Code of Ethics and Principles of Actions

Altano Energy, by means of this Code (henceforth, “the Code”), states the values and ethical principles that inspire its performance and that must govern the activity of all employees, managers, and members of the governing bodies.

The internal policies and procedures of Altano Energy must adapt their content to the values and principles of action contained in this Code.

This Code will be available to all employees of Altano Energy and new recruits will be handed a copy at the time of hiring for compliance. The new employees shall deliver acknowledgement or reception, reading and understanding of the Code.

This Code is applicable to all entities, employees, managers, and members of the governing bodies of Altano Energy (henceforth, “Subject Persons”). All of them must know and comply with the Code. Likewise, the values and principles set forth in this Code shall be transmitted, as far as possible, to the different suppliers so that they are implemented throughout their relations with the Altano Energy´s entities.

All Subject Persons, bound by the Code regarding their professional activities, shall comply with the values, principles and rules contained in it, in their professional activity, in their internal professional relations with the Altano Energy´s entities and in their external relations with public authorities, suppliers, and society in general.

As established in the Worker’s Statute and in the Collective Agreement applicable, infractions contained in the Code can be sanctioned.

Finally, Subject Persons must cooperate with any internal or external investigation or audit, conducted by Altano Energy.

The performance of Altano Energy, and therefore of the Subject Persons, shall be governed by some basic activity pillars:

• To assume the commitment to perform business and professional activities in accordance with current legislation from each of the places where they are executed.

• Protect the reputation of Altano Energy by being an example of ethics, rigor, professionalism, and honesty.

• Apply a homogeneous ethics and compliance model based on due control for the prevention, detection, and eradication of irregular conducts, including an adequate evaluation of the ethics and compliance models of third parties with whom we maintain business relations with.

• Report any incident or irregularity known through the enabled channel.

Compliance with the law, respect, integrity, transparency, excellence, professionalism, and social responsibility are the core ethical values of Altano Energy.

COMPLIANCE WITH THE LAW

All Subject Persons, subject to the Code must comply with the law and regulations in force (Laws, Regulations, etc.) as well as with any internal rules or policies of Altano Energy.

All Subject Persons must strictly comply with the politics that developed by the Criminal Prevention Model of Altano Energy and thus prevent, detect, avoid and, when appropriate, report the possible commission of crimes.

Altano Energy strictly rejects any conduct of an illicit or criminal nature or any conduct that implies the breach of internal regulations under the premise that it is acting in favor of some of Altano Energy´s entities, regardless of the possible economic benefit generated.

The Subject Persons shall always act in a lawful, ethical, and professional manner, complying in any case with the law, regulations, and other legally binding rules throughout the performance of their duties. The principles of action and the reputation of Altano Energy must not be compromised.

Additionally, the Subject Persons are obliged to collaborate with Altano Energy actively and diligently, following the instructions received, in the defense of the interests of Altano Energy before any judicial, arbitration and/or administrative instance.

Particularly, it is mandatory to appear before any judicial, administrative and/or arbitration bodies when a direct subpoena is received from the aforementioned bodies,

either at the personal or professional domicile or when requested by Altano Energy. Likewise, it is compulsory to collaborate with Altano Energy, when requested, to prepare and/or attend an appearance or statement in any process.

RESPECT

Respect for the individual

Altano Energy assumes as a fundamental value of its performance the respect for the individual and his or her dignity. Specifically, it prohibits any discrimination, harassment, abuse, or inappropriate treatment of any kind. Altano Energy will interact with the Subject Persons and, in general, with any person interacting with Altano Energy, in a fair manner, regardless of gender, gender identity, ethnicity, color, nationality, creed, religion, political opinion, affiliation, age, sexual orientation, status, disability, incapacity and other situations protected by law.

Altano Energy will maintain a work environment free of harassment, intimidation and offensive or improper behavior, and rejects any sexual proposal or suggestion and any action that may offend the dignity of the individual.

Altano Energy will promote the work-life balance of the people who are part the Energy, as well as equal opportunities among employees based on meritocracy and in accordance with the law.

Altano Energy takes its responsibility for the health and safety of employees in the workplace very seriously. At the same time, employees themselves are also obliged to always take care. Anyone who plans ahead and assesses the risks for themselves, and their colleagues makes a considerable contribution to ensuring that work conditions are safer. Altano Energy has a Health, Safety and Environmental (“HSE”) Policy which provides an overview of the approach of Altano Energy to manage HSE risks across the organization.

Respect for political pluralism

Altano Energy respects political pluralism and, consequently, all their activity shall be governed by the principle of political neutrality.

Any link, membership, or collaboration of the Subject Persons with political parties or other types of entities, institutions or associations with public purposes must be carried out making clear its personal nature, avoiding involving or compromising the name, corporate image, or the legitimate interests of Altano Energy.

Respect for the environment

Altano Energy and its member companies are committed to the preservation of the environment, respecting the current legislation in this matter for each case and adopting procedures to reduce the environmental impact of their activities. Through its business activities, Altano Energy seeks to promote the transition to net-zero through providing a source of renewable energy.

