Code of Ethics of COMSA Corporación

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Code of Ethics. Approved by the Board of Directors of COMSA CORPORACIÓN, on
May19th
, 2016. Errata update on May 2nd
, 2017
Code of Ethics of
COMSA CORPORACIÓN
Revised and approved by the Board of
Directors of COMSA CORPORACIÓN on May
19th
, 2016

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, 2017
Index
1. Object
2. Due diligence in COMSA CORPORACIÓN
3. Scope, acceptance and compliance
4. Liabilities
5. Report on irregular behaviour
6. Expected ways of behaviour
6.1 Regulatory compliance
6.2 Internal control and fraud prevention
6.3 Conflicts of interest and loyalty towards the organization
6.4 Persons
6.5 Environmental and social commitment
7. Aid and information
8. Duration of the Code of Ethics

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1. Object
The aim of the Code of Ethics of COMSA CORPORACIÓN DE
INFRAESTRUCTURAS S.L. (henceforth “COMSA CORPORACIÓN” or also
“Organization”), is to establish the guidelines of behaviour for their employees
in the day-to-day work, whatever their responsibility, their position in the
Organization or the geographical environment in which they develop their
activities may be. The term “employee” is understood to mean any person who
performs his/her functions within the corporate group COMSA CORPORACIÓN
and in all those companies in which the Organization may possess
management control.
Thereby the Code of Ethics determines the expected behaviours of the
employees in those matters of ethic nature which are related to the
commitments of the Organization in this field or to applicable rules and
regulations, which may be more relevant, under its activities and characteristics.
The Code of Ethics of COMSA CORPORACIÓN (henceforth the “Code”)
resumes the aforementioned principles and reveals the principle of due
diligence, applied by the Organization in a matter of ethics and integrity. The
Code does not modify or replace any of the regulations or policies existing in
the Organization.
The Code also reveals the expected behaviours of the directors and employees
of the Organization, as well as of their business partners, in those areas related
in the Spanish Criminal Code, after the reforms carried out in 2010 and 2015,
which the management considers more relevant, because of the characteristics
of the businesses in which it operates.
2. The due diligence in COMSA CORPORACIÓN
COMSA CORPORACIÓN understands the due diligence in the matter of ethics
and integrity as the joint activities and resources, directed to prevent, detect and
where appropriate, eradicate malpractices which might appear in the
Organization, being understood to be those the modus operandi of which are
inconsistent with the internal or external rules and regulations that the
Organization applies.
COMSA CORPORACIÓN understands that exercising the due diligence in
matters of ethics and integrity comprises diverse elements.

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Identifying risks
The Code of Ethics offers guidelines of behaviour in those matters of
ethics and integrity, whose level of risk, due to the aforementioned
characteristics of the Organization and businesses where it operates, is rather
high.
Allocation of responsibilities
The Board of Directors is, as a last resort, responsible for supervising the
effective fulfilment of the Code of Ethics of the Organization, as well as the
proceedings the Ethics Commission, set up for that purpose, without prejudice
to the management functions, entrusted in relation to knowledge,
comprehension and fulfilment of the Ethics Code by all the members of the
Organization,.
The implementation of commitments
The Code of Ethics of the Group reflects the commitments undertaken by the
Organization and by all its employees and directors, so far as ethics and
integrity are concerned.
Knowledge and understanding
COMSA CORPORACIÓN will allocate the necessary resources to ensure that
this Code, as well as the rules on which it rests, is known and understood by all
its employees and all those with whom it establishes relations.
Supervision and monitorization
The responsibility to look after the level of knowledge, comprehension and
fulfilment of the Ethics Code of the Organization has been assigned to the
Ethics Commission, insuring at the same time the adequate ethical functioning
of the Organization. Among these functions is the monitorization of the fulfilling
of the Code in the Organization and the regular report thereon delivered to the
Board of Directors.
The safekeeping
COMSA CORPORACIÓN has established a notification and consultation
procedure (channel) which supervised by the Ethics Commission allows the
employees of the Organization, to report, in good faith and safe of reprisals,

