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The essential principles of Altamira Asset Management, S.A. (hereinafter the "Company") in its business are objectivity, integrity and transparency. In its commitment to follow these principles and ensure strict compliance (with the law, regulation and ethical standards) the Company encourages a corporate culture of compliance at all levels of the organisation. This also enables adequate management of the reputational risk to which all companies are exposed.

These commitments and the corporate culture of compliance are objectified, among other means, through a set of policies, procedures, codes of conduct and internal controls, the effectiveness of which is checked regularly to ensure that they are in line at all times with the prevailing situation.

The Code of Conduct is the key element in the programme defined by the Company for implementing the culture of compliance and the internal regulations governing the actions of all Company employees. As such, the Code of Conduct includes:

As regulated in the Code of Conduct, employees and third parties may submit a compliant when willing to report any actions presumably going against only the Code of Conduct, the law and current regulations and other internal conventions.

Part of the principles contained in the Code of Conduct are developed in specific internal policies and procedures where necessary. There are currently specific internal regulations on:

Other internal regulations, in spite of providing greater detail of the principles contained in the Code of Conduct, are defined to establish other important principles in different matters and are compulsory in the performance of the Company’s activities. These internal regulations include, among others:

Finally, after the publication of the Reform of the Penal Code, which entered into force on July 1st, 2015, the Company’s prevention system has been adjusted to the current legal requirements, as reflected in the new Manual on Criminal Risk Prevention.