The Anti-Corruption Policy of ABSTI S.A. embraces the following principles.

GENERAL PRINCIPLES.

1 - In accordance with the provisions, all corrupt practices are prohibited, without exception.

2 - It is specifically prohibited to offer, promise, pay, deliver or authorize delivery, or accept, claim or request, directly or indirectly, compensation, gifts, personal or other economic benefits to / Of Public Officials, Private Persons, or the entity that they directly or indirectly represent, to influence an official or business decision or to obtain or retain a business or any other advantage, when:

- 2.1. are not of modest value, that is to say that they exceed the reasonably accepted limits in the courtesies of practice or;

- 2.2. It may be considered that they intend to exert an inappropriate influence on the relationships that the Companies maintain with Public Officials, Private Persons, or the entity that, directly or indirectly, they represent, regardless of whether there is actually an improper purpose.

3 - The “Facilitation Payments” (that is, unofficial payments of modest value, made in order to facilitate, expedite or get a routine government act or activity to be carried out that is generally considered among the obligations in charge of Public Officials or Private Persons with whom the Companies relate) are prohibited.

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