Summary

1. Introduction 
2. Objectives of the Code of Conduct 
3. Scope and Application
4. Fundamental principles and values 
5. Commitment to sustainability 
   1. Environmental management 
   2. Sustainable Innovation 
6. Labor relations and human rights.
7. Relationship with the community and suppliers. 
8. Actions against corruption, extortion and embezzlement 
9. Reporting and compliance mechanisms. 
10. Review and update of the code of conduct 

1. Introduction

At Costers del Sió we recognize the importance of operating with the highest ethical and sustainable standards. The environment, both environmental and social, while maintaining the quality and tradition that characterizes the wines of our region.

We want every employee, supplier and business partner to understand and apply these principles, ensuring that we all act in a manner consistent with our core values.

2. Objectives of the Code of Conduct

1. Foster a culture of ethics and respect in all areas of the winery.
2. Ensure compliance with applicable laws and regulations, both locally and internationally.
3. Prevent and combat corruption, extortion and misappropriation of funds.
4. Foster honesty and transparency.
5. Promote an inclusive, safe and healthy work environment based on equity.
6. Foster respect and coexistence within the winery
7. Develop the professional ethics of all workers
8. Protect privacy and confidentiality.
9. Consolidate the reputation of Costers del Sió as a benchmark in the Lleida wine industry.

3. Scope and Application

This Code is mandatory and must be followed by all employees and organizations that maintain a relationship with the Costers del Sió winery. Its application includes all areas of the company, ensuring that the decisions and actions of the winery are aligned with the principles. Specifically, the obligation to:

• All the workers and owners of Costers del Sió, without distinction of hierarchy. This includes permanent staff and potential temporary or contract workers for specific projects, regardless of department.
• Suppliers and other business partners who participate in distribution, marketing or other related activity.

The practices of Costers del Sió must also be aligned with the expectations of the environment. This includes respect for local and regional laws and a commitment to the well-being of the community.

Compliance and Responsibility:

Compliance with the Code is the responsibility of all the persons and entities mentioned, who must act according to the principles of ethics, integrity and responsibility that govern this document. Any violation of the Code must be reported in accordance with the established procedures and could involve corrective or disciplinary measures, as the case may be.

In addition, external parties that collaborate with Costers del Sió, as suppliers or contractors, must also adhere to the principles of this Code in all interactions with the winery, which ensures a consistent value chain with the ethical and quality standards of the company.

4. Fundamental principles and values

The Code of Conduct of Costers del Sió is based on ethical principles that guide all

decisions and behavior within the winery. These principles reflect the commitment to a transparent, sustainable and respectful operation, both at work and with the environment and communities.

1. Integrity: Work with honesty and transparency.Integrity is the basis of all our actions. This involves maintaining truthfulness in communication with employees, customers, suppliers and authorities; as well as avoiding any formof fraud or conflict of interest, ensuring that decisions are made based on ethical and professional criteria.
2. Regarding the Regulations: Strictly comply with the laws in force. Compliance with local, national and international laws, regulations is essential to ensure legality and ethics in all winery activities.
3. Sustainability: Minimize environmental impact and preserve natural resources.This principle guides all our decisions, from the management of the vineyards to the production and marketing of our products, ensuring that our activity has the least possible impact on the environment.
4. Respect for human rights: guarantee equality and fair treatment. Costers del Sió is committed to absolute respect for human rights and the promotion of a work environment where all people are treated with dignity and respect. This principle includes: 
   • Equal opportunities for all employees, without discrimination based on gender, race, age, religion, sexual orientation or origin.
   • The right to decent work, guaranteeing safe, fair and equitable working conditions.
   • Respect for freedom of association and expression, which allows employees to express their concerns and opinions freely and without fear of reprisal.
   • Combat any form of labor exploitation, including child or forced labor, both in our winery and in our supply chains.

5. Excellence: Seek continuous improvement in all processes.Innovate and adapt to the best practices and technologies, looking for creative and efficient solutions. Improve the quality of our products through rigorous and constant control processes, ensuring that the wine we produce always lives up to our customers' expectations. Encourage continuous learning among our employees, supporting their continuous training and the development of new skills.

