Corporate

SAERCO’s Operational Safety Policy reflects our commitment to achieving, maintaining and promoting the safety of our navigation services by incorporating Operational Safety management into our processes by:

• Ensuring that the primary safety objective in the provision of our air navigation services is to minimise the possibility of air traffic accidents, to the extent possible.
• Ensuring that the highest priority is placed on achieving satisfactory safety levels in the air navigation services we render.
• Ensuring that everyone involved in the safety aspects of the air navigation services we render (ATS/CNS/MET) be individually responsible for his/her own actions; that managers be responsible for the safety outcomes of their respective departments or divisions; and that the supplier's top management assumes the overall responsibility for safety.
• Ensuring a formal, explicit and proactive approach to the systematic management of safety that allows us to meet the safety obligations inherent to the services we render and that is applied to all services and auxiliary measures under our control.
• Ensuring compliance with all legally mandated operating methods and procedures.

Providing air navigation services to the highest quality standards based on the competence and integrity of our employees and their commitment to the continuous improvement of processes in order to keep our customers fully satisfied with the air navigation services rendered by SAERCO.

The quality management system ensures the implementation of SAERCO strategies in line with the general objectives of the organization:

• Maintain high levels of safety
• Improve the capacity of the services provided
• Maintain high levels of quality
• Incorporate new technologies and work methodologies in air navigation services.
• Financial profitability and sustainable economy

SAERCO is committed to ensure adherence to company policies:

• Identifying and ascertaining the needs of the clients and users of our services. Working together to guarantee a high level of satisfaction.
• Ensuring compliance with the laws that apply to our services as well as the requirements of UNE EN ISO 9001:2008 and UNE-EN- ISO14001.
• Ensuring the availability of the human and material resources needed to fulfil the quality objectives, optimizing these resources through the establishment of operating methods.
• Ensuring compliance with the performance objectives of Air Navigation Services (ATS, CNS, Training, MET) by controlling service indicators.
• Promoting on-going safety and quality training. Ensuring that all staff are aware of and strive to achieve the Company's objectives.
• Promoting the continuous improvement of SAERCO’s processes to ensure the effectiveness of the Quality Management System.
• Ensure a rational use of natural resources, raising awareness among staff with regards to energy saving, waste reduction and recycling.
• Establish energy efficiency measures.
• Develop new work methods by applying the latest generation of technology.

The director general guarantees compliance with this policy throughout the organization

November 2017

Jorge Avila, General Manager

The provision of air navigation services is SAERCO’s primary purpose, planning and rendering these services safely and efficiently under the government's jurisdiction. In order to render these services, SAERCO needs a series of assets that must be protected. Physical Safety protects them from a wide range of threats so as to ensure the continuity of our operations, minimise damages and maximise the company's productivity. SAERCO’s physical safety system is based on the following cycle:

• Everything starts with the knowledge and experience of the people who are responsible for safety and the users, who design the right level of security, in terms of both size and capabilities, for the Operating Units to be protected.
• A method is chosen and designed to apply this knowledge, combat threats and take the necessary protective actions.
• Useful information is recorded and used to improve system management. This step adds to the experience and knowledge base and commences a cycle of positive feedback.
• A process of periodic centralised reviews checks the operation of the system, providing new information that increases knowledge, enhances the defined process and increases the recorded information.

All SAERCO staff and visitors or users of the Operating Unit to which the policy applies must adhere to it and must comply with and enforce the standards and procedures derived from it.

The provision of aeronautical and air navigation services in all its forms is SAERCO’s primary purpose, planning and providing these services securely and efficiently under AESA supervision.

For the secure provision of the same, SAERCO needs to protect the information that it guards and manages, for which it has an Information Security Management System through which to manage the critical information that must be protected. Information Security ensures it protection against a wide range of threats and cyber-threats, in order to maximize the Confidentiality, Integrity and Availability of this information, depending on its relevance or criticality in the provision of services.

Information security is the set of measures, controls, procedures and actions coordinated to meet the basic aspects essential to protect the information managed by SAERCO:

• Avoid interruptions/alterations of information, preventing the occurrence of incidents that affect the Confidentiality, Integrity and Availability of information, through the provision of security measures and controls.
• Minimize damage, either by preventing incidents from occurring or by reducing the impact when they do. That is, to avoid deviation of processes and operations from what was planned.
• Facilitate the continuity of operations, quickly resolving deviations and promoting the use of alternative valid information in case of loss of any critical information.

