CORPORATE SOCIAL RESPONSIBILITY POLICY OF TODOPALMERA 10/12 / 2.015
INDEX
GENERAL CORPORATE SOCIAL RESPONSIBILITY POLICY

Laura Sánchez Brotons, owner of TodoPalmera.com, is responsible for designing, evaluating and reviewing on a permanent basis the corporate policies that contain the guidelines that govern the actions of the Company and the principles reflected in the Corporate Governance System. Among corporate policies, corporate social responsibility aims to promote a culture of social responsibility in the company, globally, which contributes to the creation of value in a sustainable way for society, citizens, customers and communities in which the Group develops its activities, pay equitably to all the groups that contribute to the success of its business project and undertake new investments considering its social return, generating employment and wealth for society with a long-term vision that seeks a better future without compromising the present results. Management has assumed as one of the basic premises for the success of its business project the sustainable development of the communities in which it carries out its activities and the welfare of the people: clients and citizens that contribute to the achievement of the social interest of the company. Aware of this reality, TodoPalmera.com contributes to the development of communities with their business activity and social responsibility strategy, with measures aimed at promoting education and culture and protecting vulnerable groups, and works to establish firm and permanent links , taking into consideration the interests of its human team and the financial community, regulatory bodies, customers, suppliers, the media, society in general and the environment (the “Interest Groups”). In this sense, the company’s social responsibility strategy seeks to place it at the forefront of best practices in this field convinced that, in addition to being basic to fulfill its social interest, it is a fundamental part of its strategy of excellence and improvement of your competitiveness The general policy of corporate social responsibility aims to establish the basic principles and the general framework of action for the management of corporate social responsibility practices assumed by the company and serve as a basis for the integration of social responsibility in the business model of the company and its strategy. The General Corporate Social Responsibility Policy is developed and complemented by the different Social Responsibility Policies that meet certain needs and expectations of the Stakeholders. The corporate website of the company is one of the main instruments for channeling its relations with Stakeholders. OBJECTIVES

1.Objectives of the general corporate social responsibility policy

The company has developed its own business model with the aim of creating value in a sustainable way for society, citizens, customers and for the communities in which they carry out their activities, providing a quality service through the use of energy sources that respect the environment, innovating and remaining attentive to the opportunities offered by the knowledge economy. For this, the company undertakes new investments considering its social return, fosters growth and develops the technical and human capabilities of its professionals, works for the safety of people and supply and strives to build a project of joint business success with all the participants in its value chain. The fulfillment of the company’s social interest, as it appears in the voluntary manifesto prepared, requires the assumption of corporate social responsibility policies that favor the “sustainable exploitation of its corporate purpose and the creation of long-term value for the benefit of those [the owner], taking into consideration the other interest groups related to its business activity and its institutional reality and, especially, the legitimate interests of the different communities and territories in which it operates and those of its workers “. The knowledge, diffusion and implementation of the values ​​of the company serve as a guide for the performance of the management, in its relations with the Stakeholders. The instruments put into practice by the company must contribute to the development of the communities in which the TodoPalmera.com Group is present with its business activity and its social responsibility strategy, with measures aimed at promoting education and culture and protecting to vulnerable groups and, in particular:

a) Favor the achievement of the strategic objectives of the Grupor in order to offer a safe, reliable, quality and environmentally-friendly supply of its products. b) To improve the Group’s competitiveness through the assumption of management practices based on innovation, equality of opportunities, productivity, profitability and sustainability. c) Manage in a responsible manner the risks and opportunities arising from the evolution of the environment, as well as maximize the positive impacts of its activity in the different territories in which it operates and minimize, to the extent possible. possible, negative impacts. d) Promote a culture of ethical behavior and increase business transparency to generate credibility and trust in the stakeholders, including society as a whole. e) Promote relationships of trust and confidence. the creation of value for all its stakeholders, giving a balanced and integrating response to all of them.f) Contribute to the improvement of the rep and external recognition of the company. PRINCIPLES OF THE POLICY Corporate social responsibility and its adaptation to the corporate structure of the GroupTo achieve the aforementioned objectives, the Group will be guided by the principles of action contained in the Corporate