Conflict of Interest

The Company promotes a culture of ethical and values-based service, excellence and leadership. We believe that this corporate culture promotes the recognition for employees and officers of their duty to advance the Company’s interests and that of its stakeholders. No employee, officer or director may take advantage of their position or corporate property or information for personal gain.

Employees, officers or directors are prohibited from taking advantage of their position, from taking advantage of access to corporate property and proprietary information for personal gain. They are prohibited from appropriating for themselves, corporate opportunities for sales, purchases of products and services. It is the duty of each director, officer and employee to protect propriety and confidential information.

AboitizPower employees and officers are encouraged to promptly report any potential relationship, action or transaction that may give rise to a conflict of interest to the Human Resources Department or to the Compliance Officer. Directors are under the obligation to disclose any actual or potential conflict of interest to the Chairman of the Board, to the Corporate Secretary, and to the Compliance Officer.

All Directors are also required to abstain or inhibit themselves from any Board discussion or decision affecting their personal, business or professional interests. Legal proceedings involving Directors and Officers that could affect their ability and integrity to serve the Company are required to be disclosed to the Compliance Officer.

The Company adopted the Policy on Conflict of Interest in 2012 to set out the procedures that would ensure the integrity and transparency of all transactions between and among the Company or any of its subsidiaries, affiliates, associates, major shareholders, directors and officers. No issues relating to RPTs or conflict of interests have been raised in the past or in recent years.