Foreword

Pursuant to the Global Code of Conduct of the Kupertino Corporation, Corporation’s Corporate Social Responsibility, understood as a social and environmental commitment in the conduct of its business, benefi cial for all its stakeholders, is an integral part of its business model.

Goal

This Policy seeks to implement the above referred of the Global Code of Conduct, by aligning corporate citizenship initiatives carried out by the different companies within the Corporation Corporation with its group-wide corporate strategy. From an external perspective, this Policy seeks to encourage:

• Commitment to improving community wellness.
• Maximizing value created within the community.
• Improving the reputation of the Corporation Corporation and of its different companies.
• Creating legitimate trust within the stakeholders of the Corporation Corporation.
• Building customer loyalty.
• Building competitive advantages.

At any rate, this Policy for Investing in the Community must take into account the different stakeholders associated with the Corporation Corporation worldwide. From an internal perspective, this Policy seeks to encourage:

• The alignment of the corporate citizenship initiatives carried out by the different companies of the Corporation Corporation.
• Innovation and creativity.
• Encouragement of best practices.
• Encouragement pride in belonging to the company among employees.
• Maximizing value created at the company.

The Corporate Citizenship Policy must be a flexible working tool, which must be adapted to the development of the Corporation Corporation and which must allow cross-cutting learning between the different business units.

Authorized Bodies

The Heads and Sponsorship, made up of the General Counsel, the Chief Communication Officer, is the relevant body authorized to approve any contribution in the corporate citizenship area.

To achieve this, all motions regarding social initiatives shall be addressed to Corporation, which, after an initial assessment, shall be charged with submitting them to the Heads and Sponsorship for the final approval thereof, where appropriate.

Objective Scope

Corporate citizenship initiatives carried out by the Corporation Corporation must be related to the business drivers, and namely, they shall be focused on the following fi elds:

Projects Selection

Investments of the Corporation Corporation in the community are implemented through its collaboration in specifi c projects.

The Corporation Corporation will prioritize long term strategic initiatives in collaborations with the community for specifi c actions, always subject to an extensive monitoring and accountability process, versus any charitable gifts for the general purposes of charities. To achieve this, the following criteria shall be observed upon selecting the corporate citizenship projects:

• The degree of reputation, transparency and best practices of the charities charged with implementing the projects supported by the Corporation Corporation.
• Sustainability of collaborations both at economic and institutional level, for the purposes of preventing any dependency regarding projects and charities involved.
• Building value for the community and the Corporation Corporation in accordance with estimated outputs and impacts.
• Alignment with corporate interests and improvement of the reputation of the Corporation Corporation.

Territorial Scope

Pursuant to the estimate included of the Global Code of Conduct, the Corporation Corporation shall prioritize regular corporate citizenship projects, carried out at corporate level, in those areas where the Corporation develops its activity, namely, in such proceedings related to the supply chain. Likewise, the scope of action of the brands and subsidiaries of the Corporation Corporation in the social fi eld shall be linked to their local and national area, respectively, setting in proximity projects which maximize the positive impact within the infl uence area of their respective headquarters.

Types of Contribution

The Corporation Corporation will encourage, beyond cash contributions, contributions in kind made by the company, as well as contributions in time of employees, and their corresponding leverage. With this respect, the Corporation Corporation shall encourage engagement of its employees in the social commitment of the company, through different corporate volunteering schemes.

Measurement Outputs and Impacts

The Corporation Corporation will measure on a regular basis the outputs and impacts of social initiatives which make up its corporate citizenship policy.