CODE OF
CONDUCT

www.alucoil.com

CONTENTS
Letter from the President
Since its beginnings, Alucoil has grown steadily. The key to our presence in morethan 85 countries around the world lies in our corporate culture and values.
At Alucoil, people are our most important asset and through our Code of Conduct
we must reaffirm our principles, values and standards of behaviour that will guidethe way we interact, both internally and with our environment.
Our alignment in values and objectives has been the essence of where we aretoday. Honesty and integrity, combined with respect and rigour, have become thehallmarks of Alucoil.
On this path, we continue to work as a team, on a quest for continuous
improvement with the desire to be at the vanguard of new technologies, tomaintain our standards of quality and our customer-oriented approach, allwithout losing sight of environmental protection.
This Code of Conduct is a guide that establishes the fundamental principles andbehaviours that must be present in all our relationships. Only in this way will webe able to achieve our goals.
Compliance with this Code is essential for the proper development of our activity,
confidence in our management and the image of Alucoil. We therefore expect
our employees and collaborators, regardless of their function or location, tomake the utmost effort and commitment to uphold honesty in their behaviour
and their full adherence to this Code of Conduct.
I encourage you to read it, reflect on its scope and make it your own. To consult
it if you have any doubts and to apply it in your day-to-day work.
Clemente González Soler
President of ALUCOIL

Purpose04

Philosophy and Values
Philosophy
Values

04

Scope

05

Respect for the Environment and Sustainability

06

Committed to Quality

07

Employees and the Working Environment
Human Rights and the Safeguarding of Human Dignity
Employee Health and Safety

08

Relationships with Clients and Suppliers
Client relationships
Supplier relationships

10

Integrity in our management
Conflicts of interest
Corruption and bribery
Gifts, entertainment, expenses or hospitality
Donations and sponsorship
Accuracy and completeness of data in records, reports and accounts

12

Protecting our resources
Confidentiality of Information
Protection of intellectual and industrial property
Proper use of equipment, email accounts, etc.

14

Data protection

15

Availability of this Code of Conduct

16

Enforcement and disciplinary regime

16

Channels of communication (queries, complaints, reports, etc.)

17

04

CÓDIGO DE CONDUCTAPURPOSE05

CÓDIGO DE CONDUCTA

SCOPEThis Code of Conduct aims to establish the ethical principles and rules that shall govern the actions of those who are part of
Alucoil in the course of their daily tasks, to assist and guide them so that they act in accordance with this Code of Conduct at
all times. Compliance with these principles shall be promoted among the Alucoil’s collaborators.
The principles contained in this Code of Conduct are supplementary to applicable legal regulations, standards or otherinternal or other procedures that also apply.

PHILOSOPHY

VALUESThe key to Alucoil’s success lies in our business culture, ourphilosophy, which is always based on three main pillars:
people, innovation and quality.

INTEGRITY: in all the decisions we make. We put honesty
and doing the right thing first.

People are our most valuable asset:- We implement policies based on training and internal
promotion of our employees.
- We promote a favourable working environment where
teamwork, motivation and the professional development ofeach person are encouraged.
- We care for all employees and promote a diverse andinclusive culture, where commitment and safety areparamount.
- We value people who show passion in their work, ethics,
integrity, andjustice.
Our second pillar, Innovation, is our daily focus. We areopen to all kinds of changes and improvements, to unleash
the team’s creativity by coming up with new ideas, designing
new processes and developing our own technology andengineering to anticipate future needs and market trends.
The combination of these two areas of work allows us toachieve optimum quality in our products, guaranteed bycountless certifications and by the loyalty and trust that ourclients place in our prestigious brands.

CONTINUOUS
IMPROVEMENT:
non-conformist
attitude that leads us to seek new challenges in all areasof our activity.
PASSION AND COMMITMENT in everything we do,with the aim to evolve and achieve excellence.
LEADERSHIP: The development of our professionals,
their know-how and their commitment to day-to-day
improvement has positioned us as a trusted name in the
sector.
SIMPLICITY, AGILITY AND FLEXIBILITY: What sets us
apart and has characterised us since our origins.
CUSTOMER ORIENTATION: Customer satisfaction is ourraison d’être; we always look for the best solution to theirneeds and bring added value to their organisations.

In this document“Code” shall refer to this Code of Conduct.
“Alucoil” shall refer to the company Alucoil
S.A.U.
“Company” shall refer to Alucoil.

