COMPLIANCE POLICY OF LORTEK, S.COOP.

COMPLIANCE POLICY OF LORTEK, S.COOP. LORTEK is a private technology centre that generates excellent knowledge in manufacturing proces- ses and respective digitalization so it can be transferred to industry, thereby improving competitive- ness, environmental impact and sustainability. With the legal status of a cooperative society, LORTEK’s way of working is grounded in a culture of ethical conduct based on values that serve to actively prevent and avoid any inappropriate behaviour. The core concept of our Crime Prevention System or Legal Compliance System (hereinafter the “Compliance System”) is that all the persons who together form LORTEK carry out our activities com- mitted to abiding by current legislation, especially regarding criminal law, and the ethical values and principles set out in our internal rules and in line with our culture of innovation, social commitment, gender equality and transparency. AIMS This Legal Compliance Policy (hereinafter the “Policy”) establishes and communicates the aims and general action principles of the Compliance System. a. To foster a positive and constructive culture of business ethics at LORTEK , involving all persons who together form the company, based on the principle of ‘zero tolerance’ regarding the commission of illegal acts or regulatory noncompliance. b. To comply with the different legal obligations and standards of business diligence in this area, with special reference to regulations of the European Union and the Basque Country’s legislation on cooperatives. c. To prevent the commission of crimes and regulatory noncompliance in the company, avoiding legal liability (criminal, civil, etc), the imposition of penalties and fines, and claims from third parties. d. To enhance the reputation capital of LORTEK , avoiding risks and guaranteeing its value. e. To consolidate the relationship with clients, suppliers and partners in projects , maintaining and guaranteeing professional relations with them and other third parties of interest, such as other research networks and centres and government agencies. The main objectives of the LORTEK Compliance System are: The Compliance System therefore helps guarantee and enhance the value of LORTEK and protects the company against eventual liability. SCOPE OF APPLICATION This Policy is binding and applicable to all LORTEK personnel, without exception and no matter what their position, responsibility, occupation or location, per the terms set out by applicable criminal law. For the purpose of this Policy, included as “LORTEK personnel”, among others, are persons who are partners or workers of the cooperative and persons from institutions and research or training centres who participate in the company’s activities in the form of “internships”, “research projects”, “study and end-of-degree projects” and “dual training”, along with other persons who may act as collaborators of LORTEK, with access to the company’s resources though without having an employment relationship.