Introduction

The code of ethical conduct is our guide to appropriate conduct, together with the established work standards and procedures, to guarantee what is correct and that, as a logical consequence, no crime occurs in the company.

The Code constitutes a guide for all employees of OXFORD OIL ADDITIVES SLU. in their professional performance in relation to their daily work, the resources used and the business environment in which they operate. This offers guidelines that clarify the basic principles of all management and interpersonal relationships with colleagues, collaborators, bosses, suppliers, clients, shareholders and in general any person with direct or indirect interest in the activity carried out by the company. Our actions are based on respect for our corporate values, and we employees will adapt our actions to principles of behavior that are respectful of business ethics and professionalism, with the aim of it being a benchmark in these terms and thus being recognized.

Scope of application

This Code is addressed to all employees of OXFORD OIL ADDITIVES SLU., regardless of the contractual modality that determines their employment relationship, position they occupy or the place in which they carry out their work. There is an obligation for those related to the company to inform their main suppliers of the existence of this Code, which will be available for consultation on the company's website https://ooadditives.com.

Values

Our values represent our identity as a collective. We are different because the people who work at OXFORD OIL ADDITIVES SLU. We make this company a unique and differentiating project. We are fast, we know how to listen, we seek innovation, we are helpful and we work as a team in a rigorous and transparent way. 

• We make quick decisions and act quickly and dynamically. 
• We quickly focus the solution to a problem by proposing realistic, quality and viable alternatives. 
• We adapt quickly to the changes and demands of the professional environment. 
• We listen carefully to our internal and external clients to know their exact needs and propose appropriate solutions. 
• We have the eyes and ears of the client in any operation we develop, continually asking ourselves about their satisfaction.
• We listen actively, with an open attitude and respect for the opinions of all parties involved in a situation.
• We actively seek opportunities to improve products and services and create new business opportunities.
• We take advantage of opportunities and problems to provide innovative solutions.
• We constantly update our technological knowledge to become pioneers in innovation.
• We know the needs and expectations of our clients to develop and apply solutions that increase their satisfaction.
• We serve our clients efficiently, maintaining at all times an agile and decisive behavior that enhances the credibility and reputation of the company and its professionals.
• We serve clients with the utmost interest and we strive to interpret their demands, this being the priority characteristic of the attitude of all our professionals.
• We know how to work in multidisciplinary teams, from different units, companies and countries, generating a climate of trust and mutual respect.
• We cooperate with the rest of the organization by assuming commitments aimed at achieving common objectives.
• We direct our efforts towards the same result, taking into account the contribution of each member, no matter how small it may seem.
• We respect differences, opinions and diversity.
• We are respectful of the environment and sustainability policies.

Principles of ethical behavior

The ethical behavior that governs this society is based mainly on:

Good faith

We adjust our actions at all times to the principles of loyalty and good faith with the company, with superiors, colleagues and collaborators with whom we interact. We emphasize the desire for achievement and the spirit of improvement. The concern to achieve the set objectives must be constant and continued. We promote optimistic versus pessimistic attitudes. We subordinate personal objectives to the general objectives of the Company. We ensure that there is no conflict between the two, and we act giving priority to the interests of the company over personal interests or third parties.

Honesty

All employees of OXFORD OIL ADDITIVES SLU. We undertake to declare any personal or professional relationship that could condition our behavior as employees of the Company. Furthermore, as employees of OXFORD OIL ADDITIVES SLU., we do not accept improper compensation or advantages. We instill honesty and professional ethics in normal business and professional relationships in the performance of our work, both in the private sector and in our relationships with companies.

Public administrations. We do not offer gifts, nor promise undue favored treatment to third parties, whether public or private, in order to obtain an advantage. We promote trust to declare the gifts or advantages that we may obtain from third parties and make them available to the company. Any personal or professional relationship that affects the interests of the Company is communicated to the immediate supervisor. We do not allow personal or family relationships in direct dependence or within the same organizational unit.

We avoid conduct that is contrary to free competition, or that involves an act of unfair competition. In advertising campaigns we offer information in a clear and truthful way.

Respect

Each and every one of us is responsible for generating an atmosphere of cordiality and kindness in our environment. We promote respect and trust between people. We appreciate diversity in opinions, training

and culture as a source of knowledge and competitive advantage. We take care of the language we use when talking about third parties and we encourage the non-existence of defamatory guidelines and comments inside and outside the organization.

