Code of Conduct

September 2022

Scope of application of this code

The scope of application of this Code of Conduct covers a group of industrial companies that we call the GCR Group, of which the parent company is GCR PLASTIC SOLUTIONS GROUP, S.L. (hereinafter “GCR” or “the Company”), which is also a subsidiary of GNO CORPORATE, S.L., its ultimate parent company.
The GCR Code of Conduct respects the principles and policies set out in the Corporate Code of Conduct of GNO CORPORATE, S.L., and it has been validated and authorised by the company’s board of directors.

Contents

1. Letter from the CEO

2. Purpose of the GCR Code of Conduct and the Commitment of GCR Professionals

3. GCR’s Mission, Vision and Values

4. Respect for Human Rights

5. Equal opportunity and condemnation of discrimination Condemnation of all forms of harassment

6. Health and safety at work

7. Commitment to protecting and respecting the environment Money laundering

8. Bribery, corruption and influence peddling Preventing conflicts of interest

9. Acceptance of gifts and hospitality Commitment to competition laws

10. Use and protection of company resources and confidential information Data privacy

11. Dissemination and protection of GCR’s image

12. Media relations, use of social and professional networks and the Whistleblower Channel

13. Approval and validity of the Code of Conduct

1. Letter from the CEO

Since its founding, the GCR group has grown significantly due to, among other factors, the entrepreneurial spirit of its founding family, its constant commitment to innovation, substantial investments made, and in particular the talent and effort of all members of this great team.
GCR’s product portfolio, quality and customer service have enabled the company to become a leading brand in Europe and a global benchmark in the development of environmental solutions for the plastics industry.

In order to continue moving in this direction, it is key to have a frame of reference that will enable us to continue to grow in an environment of excellence and development for all. We have therefore drafted this Code of Conduct, a formal statement of principles setting out the values and ethical standards that govern GCR’s activities. This code is a clear example of our way of doing things. It is based on a deep-rooted culture of integrity, determination, collaboration and innovation, which are the core and differentiating values behind our success.

In this regard, it is of vital importance to develop, approve and comply with the Code of Conduct. The reasons are related not only to the growth of the business itself, but to the personal and professional advancement of all GCR team members.

This Code of Conduct covers not only respect for national and international laws, but also the standards of (good) conduct applicable to our work and business endeavours in all areas in which we have a presence. It embodies an ethical culture that we also demand from our customers and suppliers of goods and services.

We at GCR are committed to ensuring that our Code of Conduct is understood, disseminated and exemplary in nature. We are also committed to ensuring full compliance with it, and we aim to continue updating its content.

We want our Code of Conduct to contribute to the continued evolution and growth of GCR, and for it to meet the needs of our customers to the greatest extent possible. It is our hope that ethics and trust will be the guiding principles of all our operations and stakeholder relations.
In this regard, the Code of Conduct is also of great help to all GCR employees and collaborators. The guidelines that comprise it encourage us to act as properly and ethically as possible in order to uphold our values and protect our reputation. They also help us to know where to turn in complex situations when we are unsure what to do.

We look forward to your cooperation in the optimal implementation of this Code of Conduct.
Let us work together to promote our values and create a working environment of utmost trust and respect, which will undoubtedly help us to achieve our growth objectives.

Kind regards,

Joan Prats GCR
Barcelona,
15 September 2022

2. Purpose of the GCR Code of Conduct and Commitment of GCR Professionals

This Code of Conduct has been developed in order to formally establish the conduct standards, values and principles that should govern the behaviour of GCR’s people in their internal and external relations.
The entire GCR team, and in particular the members of the management team and board of directors, assume the responsibility of leading by example and ensuring full understanding of and compliance with this Code of Conduct, as well as with national and international laws to which GCR is subject in all the regions in which it operates.

The aim of this Code of Conduct is to strengthen our mission, vision and corporate values by establishing rights and obligations for all GCR members. The contents of this document are thus binding on everyone associated with GCR, irrespective of their geographical location or activity.

Employees must always act in the interests of GCR in a professional and diligent manner. The Code of Conduct is a guide containing global standards of conduct expected of those who are subject to it. In doing so, we aim to ensure that we act transparently and follow best practices in line with good governance and corporate social responsibility.

