I. Scope of the code of ethics

The Code of Ethics (hereinafter, the “Code”) contains the catalogue of rules of conduct and general guidelines for action that must govern the behaviour of all employees of GADISA GROUP (hereinafter “GADISA GROUP” or “the GROUP”). For the purposes of this Code, GADISA GROUP is understood to mean the companies and business groups with their respective companies listed below:

• Galician Food Distributors, S.A.
• Gadisa Retail Business Group:
• Gadisa Retail, SLU
• Mercartabria, SLU
• Pontevicus, SLU
• Lucus Market, SLU
• Atlantic Saga Ourense, SLU
• Ecomas Supermarkets, S.L.
• Hypermarkets and Grocery Stores, SAU
• Ezequiel Arribas, SAU
• Pescarmar, SLU
• Mountain View Invest, SLU
• Atlantic Corporate Real Estate 2008, SLU
• INTASA Business Group:
• Board Industries, S.A.
• Madeiras do Xurés, SLU
• Union of Timber Companies, SA
• Eume Maderas, SL
• Piadela Cogeneration Services, SA
• Atlantic Forestry Business Group and Imegasa:
• Atlantic Forestry, S.A.
• Galician Melanimic Impregnations, SAU
• Transport Business Group:
• Piadela Transport, S.L.
• Services Polígono Piadela, SL
• Piadela Food Services, SA
• Tojeiro Transports, S.A.
• Mugardos Cisterns, SLU
• Trapi 2023, SLU

Subject persons

This Code applies to all companies and corporations dependent on the GADISA GROUP. Likewise, and without exception, to all persons in the GROUP regardless of the position and function they occupy, and specifically to:

➢ The General Directors of the companies referred to and the Management.

➢ The Boards of Directors of all GADISA GROUP companies.

➢ Employees of all GADISA GROUP companies, including trainees.

Compliance must also be promoted among external collaborators and suppliers in any operations they carry out with the GADISA GROUP.

These people will be referred to hereinafter as "Subject to the Code".

Obligation to know and comply with the Code

Those Subject to the Code have the obligation to know and comply with the Code and to collaborate to facilitate its implementation in the GADISA GROUP, including the communication of any infringement of the same that they are aware of to the Supervision and Control bodies, as regulated in the GADISA GROUP Compliance Manual.

Goals

The purpose of this Code is to provide the GADISA GROUP and its employees with a fundamental instrument that serves as a pillar for its actions and establishes the principles of conduct to be observed both in professional development and in the relations of the GROUP with its employees, clients, suppliers, collaborators, public administrations and society in general.

Scope

The principles of conduct contained in this Code establish a catalogue of guidelines for action that guide GADISA GROUP personnel during the performance of their professional activity, based on the values and vision of the GROUP, its corporate strategy, its commitment to both clients and third-party collaborators, companies in the sector and society.

II. Mission, vision and values

Mission

Through the application of this Code, GRUPO GADISA aims to establish an ethical-business framework of reference that contributes to strengthening trust in relationships with clients, suppliers, interest groups and the companies that comprise it, so that GRUPO GADISA becomes one of the reference entities in ethical-business behavior within its sectors of activity.

Vision

GRUPO GADISA is concerned about the innovation of its products, environmental sustainability, transparency in management, and support for society and disadvantaged groups.

Values

• Closeness:GRUPO GADISA is committed to its philosophy of customer proximity, honesty and dedication to service, in order to better satisfy the needs of its customers by offering them a professional service and the best quality-price ratio.
• Quality:The GROUP is based on top quality products. Beyond its food distribution activity, GRUPO GADISA meets the highest standards in the rest of its industrial processes.
• Environmental sustainability:GADISA GROUP promotes the continuity of its activities over time, reinforcing its commitment to environmental protection and social well-being, especially in the communities where it operates. For this reason, the GROUP develops actions aimed at improving efficiency in its logistics, industrial processes and points of sale, promoting recycling and reuse..
• Transparency in management:Within GRUPO GADISA there is a clear commitment to the importance of managing the activity from an ethical and responsible model, based on the principles of good governance, which is accountable with transparency..
• Corporate Social Responsibility: GRUPO GADISA maintains a firm commitment to the needs of the society around us, which translates into a significant commitment to social, economic and cultural development.
• Compliance with the Law: Respect for the environment in which we operate, through compliance with applicable laws and regulations, based on the highest ethical standards and worrying about the consequences that decisions may have on the people around us.
• Creating wealth under decent conditions: Since its inception, GADISA GROUP has set out to create wealth in decent social conditions, improving the quality of life of customers, employees, suppliers and society in general. The GROUP is aware of human value as a fundamental part of the success of the organization and, therefore, the contribution to society is part of the GROUP's philosophy.
• Continuous improvement: GRUPO GADISA promotes the development and retention of talent and knowledge, in order to carry out its activities efficiently and reliably.
• Innovation: Constant innovation is a distinctive sign of GRUPO GADISA..