This Code will serve as a guide for action bothfor the people who work in Alucoil, regardlessof their position within the organisation, and for
its collaborators.
It is therefore directly applicable to all employees(including
trainees,interns,
temporaryworkers, external workers, freelancers hiredby the company, etc.), directors, partners or
shareholders and management team.
Suppliers, customers, consultants, sponsors,
agents and any other person associated with
Alucoil, regardless of their location, must also
be fully informed of the contents of this Code.
The target audience of the provisions of thisCode must comply with them, adapting theirconduct and the way they handle all types
of issues to the principles and regulations
contained herein.

This Code will serve as a guide for action both for the people who workin Alucoil, regardless of their position within the organisation, and for its
collaborators.

06

RESPECT FOR
THE ENVIRONMENTAND SUSTAINABILITY
Alucoil’s environmental and quality
policy, based on “zero waste”,
recycling, sustainability and the use of
the circular economy for aluminium, isin force in all its factories.
Alucoil comply with strict regulations
and quality standards based on“eco-efficiency”, a set of practices
carried out by factories to reduce theenvironmental impact of production
activities, as well as recycling all surplus
material and reintroducing it back into
the circular economy.

CÓDIGO DE CONDUCTA

07

CÓDIGO DE CONDUCTAPRINCIPLES
Alucoil’s environmental and quality policy, basedon “zero waste”, recycling, sustainability andthe use of the circular economy for aluminium,
is in force in all its factories.
Control and reducethe consumption ofnatural resources.

Promote the use ofprocesses and technologies
that minimise the impact
on the environment, as
well as emissions into theatmosphere and discharges
into water.

Ensure the availabilityof information andresources to achieveenergy objectives.

Support the
procurement of energy
efficient products andservices to improveenergy performance.

In an increasingly environmentally conscious world, the demand for sustainable, reusable and recyclable products isbooming. Alucoil is therefore committed to the Sustainable Development Goals (SDGs), promotes health and wellbeing (SDG #3), invests in industry, innovation and infrastructure (SDG #9), promotes sustainable cities and communities(SDG #11), and is committed to forms of sustainable consumption and sustainable production (SDG #12) and in its climate
action (SDG #13).

Alucoil operates under ISO 14.001
certification, which is the international
standardforEnvironmental
Management within the industry. At
the same time, depending on thespeciality of each factory, other specificcertifications are added in order toguarantee the maximum quality of
their products.

In the spirit of our enduringcommitment to the environment weperiodically review these practices andprocedures through annual internal
audits.
Alucoil has always been committed toinvesting heavily in sustainability withthe aim of minimising the environmental
footprint of all our operations andproducts. To this end, policies havebeen established in accordance withthe following principles:

COMMITTED TO QUALITY
Quality has been one of the differentiating elements that has allowed us to build a prestigious reputation over the years.
The success of Alucoil and its sustainable growth depend directly on excellence and the creation of added value for ourclients, achieved thanks to the effort and talent contributed to the continuous improvement of our products, services andmanagement.
We are very aware that one of the most efficient ways to build healthy and long-lasting relationships with our customers
is to offer high quality products and services. To this end, we prioritise values such as attention to detail, continuous
improvement, punctuality in deliveries and professionalism in our relationships. We comply with high quality control
standards and rigorous product testing procedures.
The application of these principles in our day-to-day business leads us to exceed our customers’ expectations, meeting
their requirements and specifications.

08CÓDIGO DE CONDUCTAEMPLOYEES AND THE
WORKING ENVIRONMENT
Human rights and safeguarding human dignity
The most important asset of Alucoil has always been and will continue to be our employees, without whom it would
be impossible to achieve the ambitious goals we set ourselves year after year.
Alucoil has always been concerned about the welfare of its employees and their families, ensuring that their development
is not at odds with their family life and enabling our employees to achieve a balance between their personal andprofessional spheres, adapting to their needs and always complying with the legal provisions in force at all times.
Another of the aspects on which Alucoil focuses its efforts is to achieve working environments in which our people cangrow and develop, and internal promotion is one of the strategic axes of Alucoil.
Alucoil supports and respects internationally recognised labour rights and is strongly opposed to human trafficking
and child labour.
Alucoil tries to integrate these rights into its policies by promoting:

Equal opportunities and equal treatment of our employees, under the criteria of fairness
and respect. Merit, knowledge, skills and training are the criteria on which recruitment, training,
compensation and development decisions are based.