Governance System and, specifically, in the General Social Responsibility Policy corporate and its complementary policies, in relation to the company in general and to the different stakeholders with which it interacts and are affected by its activity. In its application, and in accordance with the provisions of the General Corporate Governance Policy, the following shall apply: a) To management, the establishment of the company’s policies and strategies and the basic guidelines for its management, as well as the general supervision of its development. b) To the General Director of the company, the function of organization and strategic coordination of TodoPalmera.com.c) To the management, disseminate, implement and ensure the monitoring of the policies and general guidelines of the Group in each of the countries in which they operate and in relation to the businesses they group, taking into account their characteristics and singularities. d) To the management, the ordinary direction of the application of these policies, their effective management and the responsibility of their ordinary control. The exercise of these responsibilities will be carried out by the various committees that assume functions in matters of corporate social responsibility and reputates tion. Specifically: a) Corporate Committee on Corporate Social Responsibility and Reputation, which has the functions of: defining the basic corporate lines of the evolution of social responsibility and reputation in the Group, approving and following the development plans in both areas, take cognizance of the most relevant advances and collaborate in the preparation of the public information that the company discloses in these areas. b) Committees on Corporate Social Responsibility and Reputation in each of the business lines, with the aim of promoting compliance with the policies and guidelines approved in the different countries in which the Group operates, coordinate the corporate strategy among the different businesses developed in each country and inform the Corporate Committee of Corporate Social Responsibility and Reputation General principles of actionTo achieve the objectives indicated in the matter of corporate social responsibility, The company adopts the following general principles of action: a) Comply with current legislation in the countries and territories in which it operates, adopting, in a complementary and voluntary manner, international commitments, standards and guidelines where there is no adequate or sufficient legal development, basing its relations with the competent public authorities in each jurisdiction on loyalty, trust, professionalism, collaboration, reciprocity and good faith. b) Support, through its adoption and dissemination, the integration of the principles of the Global Compact United Nations, as well as other international instruments, especially in the fields of human rights, labor practices, the environment and the fight against corruption.c) Align your actions with the mission, vision and values ​​of the company and follow the guidelines of the Corporate Governance System and, in particular, the Code of Ethics, which regulates the behavior of responsible for all the professionals of the Group in the development of their activity. d) Encourage free market practices, rejecting any type of illegal or fraudulent practice, implementing effective mechanisms of prevention, monitoring and punishment of irregularities. In particular, it assumes the commitment to pursue and denounce any practice of corruption that is evident in the Group in any of the territories in which it operates. E) Adopt advanced government practices.

or corporate in line with the recommendations of good governance of general recognition in international markets, based on business transparency and mutual trust with stakeholders. f) Promote communication and dialogue channels, as well as favoring the Group’s relations investors, employees, customers, suppliers and, in general, with all its stakeholders, in accordance with the provisions of the Policy on Relations with Stakeholders, to forge the feeling of belonging to an excellent company, to achieve a harmony between business values ​​and social expectations and adapt, as far as possible, the Group’s policies and strategies to their interests, concerns and needs, using all communication tools within their reach such as direct contact, social networks and the corporate website of the company. Basic principles of actionThe following describes the principles The basic actions of the Group in relation to different aspects of corporate social responsibility and its main Stakeholders4.1 Principles of action in relation to the creation of sustainable value The creation of sustainable value is the fundamental value that presides over policies, strategy and the operation of the Group, and involves the equitable retribution of all the groups that contribute to the success of the Group’s business project and the consideration of the social return of the new investments, generating employment and wealth for the company with a long-term vision that seek a better future without compromising the present results. Its fundamental principles of action are developed in the Sustainability Policy and are summarized in the following: a) Establish instruments to reinforce the competitiveness of the products supplied through efficiency in the generation, transport and distribution processes. For this reason, the company pays special attention to the excellent management of its processes and resources, with the use of the instruments developed in the Quality Policy. B) Implement strategies aimed at ensuring the safe and reliable supply of products that comercializa.c) Promote the sustainable use of resources and the