Letter from the Chairman

Dear friends and partners,

As you know, Armando Alvarez, S.A. was founded on June 14th, 1954, and is currently the parent company of the Armando Alvarez Group. Its corporate object is to act as a Holding Company, participating in the management of the investee companies, providing them with support and carrying out complementary activities, such as research and development in the field of plastic materials.

Founded in 1964, the Armando Alvarez Group comprises several companies that joined us throughout the Group’s history. These are independent companies that form part of the same Group, and work under the same philosophy, ethics, and respect for the commonly accepted rules and principles.

Times change, and having fully reached its corporate consolidation, the Armando Alvarez Group wishes to prove its definitive and formal commitment, within the framework required by company activity at any given time, to the corporate standards for conduct established nationally and internationally. These mainly follow the recommendations given by the Organization for Cooperation and Economic Development. By applying these recommendations and the Corporate Government rules and principles, risks can be prevented and bigger goals can be met in future services provided to shareholders and in general to the national and international industry.

Aligned with the commitment to compliance with corporate rules and ethics, the Group has established:

– A Code of Good Governance for Directors, which is the code of conduct for Group company management activities.
– A Model for Prevention of Crimes as an instrument to prevent criminal conduct within the company.
– A Corporate Code of Conduct that is a public written statement of a set of principles/values in company conduct, as well as for the conduct of its executives and employees

Beyond mere compliance with legal obligations, we are working towards a better future for people, for our clients, our employees and for society in general.

These rules, approved by the Board of Administration that I chair, are a formal expression of this commitment.

José Ramón Alvarez Ribalaygua

Chairman

Good Governance Code

The Armando Alvarez Group is currently the largest Spanish processor of polyethylene plastic film. Comprised of a group of top-quality companies that complement each other, the Group is today part of a reduced group of companies that are leaders in their field in all of Europe. The current leadership position in the industry was achieved step by step, following a strategy of acquiring companies that complement the Group’s main product lines.

The corporate governance guides described in the Code complement the contents of the Corporate Bylaws of each company within the Armando Alvarez Group. Following the corresponding bylaws and applicable legislation framework, all of the Group companies implement this Code of Good Governance for Directors.

The Good Governance Code establishes the conduct guidelines for management of the companies comprised in the Group. It also reaffirms the existing commitment to observe ethical principles towards third parties linked to the company such as the Government, the community, shareholders and other investors. These principles are compulsory criteria in the interpretation and application of this Code, as are the vision, mission, corporate philosophy and strategic objectives.

– A global company
committed to your success.

– Tradition, respect for people,
integrity and environmental awareness.

Model Treaty for the prevention of crimes

Letter from the head of compliance

Dear colleagues and partners,

The Company Governing Board is responsible for designing strategy and approving Corporate Policies. As part of this responsibility it has implemented a Model for Prevention of Crimes and a Model for Corporate Conduct, to send a message of firm opposition to any illegal action by executives, employees or third parties related to the company, and to highlight the Company’s commitment to fighting them and preventing harm to its image and reputation.

To this purpose a group of measures was implemented aimed at preventing, detecting and reacting to possible crimes (committed within the company and for its direct or indirect benefit) and I have been appointed as the person in charge of criminal prevention. To notify me of any fraud or illegal activity that you become aware of you can contact me through the reporting channel set up on the company intranet, by filling in the forms available to this purpose, or by ordinary post sent to the company’s address, marked for my attention.

No retaliation will be accepted against those employees who in good faith report alleged violations. The company will penalize any illegal action in accordance with current labour laws, notwithstanding any other liabilities that may be incurred.

Jesús García Nieto

Compliance Officer

Company Code of Conduct

What is the Sotrafa Code of Conduct?

The Armando Alvarez, S.A. Code of Conduct is the core standard of conduct that the Company wishes to have observed throughout its corporate activity. This is a standard of conduct that is usually more demanding than the standard defined by applicable legislation in the various countries where the Company operates.

It is the expression of a series of principles/values for corporate behavior, as well as for Company executives and employees. The Corporate Code of conduct is also a written statement of the public commitment made by the Company to these principles/values.

The Code of Conduct was defined by the Governing Board/Board members as the maximum governing entity and it is a commitment of the highest level.