SAERCO’s security information system is based on the following cycle:

• It starts with the knowledge and experience of the people who participate in cybersecurity and those who are users of information to design the appropriate level of security for the Operational Units to be protected.
• A method is chosen and designed to apply this knowledge, to combat threats, cyberthreats and and cyberincidents and take the necessary protective actions.
• Useful information is recorded and exploited to improve the system management. This step increases knowledge and experience and engages in a positive feedback cycle.
• A periodic centralized review process checks the functioning of the system, providing new information that increases knowledge, improves the defined processes and increases the recorded information.

All SAERCO personnel and visiting personnel or users of the Operating Units for which this policy is created shall respect, comply with and enforce the rules and procedures derived from it.

This information security policy is valid from the moment it is published until it could be totally or partially modified.

Pablo de Miguel
Chairman
May 2023

The Code of Conduct of SAERCO sets out the ethical values and principles that must be followed by SAERCO in the performance of its professional responsibilities.

The aim of this Code of Conduct is to ensure professional, ethical and responsible behaviour by SAERCO and all its employees, managers and directors in the performance of their activities in whatever country they are carried out. It is therefore a guide for action to ensure said behaviour, as a fundamental element of its business culture.

The principles and values set out in this Code must govern SAERCO's relations with its stakeholders (employees, customers, shareholders, partners and other companies or associations of any type, collaborators with which it performs its business model, and suppliers)

This Code of Conduct also sets out that it is mandatory to establish the prevention and control elements necessary to ensure that SAERCO, and the people who form part of it, comply with the principles and values set out herein and with the legislation in force in each one of the countries in which it operates, including that which relates to preventing punishable conduct.

With regard to voluntary standards of conduct, the company assumes as basic guidelines the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the UN Global Compact, among others.

1- PURPOSE

The purpose of this Code is to reflect the corporate ethical values and principles that must guide the behaviour of SAERCO, its employees, managers and directors in the performance of their activities in whatever geographical and functional location they may be.

Therefore, this Code:

- Facilitates the knowledge and practice of SAERCO's corporate culture, based on respect for human and social rights and on compliance with the law and the company’s ethical values.

- Establishes the principle of prevention, detection and eradication of irregular conduct by means of the appropriate procedures, including risk analysis, definition of employees’ functions and responsibilities, procedures for detecting and eliminating irregular conduct and employee training in all these matters.

- Raises awareness in SAERCO’s employees, managers and directors of the repercussion that their actions may have on the company’s image and reputation, and on its criminal liability, bearing in mind the principle of the criminal liability of legal persons.

- Compliance with the Code is mandatory for everybody in the company, which includes all personnel, irrespective of the position and function they discharge: employees, managers and directors.

- Application of this Code may be extended to any natural or legal person related to SAERCO, where this is beneficial for compliance with its purpose and possible according to the nature of the relationship.

2- ETHICAL COMMITMENT. BASIC PRINCIPLES

This Code of Conduct, as an ethical commitment, includes SAERCO's basic principles and standards of action.

Compliance with such basic principles and standards is embodied in the following commitments:

2.1 - Knowing and complying with internal rules and external regulations or applicable legislation

It is an obligation for the people who make up the company to comply with the provisions of this Code of Conduct and the internal rules for implementing it, as well as the legislation in force in the place and the function where their responsibilities are carried out.

It is also an obligation of the people who form part of SAERCO to comply with any requirements that the company may implement in ethical and compliance matters, including the procedures implemented to prevent, detect and eradicate irregular conduct. It is also a requirement to attend training courses.

2.2 - Compliance with ethically and socially responsible conduct, with preferential attention to people.

The conduct of the people who form part of SAERCO will be covered at all times by:

- Respect for the human and social rights of people, who will at all times receive fair and dignified treatment

- The provision of services to customers with a high standard of excellence, quality and safety in its services

- The protection of the company’s corporate interests, understood as maximising the company’s value.

