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CORPORATE SOCIAL RESPONSIBILITY POLICY Approved by the Board of Directors of El Corte Inglés, S.A., in Madrid, on 28th/February/2018

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Page 1: CORPORATE SOCIAL RESPONSIBILITY POLICY · El Corte Inglés, S.A. and the companies of its Group consider their employees as strategic collaborators who are vital for their business

CORPORATE SOCIAL RESPONSIBILITY POLICY

Approved by the Board of Directors of El Corte Inglés, S.A., in Madrid, on 28th/February/2018

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This document contains confidential information and material owned by Informática El Corte Inglés. The materials, ideas and concepts contained in this proposal are to be used exclusively for the purpose of evaluating the capabilities of Informática El Corte Inglés and must not be disseminated beyond your organisation or used for any other purposes than those mentioned above. This document may not be reproduced in full or in part, nor used for any other purpose with other organisations without prior written authorisation.

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ÍNDICE DE CONTENIDOS

1 . INTRODUCTION ................................................................................................................... 4

2 . AIM ..................................................................................................................................... 5

3 . PRINCIPLES .......................................................................................................................... 5

4 . SPHERE AND COMMITMENTS .............................................................................................. 6

5 . MANAGEMENT, REVIEW AND COMMUNICATION: ........................................................... 10

6 . APPROVAL, ENTRY INTO EFFECT AND UPDATING ............................................................ 10

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1. INTRODUCTION

El Corte Inglés has always been a pioneering company in Corporate Social Responsibility (CSR). From its foundation, and following clear action guidelines, it has developed a concept of integrity in business, as well as respect for and promotion of the common good, based on four key principles:

● Priority of customer satisfaction as the company's raison d'être,

● Involvement of the workforce in the business,

● Stability and collaboration with suppliers, and

● Integration into the community and the surroundings, participating in their events and sharing their concerns.

Those lines of action have evolved through to the present day, without losing their essence. Thus, El Corte Inglés, S.A. and the companies of its Group conceive of CSR as an integral part of their management systems, considering it a factor in competitiveness and a fundamental part of the policy of engagement with society. That is why El Corte Inglés, S.A. and the companies of its Group have, from the outset, assumed a commitment, as socially responsible companies which seek to develop and maintain constant, fluid relations with all the stakeholders with which they interact. In addition, in accordance with current legislation, ECI is classified as a public interest company, with the demands that entails.

The Corporate Social Responsibility of El Corte Inglés, S.A. and the companies of its Group is based on a series of commitments acquired by its Board of Directors, including:

● Adhesion to the United Nations Global Compact, which means adopting the principles of respect for human, labour and environmental rights and the fight against corruption which comprise that international code of ethics.

● The implementation of a Letter of Commitment with its providers, as a code of ethics for action and mutual trust.

● Integration into international initiatives which seek a guaranteed standard of respect for human and labour rights, with the main objective of advancing in the fulfilment of social responsibility in the supply chain.

● The ratification of the Children's Rights and the Business Principles of UNICEF (United Nations Children's Fund) as the formalisation of its active commitment to the rights of children and young people.

● Adoption of the Global Code of Ethics for Tourism, developed by the World Tourism Organization, an agency of the United Nations.

Social responsibility makes it possible to reconcile the social interest of El Corte Inglés, S.A. and the companies of its Group with those of all the stakeholders who may in some way be affected by its business, thus recognising the influence of its activities on the community to which it belongs and on its environment.

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2. AIM

With this CSR Policy, El Corte Inglés, S.A. and the companies of its Group seek to construct a reference framework designed to enable them to continue to promote and develop responsible social and environmental behaviour by their managers, employees, suppliers, shareholders, customers and other stakeholders, to place El Corte Inglés in the position of leadership which corresponds to it as a public interest company.

The CSR Policy is strategic to the extent that it contributes to the achievement of the Mission, Vision and Objectives of El Corte Inglés, S.A. and the companies of its Group, and it seeks to position ECI as a benchmark in Spain and Portugal of a model of responsible behaviour and sustainable quality.

Its aim is to foment a corporate culture of social responsibility, of a transversal nature, which contributes to the generation of trust and shared values. It is based on behaviour which is coherent with sustainability and open to exchange with society and citizens, employees and shareholders, customers, suppliers and public institutions, organisations and administrations with which it coincides in the quest for the common good. All of this with a long-term vision which makes job creation, the obtainment of corporate profit and the generation of wealth for society compatible, preserving the resources of future generations.