We promote respect for real equality of opportunities between men and women, avoiding any scenario of direct or indirect discrimination. No person employed at OXFOR4D OIL ADDITIVES SLU.es is discriminated against in the professional field due to race, physical disability, religion, age, nationality, sexual orientation, sex, political opinion or social origin.

We maintain a work environment free of all discrimination and any conduct that involves personal harassment, not admitting any form of physical, sexual, psychological or verbal harassment or abuse. We respect the environment and collaborate with the sustainable development of society. 

Confidentiality

We refrain from providing, internally or externally, confidential data about people and/or activities carried out in the Company. 

We do, however, provide the data that is necessary for other employees of OXFORD OIL ADDITIVES SLU. perform their function correctly, with strict respect for this duty of confidentiality. We avoid conduct that is contrary to free competition, or that represents an act of unfair competition. In advertising campaigns we offer information in a clear and truthful way. Principles of ethical behavior, respect, confidentiality and use of information. We comply with the regulations for the protection of personal data in relation to those to which we have access due to our job. The employees of OXFORD OIL ADDITIVES SLU. We are characterized by a marked proactive attitude in the treatment of confidential information. The information is the property of the Company and should be shared whenever it is beneficial and necessary for it. In our conduct: 

We provide those responsible with truthful, necessary, complete and timely information about the progress of the activities in our area; and to our colleagues, that which is necessary for the proper performance of their duties. 

We maintain the professional secrecy of the data, reports, accounts, balances, strategic plans and other activities of OXFORD OIL ADDITIVES SLU. and its people, who are not of a public nature, and whose publicity may affect the interests of the company. We will not provide information about them, except when we are expressly authorized to do so.

We obtain information from third parties in an ethical and legitimate manner, rejecting all information obtained improperly or that involves a violation of company secrets or confidentiality. 

In the event that we have doubts about the appropriate treatment of the information, we request the assessment of our manager regarding its correct cataloguing. 

We will not be able to use for our own purposes, those of third parties, or to obtain benefit or profit, the programs, computer systems, manuals, videos, courses, studies, reports, etc., created, developed or perfected at OXFORD OIL ADDITIVES SLU. given that the company retains their intellectual property at all times. 

In general, we maintain the strictest confidentiality in the use of internal knowledge outside the scope of the company, preserving our know-how. 

We will only use computer systems, software, material, reports, etc. of which OXFORD OIL ADDITIVES SLU. has acquired the corresponding license, respecting at all times their intellectual and industrial property .

The use of computer equipment is subject to the information security policy of OXFORD OIL ADDITIVES SLU. with the aim of avoiding damage to third parties and/or the company itself. 

We will not use access to the systems to act fraudulently or for personal gain.

Decalogue of questions before making a decision

Asking yourself these questions will help you decide what behavior to follow.

1. Is it against work regulations?
2. Does it seem like the right thing to do?
3. Is it legal?
4. Will it have a negative effect on my reputation or that of the company?
5. Who else can be affected by this (other people in the entity, customers, suppliers? 
6. Would I feel ashamed if others knew that I had resolved to act this way?
7. Is there an alternative solution that does not raise an ethical conflict?
8. How would I look if I were published in the newspapers?
9. What would a reasonable person think? 
10. Will I be able to sleep peacefully?

Principles of professional behavior

Passion for the customer

All employees aspire to offer our customers a product of the highest quality and to have an excellent level of service. Excellence and quality of service are constant guides for action, promoting a healthy concern for continuous improvement. The resources provided by the company seek to promote innovation and the development of services to clients, with profitability criteria. All of us, regardless of the functional area in which we work, are committed to our client's satisfaction.

We promote honest attitudes towards the client. 

Efficient management 

The employees of OXFORD OIL ADDITIVES SLU. We work efficiently during the work day, making the most of the time and resources that the company makes available to us in a rigorous and rational manner. We all give the dedication required to perform our duties, aspiring to achieve results in the most optimal and productive way possible. The Company puts at our disposal all the necessary resources to carry out the work and improve performance through optimization of the time and scope of the information necessary to fulfill our responsibilities. Therefore, we must make appropriate and reasonable use according to each person's professional needs. We do not engage in personal activities during work hours that interfere with or prevent you from fulfilling job responsibilities. 

