury, Social Security, or any other administrative body of local or regional administrations.

In Restaurantes Saona, S.L. are expressly prohibited all those practices that involve the avoidance of payment of taxes or taxes to the detriment of the Treasury, Social Security, or any other administrative body of local or regional administrations, so that the Subject Persons should avoid such practices at all times.

2. RULES RELATED TO PROFESSIONAL ACTIVITY AND INTERNAL RELATIONS

RESPECT FOR HUMAN RIGHTS

At Grupo Saona we are committed to respecting internationally recognized Human Rights, which include the rights established in the Universal Declaration of Human Rights adopted and proclaimed by the United Nations General Assembly on December 10, 1948, the Convention for the Protection of Human Rights and Fundamental Freedoms and the Tripartite Declaration of the International Labor Organization (ILO).

OCCUPATIONAL HEALTH AND SAFETY

Grupo Saona considers safety in the workplace as a priority issue, therefore, is committed to ensure the safety, health and welfare of all its members and to comply with the rules and regulations relating to the prevention of occupational hazards.

In this sense, Grupo Saona assumes the following commitments:

- Comply with the legal regulations in force regarding Occupational Health and Safety, implementing health and safety techniques, as well as the requirements of our customers, as an ethical and moral imperative.
- Develop, implement and maintain a management model of Occupational Health and Safety aimed at continuous improvement of working conditions, providing this policy, the framework for the establishment of the objectives of safety and health at work.
- Eliminate the dangers and reduce the risks detected for Safety and Health at Work.
- Interaction of this system in the management of our company, so that prevention is incorporated into all activities that are developed affecting the safety, health or welfare of
our workers.
- Ensure consultation, participation and information of workers.
- Develop the necessary training activities for the development of preventive policy.

Grupo Saona has an Occupational Risk Prevention Policy and a Prevention Plan applicable to all its restaurants, offices and production center, whose objective is to avoid any type of damage to the health of the team, guarantee spaces free of hazards and promote healthy habits.

PHYSICAL INTEGRITY AND SEXUAL INDEMNITY OF THE MEMBERS

The Grupo Saona will not tolerate any conduct that may interfere with the physical integrity and/or sexual indemnity of the members of the Group, its clientele or any other person in the Group's Organizations of interest. Acts that attempt against physical and sexual integrity, and/or that are intended to cause physical harm or emotional trauma to a person, are expressly prohibited. Conduct considered to be prohibited includes:

- Verbal or written threats.
- Physical abuse or assault
- Discriminatory, racist or sexist remarks.
- Offensive visual displays, such as pictures or gestures. - Any act that causes fear or discomfort to another person.

Grupo Saona and all its personnel shall ensure that any type of harassment or abuse of superiority is avoided. In this regard, the Group will investigate in an appropriate manner any communication reported to the Compliance Body and, where appropriate, communicate it to the competent authorities.

PROMOTION OF EQUAL OPPORTUNITIES

Grupo Saona declares its commitment to the establishment and development of policies that integrate equal treatment and opportunities for women and men in the workplace, without discriminating directly or indirectly on the basis of sex, as well as the promotion and encouragement of measures to achieve equality within our Group.

In Grupo Saona we have implemented a personnel selection policy that guarantees equal employment opportunities and non-discrimination based on race, age, sex, religion or other aspects. This policy ensures that all people who apply for our selection processes receive a job opportunity, prioritizing equity in the team (men, women, nationalities, skills, etc.).

Employees shall promote a safe working environment that respects the dignity, individual freedom and fundamental rights of all members of our organization.

RESPECT FOR THE IMAGE AND REPUTATION OF THE GRUPO SAONA

In Grupo Saona we conceive our public image and corporate reputation as one of the most valuable assets to preserve the trust of our shareholders, customers, employees, suppliers and society in general. It is for this reason that all employees must take the utmost care to preserve the Group's image and reputation in all their actions.

Our reputation for integrity is greatly influenced by the information we provide to the public and, for this reason, it is important that all communications present a true and accurate picture of our business relationships. Today, great importance is attached to the use of so-called "social media" - such as, for example, Instagram, Facebook, X, etc. - used by Grupo Saona members, whether professionally or privately, as a way of creating and sharing content, opinions, perceptions, experiences and perspectives. As a consequence of the great influence caused by these media, only authorized persons may intervene with these or any other means of public dissemination, provided that they appear in the condition of member of Grupo Saona.