Guidelines for identifying unethical behavior

Those Subjects to the Code who have doubts as to whether a particular action conforms or not to the GROUP's ethical model may consult their doubts with their hierarchical superior or with the Supervisory and Control bodies.

III. General guidelines of the Code of Ethics

The general guidelines of the Code of Ethics constitute the pillars on which the activity of GADISA GROUP is based. These principles are the subject of specific development for the area of criminal risk prevention in the GADISA GROUP Criminal Risk Prevention Manual.

• Equal opportunities and non-discrimination

GADISA GROUP offers equal opportunities in access to work and professional promotion, promoting a corporate culture based on merit. At GADISA GROUP, people are hired based on their skills, abilities, experience and capacity. Discrimination based on gender, ethnic, national, cultural or social origin, marital status, sexual orientation, religious or political beliefs is not permitted.

• Respect for people in professional relationships within the GADISA GROUP

The GROUP's human resources are a key factor for business growth and success, so the GADISA GROUP, all those Subject to the Code and, especially, those who perform management functions, will promote relationships based on respect for others and reciprocal collaboration.

Conduct such as harassment, sexual harassment, abuse, intimidation, disrespect, violence, threatening behavior, harassment or stalking, intrusion into personal or family privacy or any type of aggression or attack on dignity or integrity in professional relationships within the GADISA GROUP is prohibited.

• Work-life balance

In order to develop the commitment of GRUPO GADISA to improving the quality of life of its employees, the subjects of the Code will promote a work environment compatible with personal development, encouraging the people in their teams to reconcile the performance of their professional activity in GRUPO GADISA with the needs of their personal and family life.

• Collective rights

The relationship with representative workers' organizations will be based on mutual respect in order to promote a climate of dialogue and transparency.

• Occupational risk prevention, employee health and safety

GADISA GROUP has developed the protection of its companies in terms of occupational risk prevention based on the activity carried out by each one, in addition to a plan for preventive activity, which includes all prevention matters that must be undertaken in the exercise of continuous improvement.

• Food safety and quality of the products offered

GADISA GROUP, within its activity in the food sector, provides food of the highest quality, which passes all the necessary health controls and standards.

In this sense, the GROUP is committed to offering high-quality food products, respecting the regulations regarding safety, food preservation and product expiration dates, carrying out exhaustive control of all processes in terms of food safety and health.

• Environmental protection

GRUPO GADISA carries out its activity according to the principles and criteria of sustainability and environmental protection, with the proper management of its resources being a priority. Specifically, through the following actions:

• I respect the environment, making rational use of natural resources.
• Promoting the sustainable use of raw materials and energy resources.
• Compliance with current environmental legislation and, where applicable, voluntarily accepted commitments.
• Collaboration with the competent Administrations and Organizations.

• Compliance with regulations and ethical behavior

All those Subject to the Code shall act at all times in strict compliance with current legislation, as well as the internal procedures of the GADISA GROUP applicable to their activities.

Those Subject to the Code shall inform the company, through the corresponding hierarchical channels, of any conduct contrary to the law, human rights or ethical values promulgated by this Code.

Persons subject to the Code of Ethics may not give or accept gifts that may influence decision-making; exceptionally, they will be permitted when the following circumstances occur simultaneously:

1. Whether they are of irrelevant economic value, symbolic or propaganda objects of little value.
2. Respond to signs of courtesy or usual business courtesies
3. They are delivered or received in a transparent and occasional manner
4. Not prohibited by law or generally accepted business practices

If they do not meet these requirements, they must be rejected or returned.

• Confidentiality of information

All employees subject to this code are obliged to protect confidential or reserved information that they are aware of by reason of their position - whether technical, financial, commercial or of any other nature - and not use it outside the scope of their employment relationship, nor disclose it to third parties without the prior written consent of the company, except for those requests for information that are required by judicial or administrative authority in legal terms.

Those employees who, due to their high responsibilities, have access to particularly sensitive information may be required by the Company to sign specific confidentiality agreements as an Annex to their main employment contract.

The Company will guarantee its employees, suppliers, clients and anyone with whom it has a relationship faithful compliance with the data protection regulations, adopting the pertinent measures in its Organization so that said regulations are fully effective.

• Integrity in dealing with customers and suppliers

Those subject to the Code have the obligation to treat all GROUP clients and suppliers with fairness and integrity, working to understand and satisfy their needs based on high standards of quality and demand.