A diverse and inclusive professional environment has been and continues to be an added
value to our organisation, enabling a higher degree of innovation, learning and continuous
improvement. Alucoil is a company where employees of different origins, backgrounds, religions,genders and cultures coexist, making us unique.

Respect and honesty are the hallmarks of our relationships. Together we must promote a working
environment where trust, transparency and mutual respect prevail.

Zero tolerance for harassment, in any form. Any hostile or offensive action, whether physical,
verbal, sexual or otherwise, that undermines one of our employees has no place in our organisation.
We oppose any kind of discrimination on the basis of gender, race, religion, political opinion,
disability, sexual orientation, marital status, among others.

09CÓDIGO DE CONDUCTA

Employee health and safety
One of Alucoil’s fundamental principles is to ensure the safety of all its employees. It is therefore a priority topromote the improvement of working conditions in order to raise the level of protection of workers’ health andsafety.
This objective is to be achieved with due regard to ethical principles and standards of best practice, always inaccordance with legal and contractual requirements.
Health and safety and risk prevention is the responsibility all workers and the management of Alucoil and they
are called on to comply to the letter. Safeguarding the health and safety of employees should revolve aroundthe following aspects:
Prevention planning, through thePrevention Plan of Alucoil, which analyses
the organisational structure, responsibilities,functions and procedures of each position,
as well as the resources necessary to
carry out risk prevention actions. It is justas important to assess the risks of the job
and the activities associated with it as it
is to establish the necessary preventive
measures to eliminate, reduce and control
the risk situations identified.
Training and informing our employees
is key to ensure the correct functioning of
all aspects relating to Health and Safety
and Risk Prevention.
To consult and involve our employees inorder to improve aspects of Occupational
Risk Prevention, as nobody knows their job
better than they do, and to provide all the
personal protective equipment necessary
for the correct performance of their duties.

One of Alucoil’s fundamental principles is
to ensure the safety of all its employees.

Health and safety and risk prevention
is the responsibility all workers and the
management of Alucoil.

10CÓDIGO DE CONDUCTARELATIONSHIPS WITH
CLIENTS AND SUPPLIERS

11CÓDIGO DE CONDUCTA

Supplier relationships

Alucoil’s relationship with its suppliers has always been based on mutual respect, trust and loyalty.

One of the strategic principles on which Alucoil’s policy revolves is its client focus. As a global company, we operate in
85 countries, which means that we have to adapt to the laws, customs and practices of all of them.
Similarly, Alucoil is committed to interacting with all our clients, suppliers, business partners, agents, local and national
entities, among others, under the principles of good faith and in an ethical, legal and upstanding manner.

We have made a firm commitment to our suppliers, selecting them on the basis of the criteria of objectivity, impartiality
and good faith, and identifying and establishing continuous contact with potential future suppliers, always maintaining
our quality and competitive advantages.
In order to make this selection, we have an exhaustive approval procedure, with the aim of ensuring that our clients do
not see the quality of our service diminished. Furthermore, in this approval process we not only take into account aspects
such as product suitability, but we are also committed to suppliers who take measures to protect the environment, comply
with the relevant regulations and respect the dignity and rights of their employees.
As with our customer relationships, our supplier relationships are based on a number of principles:

Compliance with
Spanish, EU or international regulations andthose of the country
where our supplier
operates.

Client Relationships
One of the reasons why Alucoil has grown over theyears has been thanks to our clients, whom we haveaccompanied on their journey, always offering the best
service and quality in our products. It has only beenpossible to ensure these quality standards throughrelationships based on a series of principles that are
irreplaceable and indispensable for us:
Compliance with Spanish, EU or international
regulations and those of the country where we make thesale in question.
Absence of favouritism in favour of one client or
another.

Strict compliance with the General Data Protection
Regulation, as well as other supranational regulations, in
relation to especially sensitive data.
Transparency in all matters related to the General
Terms and Conditions of Sale, in particular, offers, orders,delivery times, among others.
-

Honesty and honour in negotiations.

Finally, it is necessary to mention that satisfaction
questionnaires are sent out annually in order to detectareas for improvement that will enable us to adapt to thedemands of our clients.

Rigour and honesty innegotiation.

Strict compliance with the
General Data Protection
Regulation, as well asother supranational
regulations, especially in
relation to sensitive data.

Transparency in all
matters relating to theGeneral Conditions ofPurchase.