- Protection of SAERCO's information and knowledge

- Environmental sustainability

All of this is based on the conviction that the people who make up SAERCO are an essential part of the company and that the relationships between them must be governed by respect for human values such as tolerance and solidarity.

2.3 - Compliance with ethically and socially responsible conduct in relations with third parties.

The company applies a model based on the principle of due control to prevent, detect and eradicate irregularities and to respond to such irregularities. For this purpose, the conduct of SAERCO and its personnel will be governed by:

- The extension of this conduct to business partners

- The requirement that suppliers comply with this Code of Conduct and all or part of its implementing rules by including the appropriate Clause in the agreements with suppliers.

- Cooperation with local and international bodies in the places where it operates in the prevention, detection and eradication of irregular or illegal actions.

3.- RESPONSIBLE PRACTICES AND CONDUCT COMMITMENTS

The Code Conduct sets out specific guidelines for action in relation to different contents:

3.1 - Respect for the law

All persons must know the laws that affect their work, requesting, where appropriate, specific information from their superior or from the corresponding agencies, in the event that they do not have such information.

All persons who form part of SAERCO must comply with:

- The laws in force in the countries where they perform their activity, obeying the spirit and the purpose of such laws, and conducting themselves in an ethical manner in all their actions.

- The company’s rules and procedures, as well as any instructions issued for their implementation.

Similarly, they must avoid any conduct which, even though it may not break the law, may harm the company’s reputation with regard to the national or international community, or negatively affect its interests.

3.2 - Relations with employees. Respect for people and human rights.

SAERCO believes that people are the key and fundamental element for the company. It is therefore committed to complying with human and employment rights. It promotes the defence, respect and protection of both basic employment rights and the human rights and public liberties recognised in the Universal Declaration of Human Rights.

Consequently, SAERCO undertakes to apply external and internal rules and regulations on employment conditions and occupational health and safety.

SAERCO's personnel will cooperate in compliance with employment and occupational risk prevention legislation, as well as in the prevention, detection and eradication of irregularities in such compliance.

In this regard, SAERCO’s personnel will report any hazardous situation that comes to their knowledge, as well as any possible ineffectiveness or inadequacy of the protective equipment. They will also avoid engaging in conduct and performing or cooperating in actions that might endanger their own safety or that of third parties, as well as imposing employment or safety conditions on third parties that harm, remove or restrict their right to safety.

SAERCO rejects discrimination on the basis of gender, race, disability, sexual orientation, religious beliefs, political opinions or any other status, such as age, that might be the cause of discrimination.

Professional selection and promotion processes, as well as training processes, are based on equal opportunity.

SAERCO rejects any manifestation of physical, psychological or moral harassment or abuse of authority, as well as any other conduct that may create an intimidating or offensive environment for people’s rights. The personnel will cooperate in the prevention, detection and eradication of these behaviours.

The personnel are required to act with respect for people, whether they are colleagues, superiors or subordinates, encouraging cordial relationships and a pleasant and safe work environment.

SAERCO guarantees its employees’ freedom of association, opinion and expression, as well as the right to collective bargaining.

SAERCO’s personnel must act with honesty and integrity in all their contacts, negotiations or agreements with the authorities and officials of local, national and international administrations, ensuring that all the information and documentation that they provide to them are accurate and reflect the reality of the company.

3.3 - Relations with customers

SAERCO is committed to the high quality and safety of the services it provides, allocating the necessary resources to achieve excellence and establishing appropriate measures to ensure that its quality standards are met.

All SAERCO people, in the performance of their functions, will act in compliance with the aforementioned quality standards, as well as with the other quality rules and procedures established for this purpose.

The personnel must act in an honest manner with their customers, with the objective of achieving the highest quality levels, excellence in the provision of the service and the long- term development of relationships based on trust and mutual respect.

The information provided to customers will be sufficient and truthful so as not to mislead or encourage them to make the wrong decisions.

Finally, SAERCO personnel may not give, either directly or indirectly, payments, gifts or compensation to the personnel of a Customer or possible Customer, when the gifts are not considered typical in the normal course of business, so as to prevent them from attempting to influence the adoption of an advantageous decision for SAERCO by the Customer or potential Customer.

