263

2021 INTEGRATED MANAGEMENT REPORT

ACTIONS EVALUATED IN RELATION TO CORRUPTION RISKS IN 2021, 2020 Y 2019

2021 2020 2019

Number of internal audit projects with an anti-corruption and anti-bribery component 10 6 8

Number of Crime Prevention Model (CPM) controls that mitigate the risk of corruption within CPM controls 189 195 207

Number of ICFR controls aimed at mitigating fraud risk within ICFR controls

457 409 408

Number of audit projects on non-operated assets 6 4 5

Number of reviews of investment agreements and significant anti-corruption contracts (Know Your Third Party/KYTP analysis) 17 4 8

RESULTS OF THE COMPLAINTS RECEIVED ON BREACHES OF THE CODE OF ETHICS IN 2021

Not corroborated 20

Activation of disciplinary measures

Lay-offs 14

Suspension of employment and pay 25

Written warning 28

Activation of corrective measures

Communication action 9

Training action 3

Control measure 5

Work post transfer 1

Other 1

4.12.4 Conflict of interest

The 'Policy for the Prevention of Bribery, Corruption and Conflicts of Interest' and the 'Policy on Related-Party Transactions and Intragroup Transactions', updated in 2021, lay down the procedures for preventing and/or addressing conflicts of interest in which our shareholders, Board members, executives and other employees may find themselves in their relations with the company, as well as with respect to conflicts that may arise with customers, suppliers and other stakeholders.

In the event of a conflict of interest, both policies establish the duty to refrain from deliberations and decision-making, and from accessing confidential information, as well as the duty of transparency and proactive disclosure of conflicts of interest, and the duty to cooperate in resolving them.

The Ethics and Compliance Office requests an annual statement on conflicts of interest from executives, department heads and units considered to represent a risk.

In 2021, all identified conflicts of interest have been resolved or measures have been taken to mitigate the potential risk of fraud, in coordination with the Human Resources and Organisation Department.