12CÓDIGO DE CONDUCTAINTEGRITY IN OUR MANAGEMENT

Conflicts of interest

Corruption and Bribery

All employees of Alucoil must act in the best interestsof the Company and avoid conflicts of interest.

At Alucoil, we are committed to fighting any form of corruption and we expect this commitment from our employees and collaborators as well.

A “Conflict of Interest” can be defined as a situationthat arises as a result of a clash between the privateinterests of an employee and the powers granted by
the Company to make a decision. In other words,
these are situations where the integrity and objectivity
with which the employee makes these decisions are
put at risk.
Therefore, the main preventive measure should be
disclosing to supervisors any situation that could leadto a conflict of interests with the greatest possible
openness and transparency.
We expect employees, in all dealings with suppliers,
customers and other third parties, to base any
decisions they make on the best interests of theCompany, without protecting or favouring personal
interests or the interests of third parties outside
Alucoil. Common sense and good judgement should
be used to prevent and avoid such conflicts.
If it is not possible to avoid a conflict of interest,
the employee should immediately recuse oneself
from business decisions in which a family member
or connected third party has a stake for as long asnecessary until the conflict of interest ceases.

“Corruption” shall mean offering, promising, giving, receiving, soliciting or accepting, directly or through an intermediary, an unjustified advantage, for oneself or for athird party, in order to unduly favour a party in the acquisition or sale of goods, in the procurement of services orin commercial or personal relations.
On the other hand, a “Bribe” is anything of value that isoffered, promised, paid or given to a third party for the
purpose of influencing such decision making or obtaining
an unjustified benefit in the conduct of the Company’sbusiness. It is one of the ways in which corruption materialises. Examples include: payments, gifts, entertainment,
travel, contract awards, donations, etc.
On this basis, any practice of corruption and bribery inthe conduct of business is strictly prohibited. Similarly, any
employee must refrain from engaging in any activity or
conduct that could appear to be corrupt or an attempt
at corruption.
Everyone’s cooperation is essential to prevent, detect, investigate and remedy any corrupt practices within Alucoil.
If in doubt regarding possible bribery or other corrupt
practices, employees should seek counsel from their supervisor and report it through the communication channel detailed in this Code.

13CÓDIGO DE CONDUCTA

Gifts, entertainment, expenses or hospitality
Generally speaking, we at Alucoil understand that gifts or any other legitimate form of expense or attention are a part ofour relationships with our collaborators. However, it is important to determine what kind of gifts and hospitality we cangive to customers, suppliers or other third parties we deal with, in order to avoid that these may hide possible bribery
or corrupt practices.
This Code is not intended to prohibit expenses that may be considered modest, appropriate, and consistent withreasonable business practices and acceptable under all applicable laws. Therefore, in order to be appropriate, suchcourtesies must meet the following criteria:
a. They must be made in the name of Alucoil in general; never in the name of a specific employee, administrator, etc.;
b. They must be made public and not be kept secret;c. They must be reasonable in terms of the amount or frequency with which they are made;d. Payments in cash or cash equivalents are not permitted;
e. They must not finance leisure activities, travel and similar expenses of accompanying persons or guests at businessmeetings;
f. They must not include gifts that are in poor taste, or which involve attendance at places inappropriate for the conductof professional relations;g. They must be made at an appropriate time, i.e., at a time when no material decisions are being made with respect tomatters that may have an impact on the Alucoil’s relationship with that third party;h. They must not be intended to influence the judgement of the person for whom they are intended.
Both the giver and the receiver of a gift or courtesy should question whether it may compromise the independence,
integrity or honesty of the business decision-maker. If in doubt, employees should always seek counsel through thecommunication channels detailed in this Code.
It will not be acceptable under any circumstances for an employee of Alucoil to request or solicit any kind of gift, expense
or courtesy from a third party.

Donations and sponsorship
Donations and sponsorships can sometimes hide theintention to make an improper profit. Such collaborations
are only allowed if there is a transparent relationshipbetween the parties and are never intended to cover up
illegal acts of corruption.
Alucoil is involved in the local communities where
it is located. Donations may therefore be made tocharities on an ad hoc basis. It is essential that these
donations are made without an expectation of receiving
something in return (facilities, businesses, etc.) so thatthey are genuine donations and are not mistaken for
misconduct.
Likewise, and again as a consequence of the integrationof the company in the local communities, it may sponsor
events or activities organised by third parties in orderto achieve greater visibility for their business. All of thiswill be reflected in clear contracts that will be linked, inany case, to a marketing strategy to achieve the usual
benefits in this type of exchange.

