ANTI-BRIBERY POLICY

GENERAL STATEMENT

TGC is committed to applying the highest standards of ethical conduct and integrity in its business activities in Spain and overseas. Every employee and individual acting on TGC’s behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.

The personnel of TIERRA GLOBAL COMMODITIES (TGC) and its related companies, and any third party acting on their behalf, are against all forms of acts of corruption and will promote actions to ensure that they do not materialize in business activities, and in any inherent to their position or representation, taking into consideration all national and international regulations and initiatives that establish practices against bribery and corruption.

For us at TGC it is essential that suppliers, contractors and customers share the principles of integrity and corporate ethics, as well as developing actions that promote similar principles to those we have established.

The strengthening of transparency, accountability and the fight against corruption are fundamental aspects for us to make institutional decisions in our company, which encourages us to renew and permanently implement mechanisms within the entire organization to prevent any practice that is contrary to our values and ethical principles.

Therefore, this Anti-Corruption Policy (ACP) applies to all direct employees of TGC and all its “Subsidiaries” worldwide, and includes its Directors and Agents, regardless of the country of which they are citizens. To ensure compliance, TGC will put in place the necessary controls and procedures to identify, detect and prevent potential fraud and/or bribery and establish a Corporate Culture where procedures and the behavior of its Team members go hand in hand.

ANTI-BRIBERY POLICY
TGC is committed to applying the highest standards of ethical conduct and integrity in its business activities in Spain and overseas. Every employee and individual acting on TGC’s behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.