Altano Energy complies with all applicable environmental regulations. Altano Energy obtains all necessary permits and licenses in good time and ensures that any requirements or necessary conditions are met. Employees are encouraged to actively assist in improving all existing environmental protection measures. Environmental protection is the duty and objective of the company and each individual employee. Altano Energy has a Health, Safety and Environmental (“HSE”) Policy which provides an overview of the approach of Altano Energy to manage HSE risks across the organization.

INTEGRITY

All Subject Persons have the obligation to promote the interests of Altano Energy and the prohibition to personally benefit or to benefit third parties from opportunities that arise within the course of their professional activity or through the use of assets or information of Altano Energy.

Altano Energy has an Anti-Corruption Policy that establishes a series of standards of conduct, among which are those regarding the acceptance and granting of gifts and travel and hospitality expenses.

Fair competition is a fundamental part of Altano Energy’s business. Each employee is obliged to comply with the rules of fair competition. Infringements may lead to severe penalties and fines, not only for the company concerned but also for the people involved. Altano Energy shall never enter into agreements with competitors which are intended to distort or influence competition.

No employee shall under any circumstances enter into an agreement or understanding with any competitor concerning prices, discounts, other terms or conditions of sale, profits or profit margins, costs, geographic markets, limitations on production, boycotts of customers or suppliers, or bids or the intent to bid or even discuss or exchange information on these subjects. These prohibitions are absolute and strict observance is required. Collusion among competitors is illegal, and the consequences of any violation shall be severe.

An essential part of integrity is the respect for the properties and assets of Altano Energy, which may only be used for their proper and legitimate purposes within the scope of Altano Energy.

The rules for the use of assets must be followed in accordance with the relevant provisions of Altano Energy’s Human Resources Manual. No software that is not approved beforehand by Altano Energy may be used on the terminals of the entities.

Finally, it should be noted that Altano Energy´s reputation depends, among other things, on the perception it manages to generate in society, through the activity carried out by Altano Energy in all its spheres and on the conduct of the Subject Persons. In the exercise of private activities, the name or image of Altano Energy shall not be involved or used, especially if they may have a public repercussion through the media or social networks.

Altano Energy rejects any practice in any situation that contravenes the values and principles of action in which the conduct of the Subject Persons may be related to Altano Energy.

TRANSPARENCY

Altano Energy emphasizes transparency within the society as a fundamental value of its activity.

In order to comply with its statutory accounting obligations and contractual reporting obligations, Altano Energy must ensure all business transactions are documented completely, accurately, truthfully and using the right systems, and accurately and timely forwarded to the competent authorities.

Specifically, in its relationship with business partners and suppliers, Altano Energy will enter into contracts without any attachment or interference outside the interests of Altano Energy. When working with business partners or other parties, Altano Energy always bases its partnership on written/textual contracts or agreements to ensure that there is legal protection and clarity. Changeable parts of contracts such as product specifications, prices and supplementary agreements are also set out in writing/in text form and signed in accordance with legal and internal requirements without any exceptions.

Altano Energy engages with suppliers based on need, quality, sustainability, service, price and terms and conditions. Notwithstanding economic and technical conditions, collaborative relations with suppliers should generate value for both parties. The purchase of goods or the contracting of services must be carried out with objectivity and transparency, avoiding situations that could affect the objectivity of the persons who participate in them, so they will be made without any economic, friendship or family ties with the supplier. Under no circumstances should any employee, agent or contractor attempt to coerce suppliers in any way. The confidential information of a supplier is entitled to the same protection as that of any other third party and must not be received before an appropriate nondisclosure agreement has been signed.

A supplier is generally free to sell its products or services to any other party, including competitors of Altano Energy. In some cases where the products or services have been designed, fabricated, or developed to Altano Energy’s specifications, the agreement between the parties may contain restrictions on sales.

EXCELLENCE AND PROFESIONALISM

One of the main assets of Altano Energy is the people who integrate it and the values and principles that motivate them. Altano Energy will respect and promote diversity, valuing the capabilities and contributions of each person.

As a team, Altano Energy is guided by a sense of commitment, dedication, and excellence.

SOCIAL RESPONSABILITY

For Altano Energy it is essential to integrate in its objectives, apart from an economic benefit, respect for human rights, equal opportunities, and environmental sustainability. The aim is to maximize the creation of long-term relations based on trust and transparency.

Altano Energy will manage the business and its activities within the scope of its commitment to respect the environment and individuals. In a coherent manner, it will support more environmentally friendly initiatives and projects.

In order to facilitate compliance with this Code of Ethics and the other internal policies related to it, Altano Energy has a Whistleblower Channel through which doubts can be raised about its interpretation or practical application, and to report any irregularities which may involve infringements.

Consultations and complaints are handled and resolved using a rigorous, transparent, and objective procedure, maintaining in all cases the confidentiality of the persons concerned and involved in the conduct that is communicated.

Altano Energy will not tolerate any retaliation against anyone who, in good faith, communicates facts or situations that could be catalogued within the conduct prohibited by this Code of Ethics. In this sense, Altano Energy will work continuously to always develop communication channels with best practices.

The Channel is accessible through the following e-mail: altano.compliance@altanoenergy.com.

This Code of Ethics and Principles of Actions has been approved by Altano Energy’s Managing Directors on 16 November 2023 and ratified by the Board of Directors on 29th of November of 2023.