Code of Conduct

May 2025

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 posible. And we seek to do all this while upholding ethics and trust as the guiding principles of all our operations and stakeholder relations.

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,

GCR Executive Management

Barcelona

15 September, 2022

2. 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, whose 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.

This GCR Code of Conduct respects the principles and policies set out in the Corporate Code of Conduct of GNO CORPORATE, S.L., and has been validated and authorised by its board of directors.

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. 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 policy and its requirements are thus binding on all employees, members of the management team and governing bodies and also external collaborators 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.

Respect for human rights

At GCR, we are firmly committed to upholding and respecting fundamental human rights throughout our value chain in accordance with the ILO Declaration on Fundamental Principles and Rights at Work, the Ten Principles of the Global Compact, the UN Guiding Principles on Business and Human Rights and the UN Universal Declaration of Human Rights. We therefore have a zero-tolerance policy towards any form of child labour, forced or compulsory labour and any kind of modern slavery or human trafficking in our own operations and also across our value chain.

Respect for labour rights

At GCR, we recognise our employees’ freedom of association and engage in social dialogue with formally elected workers’ representatives through structured meetings. We are additionally committed to ensuring that all employees are covered by the collective agreement applicable to our business.

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 breaches this policy.

Any concerns or behaviour which may constitute harassment, abuse, violation of rights or similar incidents is to be reported through the Whistleblower Channel as specified in its procedure

Diversity, Equal Opportunities and the Condemnation of Discrimination

Because our employees and collaborators are GCR’s most valuable asset, we advocate equality between men and women at all levels, including recruitment, working conditions and career development, and whether in technical, administrative, sales or managerial positions.

We believe in and champion diverse talent regardless of sex, gender identity, age, race, ethnicity, religion, disability or any other characteristics. At GCR we are committed to promoting diversity, equality and inclusion at every stage of our staff’s professional and personal development while also condemning discrimination against our employees, collaborators, customers or suppliers on any grounds whatsoever.

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 encourage employees to take part in skills development programmes tailored to their needs that are designed to support their personal and professional progress.

Health and safety at Work

The health and well-being of our employees and collaborators is our top priority. We are committed to fostering a safe, healthy and hazard-free working environment for them.

To enhance our performance in the health, safety and well-being of our staff, we work continuously to foster a culture of prevention, ensure compliance with best practices and deliver health and safety training.

We care about the physical and mental well-being and health of our employees and their families. We promote healthy environments and also provide staff with benefits such as a group health insurance policy which, in addition to standard healthcare services, also includes nutritional and emotional wellness programmes.

Commitment to the Protection of and Respect for the Environment

It is our mission and our common goal to protect the environment and develop sustainable solutions.

At the GCR Group, we are committed to protecting and respecting the environment. We will therefore restrict our use of natural resources, including materials, water and energy, as much as possible and minimise our carbon footprint. We will also prioritise the use of products and services with a lower environmental impact.

At the GCR GROUP, we invest in sustainability by taking all necessary measures to meet current economic, environmental and social requirements without compromising the needs and well-being of future generations.

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

Preventing corruption, bribery and influence peddling

At GCR, we do not tolerate any form of bribery, corruption or influence peddling as we view such conduct as unacceptable. We are thus committed to putting in place proactive measures to prevent it and expect 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 there is a conflict of interest when a business action or decision is, or may be, influenced by the personal interests of any GCR employee or collaborator involved or of any third party they have a personal relationship with.

Fraud

GCR undertakes to conduct its business operations with integrity, rejecting and taking action against any form of fraud while ensuring compliance with applicable legislation at all times.

Fraud can take many forms such as tampering with or forging documents, submitting false claims for benefits or misusing GCR’s resources for personal gain.

Acceptance of gifts and hospitality

As a general rule, GCR does not encourage giving or receiving gifts or invitations. They may only be accepted if they are lawful, reasonable and occasional, and under no circumstances should they be intended to influence, or be likely to influence, professional decision-making.

