Lortek Compliance

e. Consolidate the relationship with customers, suppliers and "partners" in projects, maintaining and guaranteeing the professional relationship with them and other "third parties of interest", such as other research centers and networks and public administrations. Therefore, the Compliance System helps to guarantee and increase the value of LORTEK and to protect the company from possible liabilities. 2. Scope of application This Policy binds and applies, without exception and regardless of their position, responsibility, occupation or location, to all LORTEK staff, in the terms defined by the applicable criminal law. For the purposes of this Policy, "LORTEK staff" includes, among others, members or employees of the cooperative, persons coming from institutions, research or training centres involved in the activities of the company in the form of "internships", "research projects", "study and final-year projects", "dual training" and other persons who can act as LORTEK collaborators, with access to the company’s resources, without having an employment relationship. 3. General principles of action In order to achieve the objectives of LORTEK’s Compliance System, the following General Principles of Action are established: a. Obliged to comply with the applicable legislation, internal regulations and other regulations that are applicable to LORTEK according to its activity. b. Risk identification and assessment . LORTEK identifies and evaluates the various risks associated with its activity, and implements the necessary measures to mitigate or eliminate them. c. Definition and implementation of appropriate procedures . LORTEK has policies, procedures and processes for the prevention of crime and regulatory non- compliance appropriate to its activity and structure.

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