In addition, SAERCO personnel may not accept, either directly or indirectly, gifts or compensation of any type which may be aimed at improperly influencing their commercial, professional or administrative relationships.

3.4 - Relations with authorities and officials

SAERCO personnel will interact with the local, regional and national Public Administrations of any country in which they provide their services in an ethical manner, complying with the provisions of this Code and the applicable legislation, paying particular attention to international provisions on prevention of corruption and bribery.

SAERCO will not allow behaviour aimed at influencing the will of authorities or officials of the public administrations in order to obtain any benefit through the use of unethical practices. It will also not allow other persons or entities to use these practices with its employees.

Therefore, SAERCO personnel may not give, either directly or indirectly, payments, gifts or compensation to the personnel of Public Administrations, when these are not considered typical in the normal course of business, so as to prevent that they might attempt to influence the adoption of an advantageous decision for SAERCO or for the employee.

In addition, SAERCO personnel may not accept, either directly or indirectly, gifts or compensation of any type which may be aimed at improperly influencing their commercial, professional or administrative relationships.

3.5 - Relations with Suppliers

SAERCO personnel shall interact with their suppliers in compliance with ethical principles and applicable legislation.

Suppliers will be selected by SAERCO by applying the principles of transparency, objectivity, non- discrimination and competition, reconciling the achievement of the best conditions for the company with a stable relationship with ethically responsible suppliers.

No SAERCO employee may offer, give, request or accept, either directly or indirectly, presents or gifts of any nature that might influence the decision- making process relating to the functions of their position.

Any present or gift that fails to comply with the above will be returned and the fact brought to the attention of the Compliance Committee.

3.6 - Loyalty to the company and conflicts of interest

Conflicts of interest arise when people are faced with a situation in which one of their decisions may be of benefit for themselves or for a third party with which they have a family, emotional or business relationship.

During the performance of their professional responsibilities, SAERCO personnel must act loyally and in defence of the company’s best interest. They must also avoid situations which might lead to a conflict between their personal interests and those of SAERCO.

They shall not participate in processes or decisions in which there may be deemed to be a conflict between their own interest and that of the company and they shall not take advantage of opportunities of which they have become aware or received information in the performance of their professional responsibility

SAERCO believes that the relationship with people should be based on loyalty born of common interests. In this regard, it will respect the private sphere of its personnel’s decisions and, therefore, the participation of its employees in other financial or business activities, providing they are legal, do not constitute unfair competition or a conflict with their responsibilities as SAERCO employees and do not undermine the effectiveness of the performance of their functions in the company.

In the event that any conflict of interest, whether personal or relating to a family member, arises that may compromise the professionalism of the employee, director or manager of SAERCO in the performance of their functions in this company, said employee shall inform the Compliance Committee so that it may, respecting the person’s confidentiality and privacy, take the appropriate measures.

3.7 - Use and protection of SAERCO assets

SAERCO makes available to the people in the company the resources necessary to perform their professional activity and undertakes to provide the means to protect and safeguard such resources.

All personnel shall use the company’s resources responsibly, efficiently and appropriately in the context of their professional activities. Furthermore, they must protect and preserve them from any improper use that may be detrimental to the company’s interests.

SAERCO personnel shall not use the resources made available to them for their own benefit. They shall also not make use of them for illegal purposes or for any other purposes which, without being unlawful, may harm the image and reputation of the company, the interests of its customers or third parties or negatively affect their performance or the functioning of the IT systems of the company or of third parties.

Specifically, the company’s personnel shall not install, download or use, in the computer equipment that the company makes available, programs, applications or contents whose use is illegal, which are in violation of the company’s rules or which may harm its reputation. Furthermore, they must not access the equipment of third parties without having received express authorisation to do so.

Similarly, it is not permitted to download, view or distribute material that is illegal, that violates the rights of third parties or which may be offensive due to its violent or sexual nature.

SAERCO personnel shall not use the company's funds or cards to pay for actions that are not part of their professional activity.

3.8 - Protection of the information and knowledge of SAERCO

SAERCO personnel members are obliged to protect the information and knowledge generated in, and belonging to, the company, as well as the information and knowledge which it has the right to use for a particular purpose, and which it safeguards.

