GENERAL ACTION PRINCIPLES To achieve the aims of the LORTEK Compliance System, the following General Action Principles are established: a. Mandatory compliance with applicable legislation, internal rules and other regulations applicable to LORTEK according to the respective activity (rules of international projects, etc). b. Identification and evaluation of risks . LORTEK identifies and evaluates different risks that exist due to its activity and implements the measures needed to mitigate or eliminate them. c. Definition and implementation of appropriate procedures . LORTEK has policies, procedures and processes for preventing crime and regulatory noncompliance that are appropriate for its activity and structure. d. Update of the Compliance System : continual monitoring, analysis and updating of the risks and procedures. e. Training : LORTEK’s personnel have received sufficient training to know the aims and functioning of the company’s Compliance System. f. Obligation to report any eventual conduct that is illegal or may involve regulatory noncompliance: to that end an Ethics Channel is established, which can be accessed via the website It is managed in first instance by an external company, with confidentiality totally guaranteed. g. Obligation to collaborate : all LORTEK personnel have the obligation to collaborate in eventual processes or investigations that must be carried out to determine the facts linked to alleged infringements. h. Provision of means : LORTEK will devote sufficient resources to ensuring that its Compliance System functions effectively and continually improves, with special reference to the duties of supervision, monitoring and control. i. Oversight body : LORTEK has an internal body that oversees fulfilment of its Compliance System. j. Consequences of noncompliance : LORTEK will apply the respective disciplinary measures and take the corresponding legal actions in the event of noncompliance, either of criminal nature or regarding other applicable internal or legal rules and regulations. UPDATING AND REVISION This Policy shall be periodically revised and updated to ensure adjustment to regulatory changes and those that may arise due to LORTEK’s activities, guaranteeing its effective implementation at all times. CORPORATE COMPLIANCE In Ordizia (Gipuzkoa), on 2 June 2022 Signed: Jaione Ganzarain Epelde , General Manager of LORTEK APPROVAL AND VALIDITY This Policy came into force at the time of its approval by the LORTEK Management Board on the date of 2 June 2022 and shall be applicable per the terms established and until its update, revision or revocation has been approved.