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irregular practices in matters covered by the Code of Ethics. All employees of
the Organization are bound to report malpractices which may come to their
notice.
The amendment of malpractices
COMSA CORPORACIÓN applies a zero tolerance policy in matters of ethics
and integrity. The infringements of the Code of Ethics which the Organization
may detect, will be analyzed according to internal regulations, applicable
covenants and if appropriate, legal regulations in force.
The continual improvement
COMSA CORPORACIÓN undertakes to develop its internal regulations, as the
case may be, to adapt them to the contents of this Code and to develop, if
necessary, the internal regulations that might be needed for the effective
implantation of the binding commitments.
3. Scope, acceptance and fulfilment
The principles of conduct contained in this Code of Ethics must be complied
with by all directors and employees (henceforth “persons” or “employees”) of
COMSA CORPORACIÓN and its corporate group, irrespective of the
contractual modality that determines the employment relation, position or the
place where she or he works.
COMSA CORPORACIÓN operates in various countries, consequently there
could be discrepancies as to the laws, local regulations and the Code of Ethics.
In these circumstances, the persons of COMSA CORPORACIÓN, shall apply
the strictest regulation, unless the Ethics Commission thinks otherwise.
COMSA CORPORACIÓN’s employees have the responsibility to know,
understand and meet the relevant regulations regarding their function, liability
and workplace. The Organization, for its part, will provide the necessary means
to increase their knowledge and understanding of the rules and regulations as
well as the most relevant legislation to carry out their professional duties.
In case of doubt, the employees shall have resource to their hierarchical
superior and the various media established by the Organization for the diffusion,
knowledge and observance of the principles of conduct established in the Code
of Ethics and in the norms on which it sustains.

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COMSA CORPORACIÓN expects to see from its employees a behaviour
aligned with the principles of conduct, gathered in this Code of Ethics and in the
underlying rules. Any employee may be appraised according to his fulfilment of
this Code.
Nobody, regardless of his position in the organization, is authorized to ask an
employee to infringe the rules established in this Code of Ethics. Similarly, no
employee of COMSA CORPORACIÓN may justify a malpractice on the grounds
of the order of a superior or the ignorance of the Code of Ethics.
Obligation to report
Breaches of the Code of Ethics undermine the reputation of the Organization
and may put at risk its soundness. Therefore, all employees are obliged to
report any malpractice they may witness. The obligation to report is extended to
all those cases in which irregular behaviours may be observed on behalf of
customers, suppliers, contractors or other collaborators of COMSA
CORPORACIÓN.
COMSA CORPORACIÓN provides different channels that its employees may
use to report irregularities regarding the matters contained in this Code of
Ethics. Persons infringing the provisions of this Code may be reported
according to the procedures of notification and consultation described in this
Code and will consequently be subject to the disciplinary regime in force with
the Organization.
4. Responsibilities
All persons employed by COMSA CORPORACIÓN have the obligation to know,
understand and observe the principles of conduct contained in the Code of
Ethics. Those persons having managerial responsibilities or teams
management responsibilities have additional responsibilities.
Common responsibilities
Everyone employed by COMSA CORPORACIÓN must:
 Know, understand and abide by the terms of the engagements and
principles outlined in the Code of Ethics, as well as the norms and
procedures that are applicable to the responsibilities that were assigned
to them.

