ANTI-BRIBERY AND ANTI-CORRUPTION POLICIES

MUDANZAS Y GUARDAMUEBLES TRALLERO, S.A. and Z&C RELOCATION S.L. are committed to
doing business with integrity by complying with the laws applicable to certain international commercial activities such as the US Foreign Corrupt Practices Law (FCPA) and the UK Bribery Act of 2010.

In this policy:
“Bribery” consists of offering, promising, delivering, accepting or demanding any benefit as
part of an incentive to perform an action. It is illegal and constitutes a breach of confidence. A
bribe is an incentive or compensation which is offered, promised or delivered in order to gain a
commercial, contractual, regulatory or personal advantage.

Our commitment:
1. Not to engage in any form of bribery, be it directly or through third parties.
2. Not to offer or make improper payments, or authorise any improper payments (either in cash or any other means) to anyone, including local or foreign officials or civil servants in any
part of the world.
3. Not to mislead local or foreign individuals, officials or civil servants so that they may act
illegally or improperly.
4. Never to offer or accept either money or any object of value as gifts, bribes or commissions
with the aim of obtaining business or contractual benefits.

5. Never to offer or give any gift or symbol of hospitality to any public employee, official or
government representative if there is the expectation or implication of returning a favour.
6. Not to accept gifts from business partners if there is any suggestion either expected or
implicit of returning the favour.
7. Not to make any payments in order to receive a level of service which one would not
normally be entitled to.
8. Not to disregard or omit to inform the appropriate authorities of any sign of improper
payments.
9. Not to mislead or assist any persons in violating any applicable law or norm.
This policy applies to all employees and it is our expected that our collaborators comply with this policy.