In this sense, the employees and all members of Grupo Saona are committed to:

- Ensure the preservation of the Grupo Saona 's reputation in all activities carried out.
- Maintain appropriate conduct at all times when, with the prior authorization of the person in charge, use is made of the Group's brand, logos, designs, distinctive graphics and other assets - tangible or intangible - of the Group. In any case, inappropriate use must be avoided, in order to ensure that the reputation of the Grupo Saona is not compromised or damaged.
- Monitor the correct and appropriate use of the Group's image and reputation with regard to third parties.
- Be neat and meticulous in public interventions, in the media or in all types of conferences, lectures, seminars or any other public event whenever intervening in the condition
as a member of the Group.

The Company will take appropriate legal action against any type of slander and/or libel received and attack on its corporate image and reputation, both by internal and external agents.

RELATIONSHIP WITH CUSTOMERS, SUPPLIERS, CONTRACTORS AND COLLABORATORS

In Grupo Saona we assume, lead and promote the commitment to quality, providing the necessary resources to achieve excellence and establishing the appropriate measures to ensure that the quality policy is practiced by all employees in accordance with these principles.

Saona considers its suppliers and collaborating companies an indispensable part of the achievement of its growth objectives, seeking relationships with them based on mutual benefit.

All employees involved in supplier and external collaborator selection processes are obliged to act impartially and objectively.

The quality of the products and services provided by the Grupo Saona to its customers also depends on its ability to obtain excellent performance from its suppliers. The choice of suppliers must therefore be transparent and meticulous. Saona selects them for their professionalism and competitiveness in the perspective of a relationship of trust.

All negotiations must comply with the quality principles defined by the Company. Fairness and impartiality must govern relations with suppliers in order to maintain a balanced and objective relationship with them. Purchases must be made in accordance with irreproachable ethics and comply with regulations, particularly those relating to competition rules.

In addition, Grupo Saona recommends that its suppliers or collaborating companies, if they do not already have them, adopt ethical and social standards that respect practices compatible with the Company's values.

Any lucrative relationship, with a personal interest, with any supplier and/or collaborating company of the Grupo Saona, will be grounds for disciplinary action.

6. Disciplinary regime

The guarantee of compliance with the above principles, conduct and guidelines is the responsibility of each and every one of the people who make up the Grupo Saona and of the people associated with it.

Therefore, no person bound by the Code of Ethics, regardless of his or her position or position, may engage in actions or conduct contrary to the Code or to current and applicable law.

Likewise, no member of the Grupo Saona, regardless of his or her level or position, is authorized to ask any employee to contravene the provisions of this Code, and no one may justify his or her conduct on the grounds of an order from a superior or ignorance of it.

In relation to suppliers, compliance with the Code of Ethics will be part of a supply or service contract signed with them. Failure to comply with it may give rise to the possibility for Grupo Saona to waive or terminate the contract without any obligation to compensate or indemnify.

Failure to comply with the Code of Ethics may entail labor consequences for breach of contractual good faith, regardless of the administrative or criminal consequences that, if applicable, may also be applicable. Likewise, such non-compliance may also lead to the adoption of disciplinary measures under labor legislation and the application of applicable Collective Bargaining Agreements.

7. Dissemination and follow-up

The Grupo Saona will take appropriate measures to ensure that all its recipients are aware of the contents of this Code of Ethics and that they understand its scope. This Code shall be accepted by any person as a prerequisite for joining the Group. The Code of Ethics will be available on the intranet and on the corporate website, so that all persons who are or may be linked to the Group can have access to it.

8. Review and update

The Compliance Body shall periodically review this Code, taking into consideration the annual reports and the suggestions of the people who make up Grupo Saona. The Grupo Saona's General Management shall be responsible for approving proposed changes to this Code of Ethics.

The Group undertakes to carry out the corresponding training courses in order to ensure that all Group members are aware of the rules contained in this Code and any updates that may be made to it.

9. Ethical Channel

The Grupo Saona undertakes to carry out the corresponding training courses in order to ensure that all members of the Group are aware of the rules contained in this Code and any updates that may be made to it.

All members of the Grupo Saona assume the commitment to adopt the necessary measures to detect and correct any action contrary to the law or the rules of this Code of Ethics. To make this effective, the Group will have an Ethical Channel for the communication of non-compliance and possible offenses. In case of doubts about the Ethics Channel, the Compliance Body may be contacted.

The bodies responsible for ensuring proper compliance with this Code are: Compliance Body.

Senior Management.

The Grupo Saona undertakes not to adopt or allow any form of retaliation, directly or indirectly, against professionals who in good faith have communicated through the Ethics Channel an action contrary to the law or the rules of the Code of Ethics.

All internal institutions, personnel and related third parties are expected to comply with the Code of Ethics, and should they have any doubts about how to act, they are expected to raise them with the Compliance Officer or any member of the management team, via the following e-mail address:

compliance@gruposaona.com

Grupo Saona also has a whistleblower channel accessible through the website https://www. gruposaona.com/canal-etico/.