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 Contribute to the knowledge, comprehension and fulfilment of the Code.
 Ask for help, in case of doubt.
 Report irregular conducts which may be observed regarding matters
contained in the Code.
 Provide assistance for the proper functioning of the internal control
systems set up by the Organization,
Responsibilities of those directing others
COMSA CORPORACIÓN’s employees who have been entrusted with
management responsibilities or who direct the work of others, have some
additional responsibilities with respect to the Code of Ethics:
 To collaborate in the knowledge, understanding of and compliance with
the Code of Ethics and the norms and procedures on which the latter
rests.
 To contribute in generating the adequate ethic tone in the Organization,
creating a working environment where the employees may know the
behaviour that is expected of them and act accordingly.
 To support those persons, respecting the confidentiality, who in good
faith convey their doubts or report irregularities in matters dealt with in
the Code of Ethics.
 To lead by example. Their behaviour shall be an example to follow in the
observance of the principles of conduct, gathered in the Code of Ethics.
5. Report irregular behaviours
The Organization provides the means, in order that its employees may comply
with and contribute to the compliance of the Code of Ethics, clearing their
doubts and reporting irregular conducts they may observe.
The Organization has established a procedure which allows any of its
employees to report confidentially, in good faith and without any fear of
reprisals, any irregular conduct in matters dealt with in the Code. Employees of
the Organization may also avail themselves of the procedure to consult doubts
or propose improvements in the internal control systems of the Organization in
the various matters dealt with in the Code or to point out risky conducts or
areas. The procedure is aligned with recommendation 42.1c) of the Código de
Buen Gobierno de las Sociedades Cotizadas [Good governance code of listed
companies] published in 2015.

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Employees shall pass on their messages referring to matters of the Code of
Ethics, confidentially, in good faith and without any fear of reprisals, to the
Ethics Commission through:
 Internet address: ComisiondeEtica@comsa.com
 Postal address: Letter addressed to The President of the Ethics
Commission of COMSA CORPORACIÓN, Viriato 47, 08014 Barcelona.
Reports about irregularities in matters of education, contained in the Code of
Ethics, will be carried forward by the Ethics Commission, who will determine
which department of COMSA CORPORACIÓN is the most adequate for its
resolution.
Reports shall have to be nominative and will be dealt confidentially.
Nevertheless, the fact that nominative complaints are furthered does not mean
that complaints or reports received anonymously shall not be taken into
consideration (which the Ethics Commission will have to assess in every
particular case). The data of the interveners may only be communicated in case
the denounced fact has prompted an intervention by the administrative or
judicial authorities and whenever the intervention of these authorities is
required; furthermore and in compliance with the organic law 15/1999, on the
protection of personal data and when applicable, the persons involved in any
later investigation or judicial proceedings, initiated as a consequence of the
investigation.
All reported irregularities will be analyzed and treated confidentially. COMSA
CORPORACIÓN will not tolerate reprisals committed against those persons
who avail themselves of established procedures to report irregular conduct.
The person’s right to honour is one of COMSA CORPORACIÓN’S maxims of
behaviour. Anybody of the Organization in charge of handling matters relative to
the Code of Ethics, shall pay utmost attention to ensure that right.
6. Expected behaviours
All persons employed by COMSA CORPORACIÓN shall perform their functions
on the basis of strict compliance with the internal and external norms which are
applied to the Organization and its activities. This is the basis of ethic behaviour
which is expected of all employees of the Organization.

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COMSA CORPORACIÓN’S activities and those of all its employees are carried
out respecting the human rights and public liberties, in accordance with the laws
and the internationally accepted practices. Among the standards that the
organization takes as a benchmark are the International Bill of Human Rights,
the fundamental conventions of the International Labour Organization (OIT) in
matters of labour or the OECD guidelines for multinational enterprises.
COMSA CORPORACIÓN takes steps to ensure compliance with labour
regulations contained in the basic conventions of the OIT, and will not tolerate
contrary practices, neither between the companies that make up the group nor
those that collaborate with it.
COMSA CORPORACIÓN’s employees shall observe, under all circumstances,
an ethic behaviour, avoiding a behaviour that could contravene the applicable
regulations, harm the reputation of the Organization or affect negatively its
public image. Neither will they collaborate with third parties in activities that
could breach the law or harm the confidence that third parties have in the
Organization.
All COMSA CORPORACIÓN’s employees must be familiarized with the laws
and regulations that are relevant for their professional activities and, in case of
doubt, should require the necessary advice by the units of the Organization that
specialize in the different matters.
The Organization undertakes to make available to the employees, the means
required for the knowledge and understanding of the internal and external
norms, which may be most relevant, considering their scope of responsibility.
6.2 Internal control, fraud prevention and illicit actions
Fraud is any deliberate and intentional action, committed by an employee or
third person in order to obtain a benefit for himself or for the Organization,
directly or indirectly, and to use to this end, inappropriately, any information,
asset or resource of the Organization.
As far as the computerized media are concerned and in compliance with the
Document of Security of the Organization, and as far as those are placed at the
disposal of the employees for a strictly professional and occupational use, they
do not constitute a reserved space, accordingly COMSA CORPORACIÓN may
access and audit these equipments and data processing devices, in order to
verify and control their adequate use.