The values and principles that we proclaim herein can only be brought to fruition when they are implemented through an individual and collective model of leadership and business management that is based on dialogue, respect, transparency, professionalism, accountability and responsibility.
Should a situation arise that is not covered by the company’s rules or the Code of Conduct, each professional must find the best solution guided by their own conscience and provided that it falls within the framework of GCR’s ethical principles and values. In this regard, they may seek support and advice from within GCR.

To deal with situations of conflict not covered by this Code of Conduct or any other company rules, we have prepared some questions that may serve as a guide to finding a solution for people in situations of conflict or doubt:

• Is my/your conduct likely to create a situation of conflict or a rule violation?
• Am I uncomfortable with the conflict situation? Why?
• Is my/your conduct consistent with the Code of Conduct and corporate values? What should be done to ensure that such behaviour reflects the spirit of the Code of Conduct, GCR’s values or applicable standards?
• Am I/Are you being fair and honest with myself/yourself and my/your colleagues?
• What consequences could arise from my/your behaviour, whether affecting me, GCR, customers, suppliers or any other person/entity? Are there other alternatives?
• What steps could be taken to mitigate the risks inherent in a potential risk situation?
• Who could I ask about this situation?

Compliance with company rules and our Code of Conduct, as well as the management of situations that could compromise our values, must be part of the commitment, integrity, respect and professional excellence shared by the entire GCR team.

3. GCR’s purpose, mission, vision and values

Purpose: Our reason for being

To help make the world a better place by transforming the plastics industry in a way that improves people’s lives and protects the environment.

GCR’s mission: Our objective

To reimagine materials, processes and services in a way that delivers unbeatable sustainable plastics solutions that will create value for our customers.

GCR’s vision: Our future

Being a global benchmark and partner in the innovation of sustainable and competitive plastic materials based on technological excellence, quality, service and people development.

Our Values

• Integrity: Our values guide our decisions in a way that helps us fulfil our responsibilities and obligations to promote respect for people and the environment.
• Innovation: We are looking for new ideas and solutions that will enable us to continue evolving, improving and confronting new challenges.
• Determination: We are independent thinkers who act with boldness and meet our commitments to advance and support our customers’ success.
• Collaboration: Teamwork and synergies with our customers and suppliers are essential aspects in the creation of shared value.

4. Respect for human rights

At GCR we are firmly committed to upholding the rights of individuals, and particularly in accordance with the United Nations Universal Declaration of Human Rights

Equal opportunities and condemnation of discrimination

At GCR we are committed to the professional and personal development of our employees and collaborators, and we also champion equality of treatment and opportunity. The selection and promotion of our employees is based on the performance of their professional duties and on the merit and professional competence criteria identified by the company for each position. We actively promote the participation of employees in training and development plans that are designed to promote their personal and professional progress.
GCR condemns any kind of discrimination based on race, nationality, social origin, age, gender, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of our employees, collaborators, customers or suppliers.
Because GCR considers its employees and collaborators to be its most important assets, we advocate equality between men and women at all levels, including recruitment, working conditions and career development, and whether in technical, administrative, commercial or managerial positions.

Condemnation of any type of harassment

All GCR employees and collaborators have the right to be treated and the obligation to treat each other with respect, courtesy and dignity.
At GCR we express our commitment to prevent, avoid, resolve and punish any type of physical or psychological violence or harassment at work, whether sexual or of any other type, as an essential requirement to guarantee the dignity, integrity, respect and equality of treatment and opportunity of all people. To this end, it is essential for everyone to cooperate in responding and reporting to the company’s management any conduct that violates this standard. It is necessary to resolve doubts or report harassment, mistreatment, abuse, violation of rights or any other type of behaviour, in accordance with the principles of the Whistleblower Channel.

5. Health and safety at work

Our top priority is the health and well-being of our employees and collaborators.
We work continuously to prevent work accidents and occupational diseases, as well as to improve health and safety conditions at work.

We are all responsible for health and safety at work. It is thus our obligation to foster a culture of prevention and promotion of best practices and to provide health and safety training. This is the responsibility of every person in the company, irrespective of their position or hierarchical level.

At GCR Group we promote healthy spaces, as well as the physical well-being and health of our employees and their families. We do so by providing access to social benefits such as the group health policy, which includes, in addition to typical health services, nutritional and emotional wellness programmes.

6. Commitment to the protection of and respect for the environment

At GCR GROUP our commitment to sustainability entails adopting all measures needed to meet current economic, environmental and social requirements without compromising the needs and well-being of future generations.
It is our mission and our common goal to protect and develop environmentally sustainable solutions.

