ETHICS AND CONDUCT CODE

The Ethics and Conduct Code (Code) is a tool that contains a set of fundamental ethical and conduct standards applicable to the corporate universe of Martifer SGPS (Martifer SGPS and Group companies, Martifer Group or simply Martifer), and all its activities, which the Group and all its employees are subject to and consider intrinsically as their own.

The Code applies to all Martifer's employees no matter their bond or hierarchical position, as well as to all Martifer's subsidiaries. For the purpose of this Code, "employees" means all members of the statutory governing bodies of Martifer, managing directors, senior executives, external services providers, officers and all other employees no matter the kind of relation, as well as all the entities or individuals having received representation powers for the Martifer corporate universe.

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REPORTING OF IRREGULARITIES

Any employee or service provider of the Company may submit, on a confidential basis, concerns regarding any behaviour or decisions that they perceive to be unethical or in breach of the Company's Code of Conduct. An alleged irregularity should be submitted by email or post to one of the following addresses:

E-mail: comissaoeticaeconduta@martifer.com

Mail:
Comissão de Ética e Conduta do Grupo Martifer
Martifer SGPS, SA
Apartado 17,
3684-001 Oliveira de Frades
Portugal

The participation, communication or reporting of irregularities occurring within the Martifer Group are received directly in a mailbox, whose access is limited and can only be accessed by the Chairman of the Ethics and Conduct Committee. Both anonymity and confidentiality of the person reporting is ensured whenever requested in the communication.