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COMSA CORPORACIÓN provides its employees with the resources they need
to carry out adequately their professional activity. The assets of COMSA
CORPORACIÓN include physical goods, confidential or proprietary information
and intellectual property rights.
Misappropriation and inappropriate use of the Organization’s assets constitute a
fraud.
Employees have to protect and make good use of COMSA CORPORACIÓN’s
resources and assets, using them in a responsible way to preserve them from
damage, loss, theft or inadequate use. The resources of the Organization have
to be used exclusively for the discharge of the professional functions to which
they were assigned.
The obligation to protect the resources includes also the information and the
generated knowledge within the Organization, of its property or custody.
Likewise, all employees of the Organization have to comply with current
legislation in matters of data protection. COMSA CORPORACIÓN’s employees
commit themselves to maintain the confidentiality and to make a discreet use, in
accordance with the internal regulations of the matter, of the information they
may access in the discharge of their professional obligations.
In case of doubt and unless they receive other indications, the information that
COMSA CORPORACIÓN’s employees may access in the performance of their
functions, shall be considered confidential.
On the other hand, COMSA CORPORACIÓN undertakes to offer its employees
the information, knowledge and resources that are necessary to carry out the
dispositions of the rules and regulations in matters of data protection and
information management, that are applicable in their different areas of activity.
Finally, the name and trademark “COMSA CORPORACIÓN” is a distinguishing
mark and the behaviour of its directors and employees has to be concerned
with the preservation and protection of this asset. Under no circumstances shall
the employees of the Organization use the electronic means placed at their
disposition, to distribute or access subject-matter for adults or incur criminal
conducts. Neither shall they use funds or cards of the Organization in order to
defray inappropriate or criminal practices, relative to the matters previously
exposed or any other.

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Internal control of information
Falsification, manipulation or deliberate use of false information, constitute
fraud.
In line with the provisions established in the recommendations of the National
Stock Exchange Commission (CNMV), regarding the internal control of the
financial information in the listed companies, COMSA CORPORACIÓN
assumes as a principle of behaviour, the transparency and reliability of the
financial information and the fulfilment of the applicable rules and regulations.
Employees must transmit this information truthfully, completely and
understandably. In no case shall they knowingly provide incorrect, inexact or
imprecise information, which could mislead the person receiving it.
All transactions, facts and events of the Organization must be reflected clearly
and precisely and according to the applicable regulation, in the registers of the
Organization. Likewise, these registers must reflect the transactions, facts and
events of the Organization entirely.
Likewise, the Board of Directors of COMSA CORPORACIÓN and the whole of
its employees undertake to warrant the periodic supervision, of the efficiency of
the system of internal control of the making of the financial information.
COMSA CORPORACIÓN’s employees shall reflect in the registers of the
Organization, clearly and precisely, the transactions, facts and events and shall
pay particular attention to the reliability of the financial information introduced in
the systems of the Organization and its branches, thus reflecting on the
corresponding date, the rights and obligations through the corresponding assets
and liabilities, pursuant to the applicable rules and regulations.
Should the employees of the Organization observe any circumstances, which
according to their true knowledge and understanding imply a breach of the
principles of behaviour mentioned, they shall inform the management of the
Organization through the media established for that purpose.
COMSA CORPORACIÓN undertakes to place at the disposal of its employees
the instructions that may be necessary to know, understand and comply with
the engagements entered into by the Organization, regarding the internal
control of the financial information.