6. Responsibility: Fulfill our obligations in a professional manner.At Costers del Sió, we take our responsibility seriously, recognizing that every action and decision has an impact on the winery, our collaborators and society in general
7. Confidentiality: Protect the sensitive information of the winery and its members.The principle of confidentiality is essential to ensure trust in all our commercial and working relationships. We establish clear policies for the management and disclosure of confidential information, avoiding any leakage that could harm the winery or its business partners.

5. Commitment to sustainability

Sustainability is an essential pillar that guides the way we operate, reflecting our commitment to the preservation of the environment and the well-being of future generations. Through our actions, we seek to minimize environmental impact, promote responsible practices and contribute to sustainability at all stages of our operation.

Environmental management

Environmental management at Costers del Sió is focused on reducing our ecological impact while preserving and respecting the natural environment that surrounds our winery in the Lleida region. For this reason, we adopt sustainable practices that align with the principles of environmental responsibility.

• Reduction in the use of energy resources and waste generation: We implement measures to optimize the use of energy and natural resources at all stages of wine production, storage and distribution.

• Protection of local biodiversity in the Lleida region:We recognize the natural wealth of our environment
• Promotion of reuse and recycling at all stages of production:We are committed to a full life cycle approach to minimize waste

Sustainable Innovation

Innovation is a fundamental tool to achieve our sustainability goals. For this reason, we integrate innovative technologies and models that allow us to optimize resources and reduce our environmental impact.

6. Labor relations and human rights

Our labor policy is based on promoting an inclusive, safe and conducive environment for the personal and professional development of each individual.

Fair working conditions:

1. Inclusive and safe work environment:We strive to create an environment where all employees can do their jobs free of harassment and discrimination. This includes:

Establish clear policies and effective processes to prevent, identify and address any form of harassment, discrimination, violence or intimidation.

2. Justice and equity in remuneration and benefits:Offer competitive and fair wages and benefits, aligned with legal regulations and industry best practices. This includes on-time payment and recognition of overtime.

3. Balance between work and personal life:We respect the personal time of our employees and promote reasonable working hours, as well as conciliation measures such as family leave.

Promotion of development: Invest in the training and professional growth of employees.

Continuous training: At Costers del Sió we believe that education and skill development are essential to the success of our employees and the winery.

• Regular technical and professional training programs, adapted to the needs of each area.
• Professional development plans.
• Support in obtaining certifications or related degrees with the wine industry.

Diversity and inclusion: Respect cultural differences and promote equal opportunities.

At Costers del Sió, we value and promote diversity as a fundamental pillar of our organizational culture. We are committed to creating an inclusive and respectful environment where each person is valued for their contributions and abilities, regardless of individual differences.

• Commitment to diversity:We promote respect for cultural, religious, gender and sexual orientation differences, creating an environment where everyone feels valued and respected.
• Equal opportunities:All employees, regardless of origin or status, have access to the same opportunities for employment, training and promotion.
• Inclusion of vulnerable groups:We are committed to the inclusion of people in vulnerable situations, thus contributing to personal and professional development.

7. Relationship with the community and the suppliers

Positive impact on the community:contribute positively to the autonomous community of Catalonia and the province of Lleida:

• Participate in cultural and social projects in Lleida. In addition, make sponsorships and donations to social, cultural, sporting activities, etc
• Social initiatives: collaborating with local suppliers that benefit society.
• Promotion of local employment: Prioritize the recruitment of local talent. Also encourage the inclusion of students in internships at the University of Lleida.

Ethical collaboration:Our relationship with suppliers and business partners is based on principles of transparency, ethics and respect for the values we promote. This includes:

• Responsible selection of suppliers:through questionnaires
• Promotion of sustainable practices
• Relationships based on mutual respect:being the basis of fair and equitable commercial relations, beneficial for both parties.
• Fight against corruption:

Promotion of wine tourism: Promote activities that value the cultural and natural heritage of the region. This commitment includes:

• Quality wine tourism experiences
• Sustainability in wine tourism
• Generating benefits for the community:through wine tourism, attract visitors to the region, which boosts the local economy and encourages other businesses.