Accuracy and completeness ofdata in records, reports andaccounts

Financial resources shall be managed in accordancewith the principles of transparency, verifiability,
consistency and equity.
Employees must carry out their tasks as diligently
and accurately as possible, in accordance with the
instructions of their supervisors at all times, theapplicable regulations and, in general, with the Alucoil’s
quality standards.
All financial transactions must be immediately recorded
accurately and clearly in the system. The books andrecords of the company must be available and up todate with the latest developments at all times.
Participation in the preparation of incorrect ormisleading documents which could lead to an opinion
divorced from reality shall be strictly forbidden. It
shall also cooperate, where appropriate, with external
auditors to verify that the records give a true and fairview of the Company’s position.
In the event of inaccuracies, false records, transactions
without reasonable explanations, etc., these facts
should be reported to a superior and/or through thecommunication channels detailed in this Code foranalysis.

14CÓDIGO DE CONDUCTAPROTECTINGOUR RESOURCES

CÓDIGO DE CONDUCTA

15

Proper use of equipment, company vehicles, email accounts, etc.
Company resources shall not be used for personal purposes or for the benefit of third parties such as family, friends, etc.
(except in specific cases where such use is expressly authorised by the relevant manager).

Confidentiality of Information

When receiving Alucoil resources (office supplies, telephones, company cars, computers or any other asset or service
provided by the Company), employees must undertake to conserve them diligently and to use them only for the purposesof the position for which they have been hired.

In Alucoil we value and consider our confidential
information and we respect the confidential information
owned by third parties with whom we collaborate.

Similarly, these resources must be returned to the Company on the day they are requested or upon termination of therelationship with the Company, regardless of the reason.

This “Confidential Information” includes, but it is not
limited to, trade secrets, business plans, commercial
agreements, databases, non-public financial reports,
personal information about employees, pricing or
customer details, engineering or manufacturing ideas,
etc.. Confidential information is information that is notnormally known to persons outside Alucoil.
The continued success of Aucoil depends on the correct
use of its Confidential Information and non-disclosure tothird parties (except where otherwise required by law).
As an employee, you are likely to have access to suchinformation on many occasions as part of your job. As
a general rule, any Confidential Information should beshared only with those persons authorised to receive it.

DATA
PROTECTION

An accidental disclosure of this Confidential Information
would entail serious damage for Alucoil. Therefore, allemployees dealing with Confidential Information muststrictly follow the established security procedures andavoid, in all case, situations that could lead to the loss,
misuse or theft of this type of information. Likewise,
any Confidential Information belonging to third party
collaborators of Alucoil to which we have had access due
to business relationships or various interactions must betreated with similar measures.

Personal data means “any information relating to an identified or identifiable natural person”.
Some examples of personal data:-

Protection of intellectual and industrial property
All our innovations, intellectual and industrial property
developed over the years are key assets that allow us todifferentiate ourselves from our competitors. To protect
our rights in this area, we comply with applicable European
and international laws, regulations and other standards.
The use by third parties of logos, photographs, graphics
or any other asset belonging to Alucoil must be strictly
regulated by agreements to that effect,

which include details of the conditions of use. Compliancemust be rigorously monitored.
In the event of any suspicion of violation of our industrial
and intellectual property rights, the facts should be brought
to the attention of a superior and/or communicatedthrough any of the Communication Channels for a correctinvestigation.

Personal information such as names, telephone numbers or addresses.
Financial information such as credit card or online identification data.
Other miscellaneous information such as driver’s license, social security number, etc.

Alucoil collects a significant amount of personal data that is essential to carry out all kinds of daily procedures during thedevelopment of our business activity.
We are committed to protecting this personal data from individuals during our interactions with third parties and, inparticular, from our employees. We will only collect and retain such data as is necessary to carry out our business, andonly for specified, explicit and legitimate purposes. Furthermore, they will in all cases be processed legally and in atransparent manner, using the appropriate security mechanisms in accordance with the applicable regulations.
Under no circumstances may the recipients of this Code use personal data for their own benefit, nor may they make
duplicates and/or reproductions thereof. Such recipients shall at all times comply with the instructions and protocols
established for this purpose.
In the event of an accidental disclosure of such personal data without due consent, a security breach may occur.
The Company’s Data Protection Officer shall be informed immediately of this fact and shall be notified through thecommunication channels provided for in this Code. The competent personnel, together with experts in the field, shallproceed to assess the seriousness of the situation and the measures to be taken.
The duty of confidentiality and data protection does not end with the termination of the employment relationship but
continues over time. Any violation in this regard may lead to legal action being taken by the company.