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Any publicly made communication or observation about the activities of the
Organization shall be made exclusively through an authorized spokesman.
Corruption and bribery
Under no circumstances shall the persons of the COMSA CORPORACIÓN
resort to unethical practices, in order to influence the will of the persons outside
the Organization, with the aim to obtain some benefit for the Organization or for
themselves. Likewise, they shall stay alert to avoid that third parties avail
themselves of these practices concerning COMSA CORPORACIÓN.
The Organization plainly prohibits payments or undue attentions to any person
or entity, public or private, with the intention to obtain or maintain businesses or
other benefits or advantages. COMSA CORPORACIÓN’s employees may not
make, offer or receive, directly or indirectly, any profit, gift or present in cash,
not even as a loan or advance payment. Neither are they allowed to make, offer
or receive, directly or indirectly, any other benefit, hospitality, gift or present,
which considering its value, characteristics or its circumstances, could
reasonably alter the development of their commercial, administrative or
professional relations.
This way, gifts and attentions shall only be received or given, when their
economic value is irrelevant or token, when they respond to signs of courtesy or
current commercial attentions and are not prohibited by law or generally
accepted commercial practices. Similarly, gifts and attentions received or given
should be sporadic and not regular, unless the regularity would create
suspicions as to the ultimate purpose.
In any case, COMSA CORPORACIÓN people shall ensure not only that the
gifts and attentions to third parties are proportionate, reasonable, transparent
and legitimate, but also that they are monitored, evaluated and registered
appropriately in the books of the Company. As the gifts or presents of third
parties to managers, directors or employees of the Organization are concerned,
whenever doubts arise as to whether it is acceptable or not, the offer must be
declined, or in any case, consulted with the hierarchical superior. When the
value of said presents, gifts or attentions surpasses [150] Euros, its acceptance
must be approved by the Ethics Commission.
Likewise, employees shall refrain from making payments for the facilitation or
streamlining of procedures, which would consist in handing over money or other
things of value, whatever the amount, in exchange for insuring or speeding up

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the course of a proceeding in a judicial organ, public administration or official
organism, in any part of the world.
Payment irregularities
COMSA CORPORACIÓN’s employees shall have to pay special attention to
those cases in which evidence of lack of integrity could exist in persons or
entities with which the Organization maintains relations.
In particular, employees of COMSA CORPORACIÓN shall avoid, as a rule,
payments in cash which are unusual, made with cheques to the bearer or made
in foreign currency, different from the one previously agreed upon. They shall
also avoid payments made to or by third parties not mentioned in the
corresponding agreements, as well as those made to accounts which are not
the usual ones in their relations with a certain entity, Organization or person and
revise with special attention those payments that were not foreseen in the
corresponding agreements or contracts.
They shall also pay attention to payments made to persons, companies, entities
or accounts opened in tax havens and those payments made to entities where
the partner, owner or ultimate beneficiary cannot be identified.
6.3 Conflicts of interests and loyalty to the Organization
COMSA CORPORACIÓN’s employees must behave with loyalty to the
Organization, in correspondence to the confidence placed in them.
Conflicts of interest appear when the interests of the employees are not aligned
with those of COMSA CORPORACIÓN, when they interfere with their
obligations or make them act by motivations which differ from the fulfilling of the
responsibilities assigned to them.
The relationship between COMSA CORPORACIÓN and its employees must be
based on the loyalty that arises from common interests. In this regard, the
Organization respects the participation of its employees in other financial or
entrepreneurial activities, as long as the internal regulations do not provide
otherwise, that the activities are legal and that they do not enter into competition
with the regulations or originate possible conflicts of interest with their
responsibilities as employees and that they are communicated at the proper
time to the management of the Organization.