We use email, internet access and, in general, the Company's computer systems for exclusively work purposes, and their use for personal use is expressly prohibited.

We expressly authorize the Company to control their use. Unacceptable use of the company's communications systems includes processing, sending, retrieving, accessing, viewing, storing, printing or otherwise disseminating materials and information that are fraudulent, harassing, threatening, illegal, racial, sexist, obscene, intimidating, defamatory or otherwise incompatible with professional conduct. In terms of safety at work and professional health, we will comply with preventive measures, using the individual and collective means of protection that the company has available. In the case of having a team under their charge, those responsible will ensure that the members of said team carry out their activity in safe conditions.

Team attitude

The company's employees will favor teamwork and recognize the contribution of others in obtaining common results.

As members of a team we contribute with equal commitment both inside and outside our area. The attitude of teamwork predominates and stands out over any performance at the individual level. An outstanding individual is also outstanding because of his or her ability to work as a team, and therefore there is no conflict between this behavior and being excellent individually. Individual interest does not take precedence over the interest of the team. We avoid passive attitudes: we do not let ourselves go and we do not stay on the sidelines. We encourage enthusiasm and commitment to the group and therefore to the organization.

We act in a spirit of cooperation, making available to the other areas and departments of the entity the knowledge and resources that facilitate the achievement of the company's objectives. 

Take care of reputation 

We consider the image and reputation of the company as one of its most valuable assets to maintain the trust of its customers. We monitor respect and correct use of the corporate image and reputation by all people in the company's environment. The brand image is visually reflected with our company logo, of which there are rules of use that protect its use and that we must respect. We are especially careful in any public intervention, and must have the necessary authorization to intervene before the media, participate in professional conferences or seminars and in any media.

public dissemination, as long as they appear as employees of OXFORD OIL ADDITIVES SLU. We are all part of the corporate image and therefore

We assume ethical and responsible conduct that allows us to preserve the image and reputation of the company. At no time will we act by highlighting behaviors that could damage the image. Our way of communicating, conducting ourselves and our own personal image will be in line with the professional context in which we operate. 

Professional development 

Our professional growth and that of our teams is our key to being competitive. Employees are responsible for our professional growth, and consequently it is our duty to be permanently updated with the knowledge and techniques necessary for efficient

performance of our work. People with teams in charge must pay attention to the motivation and professional development of their collaborators, committing to providing them with development opportunities based on merit and their professional contribution. To do this, they will encourage their continuous learning, recognize their efforts specifically and objectively assess their achievements, drawing up the necessary action and support plans for their development. 

Entry into force of the code of conduct, interpretation and monitoring

The Code of Ethical Conduct came into force after its approval on January 2, 2023 . The Code of Conduct has been implemented and approved.

Ethics present, this being ratified and approved by Mr. Juan de Ros Rivero, on January 2, 2023 .

The Code will be communicated to all members of the Company. It will be in force until its modification or cancellation is approved, which will be duly communicated.

We each take it upon ourselves to review and follow this Code, and we comply with all applicable laws, policies and guidelines. This Code attempts to address many of the situations we face on a daily basis, but it cannot consider all circumstances.

Try to get help from:

• Your manager.
• Your HR manager H H.
• Your service coordinator if you are an external collaborator.

All professionals must inform our manager about any conduct that we believe, in good faith, is a violation of the Code of Ethical Conduct.

If any of the above three are involved in the situation we wish to report, or cannot, or have not adequately resolved our concerns, we will inform a more senior manager or HR manager. H H. of the area or the person in charge of criminal compliance of the company, and it is reported that all personnel have at their disposal an Ethical Channel through which it is possible to notify, in a totally confidential manner, behaviors or facts contrary to ethics, to current legislation. , to this Code of Conduct

Ethics or the good corporate governance practices that govern our Company, with special emphasis on those that could have criminal significance.

We do not discriminate or retaliate against employees for reporting, in good faith, actual and proven violations. The Appointments and Remuneration Committee will ensure compliance with this Code, resolve incidents or doubts regarding its interpretation and adopt appropriate measures for better compliance.

Failure to comply with this code may lead to the adoption of disciplinary measures, including the possibility of dismissal and, where appropriate, the exercise of appropriate legal action.