Likewise, as a signatory to the United Nations Global Compact, El Corte Inglés, S.A. and the companies of its Group, in their business activities and through the CSR Policy, also incorporate the commitment to working to achieve the Sustainable Development Goals adopted on the 25th of September 2015 in the Assembly of the United Nations.

3. PRINCIPLES

This Policy is based on the Code of Ethics of El Corte Inglés, S.A. and the companies of its Group, which establishes the general and specific action principles of the companies with regard to their employees, suppliers and stakeholders.

The CSR Policy of El Corte Inglés, S.A. and the companies of its Group is based on the following general principles:

1. Fulfilment of the commitments voluntarily acquired by El Corte Inglés, S.A. and the companies of its Group related to CSR at national and international level;

2. Compliance with current national and international laws and regulations in the countries in which the ECI Group operates;

3. The maintenance of good corporate governance practices;

4. Active communication and dialogue with employees, shareholders, customers, suppliers and all stakeholders;

5. Respect for Human Rights, through the instruments of the United Nations, in particular:

a. The Global Compact.

b. The Guiding Principles on Business and Human Rights

6. The Defence of Labour Rights, in particular those highlighted in the Fundamental Conventions and Recommendations of the ILO (International Labour Organization).

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7. Promotion of the intellectual capital of its employees, ongoing training, professional promotion, the promotion of equality of opportunities and support to diversity, combating discrimination in all its forms.

8. The conservation and proper management of the environment, including animal welfare and the preservation of biodiversity.

9. The fight against any form of corruption and fraud.

10. Transparency in communication, as a fundamental factor to convey trust and credibility.

4. SPHERE AND COMMITMENTS

The CSR Policy is applicable to everyone who provides services for El Corte Inglés, S.A. and the companies of its Group which adhere to it, their directors, executives and employees, as well as all the companies which have contractual relationships with them.

Approval, modification or replacement of this Policy, where applicable, is the competency of the Board of Directors.

The adhesion of the companies of the El Corte Inglés Group to this Corporate Compliance Policy must be formalised by means of decisions of their Administrative Bodies.

This Policy is structured around the three dimensions of CSR - economic, social and environmental - in commitments which impact five areas which, in line with the Group's business model, are focussed on:

1. A committed team;

2. Commitment to customers;

3. Commitment to the value chain;

4. Commitment to the Environment;

5. Commitment to Society.

Responsible action commitments

A. A committed team

El Corte Inglés, S.A. and the companies of its Group consider their employees as strategic collaborators who are vital for their business activities. Therefore, El Corte Inglés is committed to offering them a good working environment, and to fostering their promotion and ongoing training, starting with the guarantee of decent, secure jobs.

As part of its commitment to excellence in customer service, employee motivation and pride in belonging play a key role in maintaining a committed team. For that purpose, El Corte Inglés, S.A. and the companies of its Group will constantly strive to:

a. Develop and maintain at all times a favourable framework of labour relations based on guaranteeing stable employment and fair pay, equality of opportunities, non-discrimination and the consideration of diversity in all its forms, facilitating measures for the employment of vulnerable groups and people with different abilities, as well as the work-life balance.

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b. Fulfil the objectives agreed to in the framework of the Equality Plan.

c. Promote workers' training, favouring professional promotion and paying particular attention to everything related to change and the digital transformation of activities.

d. Inform all employees of relevant activities related to CSR carried out by the Organisation, training them in particular in those practices related to their jobs.

e. Make talent management and career plans an engine driving development, making the best use of intellectual capital and the ability to innovate, which are keys to motivation and excellence in the service.

f. Ensure a safe and healthy working environment in the ECI Group, as well as in its spheres of influence.

g. Promote staff participation and engagement through corporate volunteering plans as a way of reinforcing involvement in the community and the surroundings, through the social action projects developed by El Corte Inglés, S.A. and the companies of its Group.