16CÓDIGO DE CONDUCTAAVAILABILITY OF
THE CODE OF CONDUCTThis Code will be provided to all employees of Alucoil
upon joining the company. They will be informed about its
content and future updates will be communicated to themby the appropriate means.
Employees shall promote compliance with this Code andinform the collaborators with whom they interact of its
availability so that they are aware of its content and adhere
to it from the beginning of the relationship.

The content of this document will be reviewed and updated
to adapt to the continuously changing environment inwhich Alucoil operates.
This Code of Conduct will also be permanently available to
all Alucoil employees, as well as to all our collaborators, via
the website www.alucoil.com.

CÓDIGO DE CONDUCTA

17

CHANNELS OF COMMUNICATION(QUERIES, COMPLAINTS, REPORTS, ETC.)
Alucoil undertakes to have communication channels accessible
to both employees and third parties, in order to facilitate thecorrect application of the rules and principles that guide theethical behaviour of our organization set out in this Code of
Conduct.
In line with our social commitment, Alucoil has created an
Ethical Channel, with public access, so that any person linked
to our organization can report, completely anonymously andconfidentially, any irregular or illicit behaviour. The Ethical
Channel is accessible here.

ENFORCEMENT AND
DISCIPLINARY REGIME
From the moment an employee joins the Alucoil team, they
are obliged to comply with this Code of Conduct, as well aswith the rest of the internal protocols and instructions that
apply to their job. It is a unique and personal responsibilityof each worker.
Among the fundamental purposes of this Code is thefight against and prevention of possible criminal orunethical actions in both the workplace and in business.
It is therefore essential that area managers promote theapplication of these standards and act as role models fortheir subordinates, setting an example of honest behaviour
and integrity in their decisions.
Anyone who violates this Code will face the corresponding
consequences depending on the type and severity of theviolation committed and his or her position in the Company,
among other factors.
Employees or third parties who become aware of a breachof this Code should promptly report it to their manager
and/or report it through the Whistle-blower Channel.

Upon receipt of such information, the competentauthorities shall immediately proceed to investigate thefacts in an objective and fair manner. All proceedings
will be conducted with the utmost confidentiality. In theevent that an act contrary to this Code is likely to havebeen committed, all necessary measures shall be taken toprevent the continuation of the actions detected.
If such inappropriate behaviour or behaviour contrary
to the provisions of this Code is confirmed, appropriate
disciplinary sanctions will be imposed, up to and including
dismissal. Furthermore, depending on the nature of thebreach, the Company may be obliged to report the facts
to the competent authority.
Any disciplinary sanction may be applied without regard
to the end result of an offence or offence as a consequenceof misconduct, i.e., sanctions may be applied for thecommission of the misconduct alone without regard to
the consequences of the misconduct.

From the moment an employee joins the Alucoil team, they are obliged tocomply with this Code of Conduct, as well as with the rest of the internal
protocols and instructions that apply to their job.

It is important that any person who becomes aware of unethical or illegal behaviour, reports it immediately
through the Ethical Channel, either in person or anonymously. In any case, Alucoil guarantees that all information
received through the Ethical Channel as a complaint or report of irregularities, as well as the identity of thecomplainant if applicable, shall be treated with the utmost confidentiality. Alucoil prohibits reprisals against those
who make these reports in good faith.
In no case shall any employee be allowed to suffer demotion, penalty or other adverse consequences for refusing toengage in conduct of questionable integrity, even if such refusal may result in a loss of business for Alucoil.
In addition, other types of communications may be made through email: info@alucoil.com. Specifically, through thischannel, it will be possible to carry out the following procedures:Requesting information and making queries on any matter related to the Code of Conduct and its application.
Raising doubts about the possibility of carrying out or continuing a certain behaviour.
Raising recommendations and proposals to improve the application of the channels of communication and
the Code of Conduct.

18

Pol. Ind. de Bayas,
Calle Ircio Parcelas R-68 a R-74,
09200 Miranda de Ebro,
Burgos (SPAIN)+34 94 733 33 20
www.alucoil.com
info@alucoil.com