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Employees shall avoid situations which may create a conflict between their
personal interests and those of the Organization. They shall also refrain from
representing the Organization, or influence their decision making when they
themselves or a close third party has a personal interest in the matter.
No employee shall render services as a consultant, advisor, director, employee
or adjuster to a competitor of the Organization, except those services which
could be rendered at the request of COMSA CORPORACIÓN or with its
authorization.
All employees are required to communicate to their immediate superiors those
circumstances from which a conflict of interest might reasonably arise.
COMSA CORPORACIÓN’s employees and directors are not allowed to
participate in external activities which may have a negative impact in the
execution of their work or that may reflect negatively in the business, image and
reputation of the Organization.
Purveyors, customers and market
Those employees of COMSA CORPORACIÓN that participate in processes of
selection of external purveyors, contactors or collaborators, are required to act
impartially and objectively, adopting the criteria that the Organization adopts in
the selection of them. Similarly, employees are required to take reasonable
steps and act with diligence to avoid acquiring material of dubious origin and
shall exercise the due control to avoid that foreign workers could be hired
illegally.
Employees of the Organization shall keep an eye on the respect of their image
and reputation accorded by contractors and suppliers and, in general,
collaborating firms and shall avoid undue influences in the processes of
selection and contracting.
COMSA CORPORACIÓN will compete fairly in the marketplace, their
employees committing themselves to make business in an honourable way and
not take part in activities that suppose unfair competition, including misleading,
inaccurate or ill-disposed information about competitors. Likewise, employees
shall avoid any form of deceitful, fraudulent or wicked conduct that would lead to
obtaining inappropriate advantages over customers, suppliers or competitors. In
particular, employees shall use their best endeavours to secure that the
conditions established in the contracts and in the adequate working of the

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measuring instruments will be observed, in order to avoid that their manipulation
could prompt an inadequate treatment of customers.
In the course of their commercial activities, employees shall promote the
products and services of the Organization in accordance of their quality and on
the basis of objective standards, without discrediting the competition in any
case or giving false information about the same.
They shall also ensure that subsidies received by public administrations receive
an adequate use and that their request follows transparent criteria, avoiding
falseness of the conditions for receiving them or giving them an inadequate use.
Market research or search about companies of the sector by COMSA
CORPORACIÓN’s employees shall always be carried out in an ethical way and
according to the rules which protect that type of information. Employees of the
Organization shall refuse to obtain data in an inadmissible way or violating the
confidentiality in which they are kept by their legitimate owners. They shall, in
particular, take special care not to violate company secrets in case of in
CORPORACIÓN of professionals from other companies.
COMSA CORPORACIÓN shall comply with antitrust rules, avoiding any
conduct that constitutes or could constitute collusion, abuse or restriction of the
competition.
COMSA CORPORACIÓN will place at the disposal of its customers, purveyors,
contractors and collaborating companies, the contents and principles of this
Code of Ethics. Particularly those contents which establish the compromises of
conduct assumed with third parties by the employees of the Organization.
6.4 Persons
At COMSA CORPORACIÓN and its group of companies, the management of
human resources and the relations between the employees always start from
the scrupulous respect of the dignity and the rights of the persons.
Persons belonging to COMSA CORPORACIÓN must treat themselves in a
respectful, professional and kind way in order to generate a pleasant, gratifying
and secure working atmosphere that enlivens the persons to do their best. The
relations between COMSA CORPORACIÓN’s employees and their purveyors,
contractors and collaborating companies shall be equally based on professional
respect and mutual collaboration.

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Persons belonging to COMSA CORPORACIÓN shall avoid and refuse
expressly the abuse of authority and any kind of physical, psychological or
moral harassment, as well as any other conduct that can create an intimidating,
offensive or hostile working atmosphere.
In the same way, persons belonging to COMSA CORPORACIÓN shall remain
alert and shall exert due control to avoid circumstances in which foreign workers
could be hired illegally, both in the Organization and along the chain of supply in
purveyors, contractors and other collaborating companies.
COMSA CORPORACIÓN’s employees shall remain alert to avoid that there
may be circumstances in which workers would work in an irregular way for the
Organization, that the paysheets do not reflect the corresponding collective
wage agreement or that they contain erroneous wage components.
Equal opportunities, development and culture of merit
COMSA CORPORACIÓN’s employees do not tolerate discrimination for reason
of gender, race, sexual orientation, religious beliefs, political opinions,
nationality, social origin, disability or any other characteristic that could originate
discrimination.
Decisions of selection and promotion in the Organization are based on the merit
and in circumstances and valuations of an objective and transparent character.
Employees of the Group will know the methodologies and procedures used for
the development and professional advancement in the Group.
COMSA CORPORACIÓN undertakes to provide the means to contribute to the
apprenticeship and the formation of its employees and to the actualization of
their knowledge and competence, in order to favour their professional progress
and maximize their contribution of value in favour of customers, shareholders
and the company in general.
Teamwork
Collaboration and teamwork are prerequisites for COMSA CORPORACIÓN to
achieve its goals and to optimise the available capacities, resources and
diversity of knowledge, talents and experiences which form the Organization,
The Organization promotes, facilitates and motivates the collaboration and the
teamwork, irrespective of the unit or business in which the persons perform their
activity.