To the extent possible, we will restrict our use of environmental resources – materials, water and energy – in order to reduce our carbon footprint. We will prioritise the consumption of products, suppliers and services with lower environmental impacts.

Money laundering

At GCR we are keenly aware of this problem and the need to comply with applicable regulations designed to tackle it, and we demand the same from our suppliers and customers.
Under no circumstances will GCR collaborate with or permit actions that could in any way or even indirectly aid or serve as a cover for terrorist or criminal activities.

7. Bribery, corruption and influence peddling

At GCR we do not allow any form of bribery, corruption or influence peddling, as we consider such practices to be unacceptable. In this regard, we are committed to preventing them and demand the same from our customers and suppliers.
In particular, offering payment or invitations to public officials with the aim of influencing their actions or decisions is strictly prohibited.
Business practices must comply with GCR’s Code of Conduct, and situations of non-compliance that entail obtaining unjustified profit or enrichment are prohibited. Furthermore, GCR does not offer, give, request or receive any type of non-contractual or non-invoiced charges or payments.
GCR also requires suppliers of goods and services, as well as external collaborators and professionals, to comply with ethical standards that are consistent with our Code of Conduct, in particular with regard to the prevention of bribery and corruption.

Preventing conflicts of interest

GCR’s relationships with its employees and collaborators are based on loyalty and trust. We thus avoid all situations in which the personal interests of employees and collaborators could directly or indirectly conflict with those of GCR.
At GCR we understand and respect the involvement of our employees in other financial, professional and business activities, provided that such activities are legal, do not entail unfair competition and do not interfere with the responsibilities, obligations or due dedication required to perform professional work.
In this regard, we consider that a conflict of interest exists when any employee of GCR directly or indirectly engages in practices that favour other companies in the same sector and/or related sectors, customers or suppliers, or any other company, public or private entity whose business may be in competition with or negatively affect GCR.

8. Acceptance of gifts and hospitality

Any form of corruption, whether active or passive, public or private, is prohibited. In this regard, corruption is understood to mean the attempt to influence a person’s decision by offering unjustified benefits or advantages. We do not offer or accept payments, gifts or favours; nor do we accept or promote activities that involve or, in the judgement of an impartial observer, could constitute or be seen as exerting improper influence on decision-makers whose authority is based on regulation or the decision of a third party.
As a general rule, we should not offer or accept gifts and hospitality, especially when the receiving party is someone who must make decisions of relevance to us or our business.
However, gifts and/or hospitality may be exchanged as a normal part of business relations. In such cases, the following considerations should be borne in mind:
Accepting or offering gifts and hospitality:

• They should not run afoul of the legal system and applicable laws or go beyond customary, social and polite customs.
• They may not be offered to decision-makers, unless they are obviously being given as a matter of courtesy. In the latter case, prior approval of the Management Committee is required.
• They must not be intended to influence a decision or obtain any kind of business advantage.
• They must not be intended to obtain or be part of an exchange for favourable treatment or give rise to a conflict of interest.
• They must be given in an honest and transparent manner.
• They must not consist of cash or cash-equivalent items (e.g. gift cards).
• Invitations to extravagant or inappropriate meals or forms of entertainment (e.g. gambling or adult entertainment) must not be accepted or offered.

If you receive any courtesy or gift that does not comply with these considerations, it must be immediately returned or refused. If the item cannot be returned or refused, the Human Resources Department should be notified and, to the extent possible, the gift should be used for social purposes. Furthermore, all individuals involved, including non-GCR members, should be informed of the non-influential nature of the courtesy or gift in regards to decision-making.

Commitment to competition laws

Our responsibility to conduct business in an ethical manner extends to our relationships with customers, suppliers, competitors, regulators and other stakeholders.
Our competitive advantage is the result of team effort and a clear focus on innovation, quality and operational excellence. Our results are not obtained through engagement in illegal practices or unfair competition.