B. Commitment to customers

Striving for excellence in serving our customers, quality services and guarantees in the range of products characterise the commitment of El Corte Inglés, S.A. and the companies of its Group to their customers. As well as seeking to anticipate their needs and demands in order to offer them the best service, El Corte Inglés also pledges the following:

a. To strive to ensure customer satisfaction at all times, creating an environment which provides a positive experience, exceeding their expectations.

b. To ensure the health, well-being, protection and safety of its customers in all the products and services it markets, seeking to go beyond mere compliance with the legislation applicable in each case, and particularly emphasising the quality of the information provided to consumers.

c. To improve the accessibility of customers with disabilities and provide them with the necessary information in relation to the products offered and the services provided, by means of the implementation of the appropriate instruments to that end, in both physical and digital environments.

d. To promote responsible, sustainable consumer habits, increasing the offer of sustainable products and services and adopting an approach which takes into account the life cycle of the product and the promotion of the circular economy.

e. To adopt the instruments necessary to guarantee confidentiality of its customers' data.

f. To monitor the quality of the service provided and measure their level of satisfaction.

C. Commitment to the value chain

El Corte Inglés can only fulfil its mission thanks to intensive, long-term collaboration with all the people and companies which participate in its value chain. With all of them, it shares the guarantee of quality, the commitment to innovation and the need to anticipate and satisfy new customer requirements. To that end, a special framework of collaboration is established with the suppliers, with which the commercial offering is materialised.

In this regard, it seeks to ensure that all the participants in the value chain of El Corte Inglés, S.A. and the companies of its Group share the principles and values set out in its Code of Ethics, by signing the Letter of Commitment. That includes the fulfilment of current

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legislation, international conventions, respect for human and labour rights, as well as the international standards adopted by El Corte Inglés, S.A. That is why El Corte Inglés, S.A. and the companies of its Group undertake to:

a. Offer sincere, balanced, transparent relations with their suppliers, based on the fulfilment of mutual commitments and recognition of the value contributed.

b. Promote, throughout the value chain, respect for human rights, reflected in both the International Bill of Human Rights and the ILO Declaration on fundamental rights at work, establishing for that purpose mechanisms for the verification of their fulfilment.

c. Maintain responsible practices in supply chain management, in terms of both social and environmental aspects and animal welfare. That includes scrupulously evaluating the potential risks and exercising due diligence by means of instruments for the assessment of CSR performance by its suppliers, commercial partners and the logistics chain, promoting constant improvement.

d. Strive to improve the product or service, innovation and the rapid response to customers' requirements.

e. Respect, promote, protect and help to protect intellectual and/or industrial property, both its own and that of others.

f. Apply responsible, sustainable policies for the procurement of products and services, in collaboration with the suppliers of El Corte Inglés, S.A. and the companies of its Group, paying particular attention to especially sensitive, scarce or endangered raw materials and natural resources.

g. Promote sustainable development also through support to local products, as well as small and medium-sized enterprises and the social economy.

D. Commitment to the Environment

El Corte Inglés, S.A. and the companies of its Group are committed to improving their environmental management in order to develop a business which is recognised for the sustainability of its actions. With the aim of promoting respect for and conservation of the environment in those areas where it carries out its commercial activities, ECI acquires the following commitments:

a. To minimise the consumption of resources (energy, water and materials) in its operational processes, opting where possible for the use of clean energies and the most environmentally-friendly materials.

b. To contribute to mitigating the effects of climate change, conserving and making good use of natural resources, preventing contamination and making constant efforts to reduce its greenhouse gas emissions and its water footprint.

c. To extend the processes of the circular economy in its management, promoting complete-cycle actions to ensure an effective reduction of waste and the optimum utilisation of resources. This process will require greater discipline and control in the separation of waste and in its delivery to recovery and recycling entities.

d. To preserve the biodiversity of the ecosystems, landscapes and environments in which the ECI Group carries out its activities.

e. To promote collaboration with institutions, initiatives and systems aimed at improving the aforementioned commitments.

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E. Commitment to Society.