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 ethically extends to our relationships with customers, suppliers, competitors, regulators and other stakeholders. Accordingly, we foster a fair, free and open market, devoid of practices which may hinder or restrict free market competition.

Likewise, all staff must be familiar and comply with the organisation’s internal policies. These are specific guidelines which may be more stringent than legal requirements although in no case will they run counter to applicable laws.

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 ractices or unfair competition.

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 one of the Company’s core values, we are committed to managing the personal data of our employees, collaborators, customers and other stakeholders responsibly while also safeguarding third-party intellectual property rights.

We have internal policies and procedures in place to enhance the security of our applications and personal data processing and make sure that such data are gathered, processed and stored securely.

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

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.

5. Implementation and oversight of the Code

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/

Any behaviour that may constitute a breach of the code of conduct through the Reports may be made either by name or anonymously; in either case, confidentiality of the whistleblowers and the absence of reprisals will be ensured. The regulations governing this procedure are available via the channel.

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.

Whistleblower Channel Board

It comprises the single-member Investigative Board and the Report Resolution Board (RRB). The former is entrusted with managing the Whistleblower Channel by receiving, processing and following up on incoming whistleblower reports and other communications and conducting the management and investigation procedures for such communications and reports. The latter is tasked with resolving the investigation cases handled by the Investigative Board and determining the consequences of each investigation conducted and completed.

Approval and Validity of the Code of Conduct

This Code of Conduct has been approved by GCR’s board of directors and validated by the board of directors of GNO CORPORATE, S.L. The Compliance Officer, who reports to GCR’s board of directors, is responsible for its implementation.

The Code of Conduct will be updated based on regular 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.

Communication of the Code of Conduct

The Code of Conduct is available to employees, collaborators and other stakeholders on the corporate website and the employee portal. GCR undertakes to ensure that all staff are aware of and understand its contents.

Breaches of the Code of Conduct

Please refer to our Whistleblower Channel Policy.

If a breach of this Code is confirmed, appropriate disciplinary measures will be taken depending on the seriousness and impact of the incident. Such measures will be applied proportionately and always in compliance with applicable legislation.

Acknowledgement of Receipt

I, the undersigned, (first name and surname):

…………………………………………………………..

personal identification number:

…………………………………………………………..

HEREBY DECLARE that:

• I have received a copy of the company’s Code of Conduct.
• I have read it and confirm that I have fully understood its contents.
• I am aware that the most up-to-date version of the Code and the policies referred to in it are available on the corporate website and the employee portal.

Signature

6. Appendix

Practical guidance for real-world situations

Q: I’ve noticed that a supplier is treating its workers in a way which might infringe their rights. What should I do?

A: You should report this via the whistleblower channel or to the compliance department. GCR is committed to working only with suppliers who respect fundamental human rights.

Q: A colleague keeps making inappropriate comments. Is this harassment?

A: Yes. Harassment includes any unwanted behaviour which undermines a person’s dignity. You should report it immediately; the company ensures confidentiality and protection against retaliation.

Q: I’ve been asked to help choose a supplier who employs a close friend of mine. Can I do this?

A: No. You must disclose your relationship and refrain from taking part in the process to avoid a potential conflict of interest.

Q: A supplier has offered me tickets to a sports event. Can I accept them?

A: If you’re unsure, check with the compliance officer.

Q: Can I share a customer’s personal information with another department without their consent?

A: No. All personal information must be kept confidential and handled according to data protection regulations. It may only be shared if there is a legal basis or express consent.

There may be situations in your work where the right course of action isn’t always clear. This guide is designed to help you identify potential ethical risks and learn how to deal with them. If at any time you are unsure about what to do, remember that you are not alone: you can and should get in touch with the Compliance Officer or use the reporting channel set up by GCR. Acting with integrity is everyone’s responsibility, and seeking guidance demonstrates a