9. Confidential information of the company

At GCR, we consider information and our knowledge to be key assets that are essential for business management, which is also why they must be subject to special protection.
Protecting GCR’s knowledge is the responsibility of the entire team, irrespective of each person’s organisational level or position.
GCR’s success and future depend on innovative products and solutions being developed by our teams. It is therefore imperative for us to be the ultimate guarantors of our knowledge and protect our intellectual property against theft, misuse or loss.
In particular, GCR’s business secrets must receive special care and management. We are all obliged to protect them and to prevent unauthorised or improper access to them.
Contravention of these obligations is considered unlawful and will be pursued by GCR, including through criminal prosecution.
GCR’s Legal Department supports us in protecting intellectual property, confidential information, trademarks and other interests with a view to maintaining our competitive advantage and promoting sustainable growth.

Data privacy

As respect for people is among our company’s values, we protect the privacy of all our employees and collaborators.
At GCR, we defend the diligent use of personal data, and only when such use is absolutely essential and with the utmost respect for the right to privacy. In addition, such use must comply with legal requirements, the company’s own policies and personal data protection regulations.

10. Dissemination and protection of GCR’s image

It is the responsibility of each and every employee and collaborator to preserve the image and reputation of GCR in all professional activities, including public interventions and activities in social media and professional networks.
Our brands and the reputation we have built together over the years are part of our success. We are therefore committed to taking good care of our own corporate image and the image of all GCR professionals, both in the course of our relations with customers and suppliers as well as in other professional arenas and on social networks.
We all build GCR’s image and reputation through our relationships with other employees and collaborators, as well as with customers and suppliers. We therefore insist on maintaining internal and external relations based on respect, fairness, honesty and adherence to our corporate principles and values.
As GCR employees and as collaborators, it is our responsibility to deliver the highest standards of quality and excellence in our business relationships while also striving to meet the needs of our customers, collaborators, suppliers, public organisations and other stakeholders by providing them with innovative and high-quality solutions.

11. Media relations and the use of social and professional networks

We are all ambassadors for GCR and its brands, and everything we do has an impact on the company’s corporate image.
In order to ensure compliance with the law and to protect our interests, only duly designated individuals may represent GCR to the public, news media, social media or professional networks.
Media relations and official messaging are handled by the executive management, marketing and communication teams.
Social media and professional networks in particular are part of the normal business routine, so it is vitally important to distinguish between authorised company communication and personal communication.
Individual means of expression in any arena or format on topics of a political, social, religious, economic, etc. nature should leave no doubt that they express personal opinions and do not represent the opinion of GCR.
All commercial communications published on behalf of GCR must respect and promote the Group’s values and be duly authorised by GCR’s marketing management team.

Use of resources

We are all obliged to protect GCR’s resources and make proper use of them according to GCR’s corporate policies. We must protect them against theft, damage and unauthorised access or use (credit cards, computers, mobile phones, internet access and email accounts or other means of communication, etc.).
The resources provided by GCR are strictly for professional use, and the policies and procedures set forth by the company must be complied with at all times.

Whistleblower Channel (EQS Integrity Line)

Any behaviour that may constitute a breach of the code of conduct through the Whistleblower Channel that GCR makes available to employees and collaborators and, in general, to stakeholders (mainly customers and suppliers).

The Whistleblower Channel is part of the EQS Integrity Line and is managed by lawyers associated with the group’s parent company.

The Whistleblower Channel is an effective (and anonymous, when needed) means of facilitating communication between GCR and its employees, collaborators and third parties to ensure compliance with applicable regulations, ethical standards and our Code of Conduct. It provides a means to report events or file complaints regarding suspected breaches of the law, company regulations and/or ethical standards and/or the Code of Conduct.

The Whistleblower Channel can be accessed via the following link: https://gcr.integrityline.com/frontpage

Reports may be made in one’s own name or anonymously. The rules for this channel are found in the link.
We respect those who express concerns and doubts about misconduct. Our Code of Conduct does not permit retaliation of any kind against any person who reports a possible violation in good faith or provides assistance to an investigation into possible abusive or improper conduct.

The importance of this topic cannot be overemphasised, and all GCR employees, collaborators and other stakeholders are expected to personally make use of this tool in the event of any suspicious or doubtful situation.

Notwithstanding use of the aforementioned channel, the company’s division and department managers are obliged to deal promptly with any such queries, enquiries and complaints.

12. Approval and Validity of the Code of Conduct

This Code of Conduct has been approved by GCR’s board of directors, and it has been validated by the board of directors of GNO CORPORATE, S.L.
The Code of Conduct will be updated based on periodic reviews with the aims of maintaining our environment of excellence and ensuring that all GCR employees and collaborators comply with the law and ethical standards.