SAERCO personnel shall use the data, documents or information obtained during the performance of their responsibilities in accordance with internal regulations and legislation on the matter. On a general basis, and unless otherwise indicated, the information to which SAERCO personnel have access must considered confidential and may only be used for the purpose for which it was obtained.

SAERCO personnel must respect the personal and family privacy of those people whose data they have access to in the performance of their functions in the company. The personnel must comply with the internal regulations and applicable legislation for the proper processing of the information. They must also comply with regulations on data protection, including internal procedures relating to storage, custody and access to data with the appropriate security levels.

SAERCO personnel shall notify the competent Department of any incident they detect relating to information confidentiality or data protection.

SAERCO personnel shall maintain the confidentiality of the confidential information and shall not disclose it to third parties, except in compliance with applicable regulations. In this case, and in the exercise of their responsibilities, SAERCO personnel shall provide accurate and comprehensive information. Under no circumstances may they knowingly provide incorrect, inaccurate, imprecise or misleading information.

3.9 - Protection of intellectual and industrial property

SAERCO is committed to the protection of its own and third- party intellectual and industrial property rights.

SAERCO personnel shall take the necessary measures to protect such rights, ensuring that processes and decisions in this matter are documented and verifiable.

The intellectual and industrial property resulting from the work of SAERCO personnel during the term of their contract with the company, and which is related to the company’s present and future business, is the property of SAERCO.

3.10 - Recording transactions

All material transactions performed by the company will appear in the appropriate accounting records that represent the true and fair view of the transactions performed.

SAERCO personnel shall enter the financial information clearly and precisely, in compliance with accounting policies, and it will be subject to the applicable control systems and supervision mechanisms, as well as the process controls for managing and safeguarding information of this nature.

3.11 - Environmental commitment

SAERCO personnel shall perform their activity promoting the company’s environmental sustainability as a route for the responsible creation of value among all its stakeholders.

In this regard, the company promotes environmental commitment among its suppliers, contractors and partner companies. The organisations that work with it must conduct their activities in line with the environmental protection guidelines and principles established by the company.

4.- ACCEPTANCE OF AND COMPLIANCE WITH THE CODE OF CONDUCT

This Code of Conduct will be communicated to all the people in SAERCO that join or form part of the company, including directors, managers, employees and any person representing them, who must undertake in writing to comply with it. Similarly, the obligation to comply with the Code will be expressly set out in their employment contract. Employees will be given a copy of the Code prior to signing the Contract.

The company will oversee compliance with this code by each person in SAERCO so as to ensure said compliance. In the event of non- compliance, the procedures established in the Collective Bargaining Agreement and applicable internal regulations shall apply.

Any doubt that may arise with regard to the interpretation or application of this Code of Conduct must be consulted with the hierarchical superior or, when necessary, with the Compliance Committee.

No person may justify improper conduct on the basis of an order from a superior or ignorance of this Code.

5.- COMPLIANCE COMMITTEE

The Compliance Committee is a body that reports hierarchically to the Sole Director of SAERCO. Its functions are set out in the Code of Conduct and its implementing rules and regulations, including the Criminal Risk Prevention Programme.

The main functions of the Compliance Committee are as follows:

- Promoting the dissemination, knowledge and fulfilment of the Code of Conduct.

- Interpreting the Code of Conduct and guiding actions in the event of doubt.

- Resolving conflicts relating to application of the Code of Conduct.

The Compliance Committee will be made up of the SAERCO President, who will chair the committee, the Human Resources Director as member, the Economic- Financial Director as member, the Quality Director as member, the General Manager as member and the Compliance Officer as Secretary. The operating and decision- making rules of this Committee are set out in the Regulation of the Compliance Committee.

6.- VALIDITY

This Code was approved by the Management Body of SAERCO on 15 November 2019, following the review and update of the Code corresponding to the 2018- 2019 period and it enters into force on the same day of its approval. It therefore repeals and replaces the Code of Conduct approved by the Management Body of SAERCO on 15 November 2017.

It will be reviewed and updated periodically by the Sole Director, following a proposal by the Compliance Committee, which will take into account for this purpose the suggestions and proposals made by SAERCO personnel.

Pablo de Miguel
Charmain
Noviembre2019