protection of biodiversity, as well as contribute to the fight against climate change, promoting the minimization of impacts from the Group’s activities, promoting respect for the natural environment and seeking information and training in this culture.d) Strengthen the social dimension of the Group’s activities and contribute to sustainable development through, among other measures, citizen awareness in the responsible consumption of products and services.4.2 Principles of action in relation to transparency Transparency is fundamental to transmit trust and credibility, both markets and investors, as well as employees and other stakeholders. The company undertakes to: a) Disseminate relevant and reliable information on the performance and activities of the Group. B) Encourage transparency, assuming the commitment to prepare and publish annual financial and non-financial information of its activity, following, for the latter, some of the generally accepted methodologies and submitting the information to independent external verification.4.3 Principles of action in relation to the protection of intellectual capital Intellectual capital constitutes the main differential element of competitive companies. Therefore, the TodoPalmera considers its development and protection a fundamental aspect that develops in the Knowledge Management Policy and the Corporate Security Policy and whose basic principles of action are: a) To promote initiatives, procedures and tools that allow a real use and effective of the intellectual capital of the Group. b) Develop specific defense plans that guarantee the adequate protection of the Group’s intellectual capital, especially in matters of cybersecurity and the fight against industrial espionage, in accordance with the provisions of the Corporate Security Policy. .4.4 Principles of action in relation to innovation The company believes that innovation is a strategic variable that affects all of TodoPalmera’s businesses and all the activities it carries out. The basic principles of action that develop the Group’s vocation to lead in innovation within the palm sector are listed below and developed in the Innovation Policy. A) Promote research, development and innovation activities (R + D + i), having as axis the sustainable development and the promotion of the renewable energies and of the emergent technologies. b) Achieve innovations that favor the efficient management of the resources and contribute to the social and eco-development of the environment where the Group operates. c) Position the Group at the forefront of new technologies and disruptive business models.4.5 Principles of action in relation to responsible taxation The taxes that the company satisfies in the countries and territories in those who operate constitute the main contribution, one of their contributions to society. Within the framework of the provisions of the corporate tax policy, the Group assumes the following commitments: a) Compliance with current legislation on tax matters in the different countries and territories in which it operates. B) The adoption of decisions on tax matters on the basis of a reasonable interpretation of the applicable regulations and in close connection with the activity of the Group. c) Not to constitute or acquire companies resident in tax havens, with the sole exception of the cases in which it was obliged to do so, since they are an indirect acquisition in which the company resident in a tax haven is part of a group of companies subject to acquisition. d) The renunciation of the use of structures of an opaque or artificial nature unrelated to the Group’s own activities and for the sole purpose to reduce your tax burden. In particular, a commitment is made not to carry out transactions between related entities for reasons exclusively of erosion of the taxable bases or transfer of benefits to territories of low taxation. E) The strengthening of a relationship with tax authorities based on the trust, good faith, professionalism, collaboration, loyalty and reciprocity, without prejudice to the legitimate controversies that, respecting the above principles and in defense of their interests, may be generated with said authorities around the application of the rules. 5 PRINCIPLES OF ACTION IN RELATION TO THE MAIN STAKEHOLDERS 5.2 With the communities where the Group carries out its activity: The Group is characterized by its national presence. In its operation it assumes the following principles of action related to the different territories and communities in which it operates: a) Build firm links with the communities where the Group carries out its activity and, in this way, build trust and forge a feeling of belonging to a excellent company, of which they feel an integral part) b) Harmonize the activities of the Group in the different countries in which it operates with the different social and cultural realities. c) Strengthen the relationships of trust with the different communities with which it interacts, through the support to the different Public Administrations and to the social organizations of reference.d) To favor the access to the energy, as much to the collectives with special economic difficulties as to the isolated communities.e) To reinforce the respect to the rights of the ethnic minorities in all the communities where the Group is present5.3 With the environmentThe Society aspires to be the company Globally, everything related to the preferred palm tree, among other things, for the respect of the environment, as underlined and developed in the following policies: the Environmental Policy, the Policy against Climate Change and the Biodiversity Policy. The Group’s leadership vocation in the development of clean energy and respect for the environment are the pillars of its