El Corte Inglés, S.A. and the companies of its Group maintain and reinforce their commitment to society in general. Sharing the challenges and achievements of all the territories and communities in which they operate, they seek:

a. To integrate their activities into the community and collaborate with its cultural manifestations and institutions. In the same way, to participate in organisations and forums which study and promote the development of the economy, in particular when the point of reference is commerce and services to consumers.

b. To maintain open dialogue about expectations and challenges of the community, contributing their experience and welcoming the points of view of their interlocutors.

c. To harmonise the activities of El Corte Inglés, S.A. and the companies of its Group in those places in which they operate with the different social, linguistic and cultural realities that exist in them.

d. To promote strategic social action projects which, related to the activities of El Corte Inglés, S.A. and the companies of its Group, generate shared value for society and incorporate the active participation of stakeholders, with a vision which promotes long-term sustainability.

e. To collaborate with specific projects in emerging countries related to the value chain of El Corte Inglés, S.A. and the companies of its Group, as well as in areas in situations of humanitarian crises.

f. To support the promotion and conservation of the cultural and artistic heritage of the territories and communities in which El Corte Inglés, S.A. and the companies of its Group operate.

g. To collaborate with different stakeholders in the development of a specific animal welfare policy.

One particularly sensitive aspect for society as a whole is responsible tax practices. The company has adhered to the Code of Good Tax Practices, approved on the 20th of July 2010 by the Large Companies Forum, created at the request of the State Tax Administration Agency. To that end, it acquired the following commitments:

a. The adoption of practices designed to lead to the reduction of significant tax risks and the prevention of those behaviours which are liable to generate them.

b. Collaboration in the detection and resolution of fraudulent tax practices which may be carried out in the markets in which El Corte Inglés, S.A. and the companies of its Group are present, in order to eradicate those that already exist and prevent them from spreading.

c. To promote a relationship with the Tax Authorities based on the principles of transparency and mutual trust, which therefore should give rise to development of that relationship in accordance with the principles of good faith and loyalty between the parties.

d. To avoid the use of opaque structures for tax purposes, by which we mean those which are designed with the aim of preventing the Tax Authorities from being able to ascertain those ultimately responsible for the activities or the ultimate owners of the assets or rights involved.

e. The reduction of conflicts deriving from the interpretation of the applicable regulations, favouring the use of the instruments established for that purpose by the

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Legal System in relation to Taxation

5. MANAGEMENT, REVIEW AND

COMMUNICATION:

Management and Review System

El Corte Inglés, S.A. and the companies of its Group consider CSR to be an integral part of their management systems. Therefore, this CSR Policy will be developed over time through:

● Specific policies which address particularly important questions

● Successive strategic plans, which will contain:

● Concrete aims

● Indicators and mechanisms for measurement of the impact, with regard to both tangible matters and, in so far as is possible, intangible aspects;

● Progress reports which reflect the approach of constant improvement in management.

At least once a year, the Chief Compliance Officer will review the fulfilment and efficacy of this General CSR Policy and will report the result to the corresponding Delegated Committee of the Board of Directors.

Transparency and Communication

Transparency and communication are key factors as regards conveying confidence and credibility to the markets and investors, as well as to employees and customers and all other stakeholders. That is why El Corte Inglés, S.A. and the companies of its Group undertake to:

a. Maintain responsible communication, marketing and advertising criteria, taking into account the reputational risks which could derive from any possible non-fulfilment.

b. Disseminate relevant, reliable information on the performance of the CSR activities of El Corte Inglés, S.A. and the companies of its Group.

c. Favour transparency and accountability, assuming the commitment of preparing and publishing financial and non-financial information on their activities each year. Likewise, El Corte Inglés, S.A. and the companies of its Group will make public both the additional information required by the applicable regulations in each country and that agreed to voluntarily.

6. APPROVAL, ENTRY INTO EFFECT AND

UPDATING

a. This Corporate Social Responsibility Policy was approved by the Board of Directors of El Corte Inglés, S.A. at a meeting thereof held on 28th February 2018. From that moment on, it is fully in effect in all its terms.

b. This Policy must be kept up to date over time. Therefore, it must be reviewed once a

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year ordinarily and, extraordinarily, each time there are changes in the strategic objectives or the applicable legislation, with the CCO presenting a proposal for modification, having first consulted with the Compliance Committee, to the Audit and Control Committee, which, where applicable, will refer it to the Board of Directors for its approval.

LOG OF CHANGES

CORPORATE SOCIAL RESPONSIBILITY POLICY

First Version

Date of approval: 28th February 2018 Compliance Doc. Ref.: 9/18

Date of annual review Conformity Proposed Modification

……………………. ………………… ……………………..

………………………. ……………….. ……………………..

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