IV. External relations

1. Supplier relations

The relationship with GRUPO GADISA suppliers is based on mutual conditions of seriousness, rigor and respect, and ensures effective collaboration for both parties.

This relationship is configured as a key element in achieving the objectives of GRUPO GADISA, such that, in any case, an ethical and lawful relationship with suppliers of goods and services must be promoted.

2. Customer relations

All efforts of GADISA GROUP are directed towards providing a better service to its customers. This leads the GROUP to a permanent adaptation of assortments, families and lines, introducing new references, always under the highest quality parameters.

In the industrial sectors of activity, GRUPO GADISA is committed to the highest quality standards.

GRUPO GADISA is committed to competing fairly in the market, never accepting deceptive, fraudulent or malicious conduct, even when it leads to obtaining advantages for the company.

3. Community Relations

GRUPO GADISA promotes participation in social initiatives or projects that contribute to improving the environment in which it operates.

An essential element of management is to do things impeccably within the areas in which GADISA operates. The GROUP's commitment is none other than to try to give back to society part of what it has given to the GROUP by trusting in it.

4. Competition and price change

GADISA GROUP believes in the need for fair competition and a competitive market that contributes to the innovation and continuous improvement of the GROUP and the different sectors in the 9

which operates, in such a way that it is committed to compliance with competition legislation and regulations.

5. Relations with Public Administrations and Authorities

The relations established by GRUPO GADISA with any public or official body or its representatives must be governed by the principle of institutional respect, collaboration, legality and ethics, consequently complying with the resolutions arising therefrom.

Acts of bribery shall be expressly prohibited, including the offer or promise, directly or indirectly, of any type of improper advantage, any instrument for concealing it, as well as influence peddling..

V. Application and compliance

1. Control of application of the Code and Competencies

Compliance with the Code is monitored by the Supervisory and Control bodies, which will report to the corresponding Board of Directors of GRUPO GADISA.*.

The Supervisory and Control bodies will include in their review models the necessary controls to verify compliance with the provisions of the Code of Ethics, will make the necessary proposals for its improvement, and will periodically inform the corresponding Board of Directors of GRUPO GADISA about the degree of compliance and non-compliance detected.

It is the responsibility of the Supervisory and Control bodies to make the Code of Ethics available to all employees and obliged subjects, to organize training for their proper understanding and to interpret and respond in general to any queries that may arise.

2. Communication, dissemination and evaluation of the Code

GADISA GROUP will adopt the appropriate measures to disseminate and communicate the content of this Code of Ethics to all employees. This task will be carried out by the Supervisory and Control bodies.

3. Non-compliance with the Code and disciplinary regime

No one, regardless of their level or position, is authorized to request that a professional commit an illegal act, or one that contravenes the provisions of the Code.

Failure to comply with the Code may give rise to the application of the disciplinary regime established in current labour regulations or in applicable collective agreements, without prejudice to any administrative or criminal sanctions that may be applicable, and may also result in termination of the employment relationship.

4. Irregularities

All Code Subjects are required to report the following irregularities:

• breaches of the Code of Ethics;
• breaches of GRUPO GADISA policies and procedures;
• Other acts or behaviors that could represent a violation or breach of the Code of Ethics.

Such incidents must be reported directly to the Supervisory and Control bodies through the reporting channels.

GRUPO GADISA will protect any employee who honestly raises a concern, although making false or unfounded accusations or failing to cooperate in the investigation of any breach may constitute a violation of this Code.

5. Approval of the Code and entry into force

This Code will enter into force once it is approved by the corresponding Boards of Directors of GRUPO GADISA.

This is version 2 of the Code of Ethics that was approved by the Council held on June 29, 2018.

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* Hereinafter, Boards of Directors refers to the Boards of Directors of GALLEGA DE DISTRIBUIDORES DE ALIMENTACIÓN, SA and the rest of the companies that make up the GADISA RETAIL BUSINESS GROUP, BICA 2008, SLU, INTASA BUSINESS GROUP, FORESTAL DEL ATLÁNTICO AND IMEGASA BUSINESS GROUP, and TRANSPORT BUSINESS GROUP.

VI. Supervisory and control body

In Within the framework of this Code, the Supervisory and Control bodies will be responsible for the control and management of queries or complaints, and those responsible for compliance with the Code of Ethics..



VII. Internal information system / Ethical Channel

With In order to promote compliance with the law and the rules of conduct established in this Code of Ethics, a web platform for a Complaints Channel or Ethics Channel is made available to those Subject to the Code of Ethics and any interest group with which the GADISA Group is associated, which can be accessed from the GADISA website, so that they can report any conduct that may imply the commission of any irregularity.