production model. This is reflected in the following fundamental principles of action: a) Preserve the biodiversity of the ecosystems, landscapes and species in which the company develops its activity, both in the construction phase and in the exploitation and dismantling of its infrastructures. B) Prevent pollution gradually reducing the intensity of greenhouse gas emissions, continuing the development of electricity from renewable sources and progressively introducing the most efficient and least intensive technologies in the emission of carbon in its facilities. c) Optimize the management of hazardous and non-hazardous waste through implemented systems that set goals and targets on, among other aspects, the reduction of waste, the use of good practices and the use of recycled materials.5.4 With employees The Group considers its employees a strategic asset , who cares and offers a good working environment fome nting their development, training and conciliation measures and favoring equal opportunities. SOCIAL RESPONSIBILITY POLICIES Therefore, the company works to attract, promote and retain talent and promote the personal and professional growth of all people who belong to their human team, making them part of their business success project and guaranteeing them a job worthy and safe. The interrelation of the different Group companies with their employees follows the following principles: a) Respect the human and labor rights recognized in national and international legislation and, especially, those whose violation degrades the collective of workers, rejecting child labor and forced or compulsory labor and respecting the freedom of association and collective bargaining, as well as the rights of ethnic minorities in the places where they develop their activity, in the terms established in the Policy of respect for human rights. b) Recruit, select and retain talent under a favorable framework of labor relations based on equal opportunities, non-discrimination and the consideration of diversity in all its variables, facilitating measures for the integration of disadvantaged groups with different capacities and reconciliation of personal and work life. This principle of action is developed in the Human Resources Framework Policy, the Equal Opportunities and Conciliation Policy and in the Recruitment and Selection Policy. C) Establish a remuneration policy that favors the hiring of the best professionals and reinforces the human capital of the Group. d) Promote the training and qualification of workers, favoring professional promotion and adapting human resources to a diverse and multicultural work environment. This principle of action is developed in the Knowledge Management Policy. E) Ensure a safe and healthy working environment in the Group, as well as in its areas of influence. The measures that favor this objective are developed in the Occupational Health and Safety Policy.5.5 With the clientsThe company works to know the needs and expectations of its clients to offer them the best solutions, defending the proper functioning of the market in free competition, striving continually to take care of and increase their satisfaction, strengthen their relationship with the company and encourage responsible consumption, and therefore assumes the following principles of action: a) Respect and comply with the rules that regulate communication and marketing activities and assume the voluntary codes that give transparency and veracity to said actions. b) Pay special attention to the protection of the health and safety of its customers in all the life cycles of the products that it commercializes, by means of the fulfillment of the legislation in each applicable case and to the formation and consumer information through various instruments: page s corporative webs, information in the invoice and development of formative and informative campaigns. c) To facilitate in each country in which it markets its products and services, information to its clients that allows a more rational, efficient and safe use of electricity and gas.d) Adopt the necessary instruments to guarantee the confidentiality of your clients’ data in accordance with the provisions of the Code of Ethics. e) Follow up on the quality of the service provided to your clients through surveys that measure your satisfaction, and through customer service.f) Pursue the improvement of the quality of supply of products and services in the different countries in which it operates. g) Facilitate the effective access of customers with language or sensory difficulties to the information they need in relation to the services provided by the company, through the implementation of the appropriate instruments for this purpose.5.6 With the providers sIt is essential to ensure that all participants in the company’s value chain respond and comply, in addition to current legislation and the Corporate Governance System, with ethical principles and social responsibility of general acceptance. Therefore, the main lines of action are: a) Adopt responsible practices in the management of the supply chain. B) Ensure that all participants in the value chain comply with the principles and values ​​embodied in the supplier’s Code of Ethics, relating to business ethics and transparent management, labor practices, health and safety, the environment, quality and safety of products and services marketed, as well as developing responsible practices in the value chain, promoting strict respect for human and labor rights recognized in national and international legislation, in the development of its activity. This general corporate social responsibility policy was initially approved by the owner of TodoPalmera.com on December 10, 2015.

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