8. Actions against corruption, extortion and embezzlement of funds 

1. Corruption and Bribery

Corruption and bribery are incompatible with our values and ethical standards. For this reason, we establish the following guidelines:

- Strict prohibition of bribery: No employee, manager or business partner may accept, offer or solicit bribes in any way. This includes, but is not limited to:

• Cash, expensive gifts, improper favorsoranybenefitintendedto influencebusinessorgovernmentdecisions.
• Actionsthatcanbeperceivedasanattempttoobtain unfairorinappropriateadvantages.

- Gifts and hospitality:We only allow details that do not compromise the ethics or objectivity of the decisions. These include:

• Low value promotional material (such as pens, notebooks or calendars).

• Reasonable invitations as long as they are transparent and in line with winery policies.

• Other related, as long as they comply with the policy of the winery.

- Awareness and training

2. Extortion and Coercion

We reject any form of pressure, threat or coercion in commercial operations or labor relations.

- Zero tolerance policy for extortion: We do not accept or practice any form of extortion or coercion, whether in our internal or external relationships.

• Threats of retaliation against employees, suppliers or business partners who refuse to engage in illegal activities.
• Improper use of influence or power to obtain personal or business advantage.

- Confidential reporting channels:To ensure a safe and transparent environment, we have established reporting channels that allow employees to report any situation of coercion or extortion. Complaints can be made anonymously, and the winery undertakes to guarantee the confidentiality and protection of complainants via email: denuncies@costersio.com .

- Immediate actions for reported cases:We will investigate all allegations of extortion or coercion thoroughly and take disciplinary or legal action against those responsible.

3. Misappropriation of Funds

Responsible stewardship of resources is critical to maintaining the trust of our employees, business partners and the community.

• Appropriate use of resources:Cellar funds, assets and resources must be used only for authorized purposes and in line with the legitimate business objectives of Costers del Sió.

• Improper use of company resources is strictly prohibited.

• Documentation and traceability:All financial transactions must be clearly documented and recorded, ensuring that they are verifiable and comply with legal regulations. We avoid opaque or suspicious operations that could compromise the winery's reputation.

9. Mechanisms of complaint and compliance

At Costers del Sió, we have implemented a Complaints Channel through an exclusive email, designed to facilitate the confidential communication of any irregularity or non-compliance with the Code of Conduct: denuncies@costersio.com . This channel is available to all employees, suppliers and business partners, ensuring the privacy of those who use it and ensuring that their concerns are dealt with in an impartial and professional manner.

Each complaint received will be analyzed with rigor and objectivity to guarantee a fair and transparent process. Throughout the process, the confidentiality of the information will be maintained and the identity of the complainant will be protected.

In the event that a violation of the Code of Conduct is confirmed, disciplinary measures proportional to the seriousness of the violation will be applied. These can include formal warnings to the termination of employment or commercial contracts. Likewise, when the situation warrants it, the relevant legal authorities will be notified to ensure that action is taken in accordance with the applicable laws and the corresponding sanctions are adopted.

10. Review and update of the code of conduct

The Code of Conduct of Costers del Sió is a living document that reflects the values, principles and commitments of the winery. We recognize that the

regulations, ethical standards and the needs of the organization evolve over time, which is why we are committed to regularly reviewing and updating it to ensure its relevance and effectiveness.

We will carry out regular reviews, at least once a year, or more frequently if there are significant changes in the regulatory, social or business environment.

During the review process, the participation of employees, managers and other relevant groups should be encouraged, who can provide suggestions or point out areas for improvement.

Any updates will be communicated in a clear and timely manner to all employees, suppliers and business partners. In addition, training or information sessions will be provided to ensure understanding and compliance with the new provisions.