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All employees shall show spirit of collaboration, providing help by offering their
knowledge, skills and talents to those who are in demand of it, thus contributing
to the achievement of the goals and global interests of the Organization.
This way COMSA CORPORACIÓN’s employees work efficiently, optimizing the
use of their time and resources which the Organization places at their disposal.
Health and safety of the persons
With regard to health and safety, the commitment of the COMSA
CORPORACIÓN starts with the scrupulous fulfilment of the applicable rules and
regulations wherever the company acts, in order to offer its employees a safe
and healthy working environment. Likewise, the Organization shall improve
continuously the measures of prevention of occupational risks and the
promotion of working health measures, in every place and sector where it
operates.
COMSA CORPORACIÓN also promotes and stimulates the adoption of
advanced practices in matters of safety and health among its purveyors,
contractors and, in general, collaborating enterprises.
All employees of the Organization have to comply at work rigorously with the
rules and regulations of health and safety, ensuring their own security and, in
general, that of all the persons that might be affected by their activities.
Likewise, they shall use in a responsible way the equipment they have got
assigned, when they carry out risky operations and disseminate the knowledge
and practices in matters of safety, health and prevention of risks to their
workmates.
On the other hand, the Organization undertakes to equip the staff with the
necessary resources and knowledge for the performance of their functions in
safety and in a healthy environment.
6.5 Social and environmental commitment
COMSA CORPORACIÓN faces its environmental commitment from the strict
fulfilment of the applicable legislation in the whole range of operations in the
matter. The Organization operates with the utmost respect for the environment,
while minimizing the negative effects that could arise.
To that effect, it will establish the best practices and promote among the
employees the necessary formation, in order to preserve the environment. In its

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relations with contractors, purveyors or collaborating external enterprises, it will
transmit these principles and will exact the fulfilment of the procedures and
environmental requisites that may be applicable in each case and provide the
means to insure the adequate fulfilment of the same.
In this regard, the Organization undertakes to correct the inadequate
environmental behaviours or those that are not committed to the care of the
environment.
The Organization makes a continuous effort to identify, characterize and
minimize the environmental impact of its activities and puts its faith in the
efficiency, the responsible consumption, the protection of the biodiversity and of
the natural environment. All persons of the Organization share their
environmental commitment.
COMSA CORPORACIÓN’s commitment to society materialises in the
development of sponsorship activities, patronage and social action. The
Organization shall only support organizations with an impeccable reputation that
guarantee the sound use of the resources. All donations need to be reflected
accurately as such, in the registers of the Organization.
7. Aid and information
The Code of Ethics collects the expected patterns of behaviour of the persons
that are a part of COMSA CORPORACIÓN.
In case of doubt, employees may obtain from their immediate hierarchical
superior or from the instance which has been assigned to insure compliance
with the Code. They may also, through the mechanism described in point 5 of
this code, report those irregular behaviours, they may observe.
In case the employees need specific advice regarding the subjects included in
this Code, they may also have recourse to the units and departments which
specialize in these matters.
8. Duration of the Code of Ethics
The COMSA CORPORACIÓN Code of Ethics shall take effect from the moment
it is adopted by the Board of Directors and shall be applicable as long as it is
not updated, revised or repealed.

19
May19th
, 2017
The Code will be revised and updated according to the instructions of the Board
of Directors. The possible revisions and the updating shall comply with the
commitments acquired by COMSA CORPORACIÓN in matters of ethic, good
management and the new commitments emerging at the regulatory ambit.

Code of Ethics of COMSA Corporación

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Code of Ethics of COMSA Corporación