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1. PURPOSE AND SCOPE OF APPLICATION

This Code of Ethics sets out the values and guidelines of Ocean Brotherhood SL, with VAT ID B66764952 and registered office at c/ Calvet 36 E2, 08021 Barcelona.

It applies both internally (employees and management team) and externally (suppliers, clients, collaborators, ambassadors, investors, and all stakeholders with whom we engage), at both national and international level. The company provides this Code to all of them so they are aware of its content and can commit to its compliance in the areas where it applies.

The Code of Ethics is approved by the company’s Management Committee, which is also responsible for supervising and ensuring compliance, with the support of the relevant departments.

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2. VISION

We believe in a world where businesses help build a better society. We believe in a world where companies that are not good for people and the planet have no place. We believe that collaboration between individuals is necessary to solve the world’s main challenges.

One of the greatest challenges we face is the climate crisis and the protection of the oceans. The oceans are the primary source of life; they are what sustain life on this planet. Protecting the ocean is the basic condition to leave a better world for our children. We believe that protecting at least 30% of the ocean is possible and that this will contribute to the sustainability of our planet and help mitigate the effects of climate change.

We believe in a world where people and their consumption choices can generate a positive impact. We believe that everyone can contribute to ocean health, whether through protection, education, or awareness. Above all, we believe the solution does not rely on individual actions alone or on shifting responsibility to governments or other institutions. It will be achieved by listening to the scientific community and aligning all stakeholders: companies, institutions, and consumers—each contributing through consumption decisions and direct actions.

We aim to be a benchmark company in transforming the world towards sustainability and promoting the circular economy. We want people to benefit from products that are good for the planet and to mobilize society to contribute to educating their children, gaining knowledge, and engaging in ocean protection. For this reason, the primary economic benefit of this company is its social impact—the improvement of ocean health. We therefore allocate 52% of our available profits to ocean protection, and through this we aim to support scientific research and the development of solutions for a healthy ocean.

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2.2 Beliefs and Values

• A business that does not have a positive impact on the world is not a good business.
• Environmental and social awareness. We are responsible for leaving a positive impact on the planet. While companies inevitably generate environmental impact through resource consumption, transport use, and waste generation, the benefit they provide to society must outweigh this impact. We must never generate unnecessary negative impact.
• We believe we can help transform the food and beverage sector towards a more sustainable model.
• We can mobilize the ocean community and society as a whole to drive behavioral change towards greater environmental responsibility.
• Surrounding ourselves with the best experts is essential to ensure reliable information and constant inspiration; therefore, we rely on our network of ambassadors, investors, and collaborators.
• Honesty: we call things by their name and are committed to collective goals. We are honest and do not claim to be what we are not.
• Creativity, open-mindedness, and freedom to express ideas, think differently, and share opinions openly.
• Humility to acknowledge mistakes, to say “I don’t know,” and to learn from others.
• We embrace challenges: a dream without action is hallucination.
• We enjoy teamwork, collaboration, and sharing. We are genuinely energized by what we do.
• A strong project is built on a strong team. We believe in a committed, motivated team and foster an environment that retains and attracts talent.
• We believe that, with everyone’s help, it is still possible to save the ocean.

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3. MISSION

To transform an industry with negative impact into one that helps protect the ocean.

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REAL IMPACT

• Prevent overproduction of single-use plastic bottles and their arrival into the ocean.
• Promote responsible consumption.
• Increase societal knowledge about the ocean.
• Support scientific institutions and groups directly working on ocean protection.

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4. CODE OF CONDUCT

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4.1 Legal Compliance

Business and professional activities are carried out in strict compliance with applicable laws in each country where they are conducted.

Clarity and transparency are ensured in all documentation to guarantee proper understanding by all parties.

All information contained in physical (paper, cardboard, etc.) or digital media is part of the company’s knowledge and value and therefore its property. It may not be sold, transferred, misappropriated, or disclosed without management authorization.

All necessary confidentiality agreements will be signed to ensure information protection.

Employees shall not engage in illegal activities or actions that may damage the company’s reputation, and shall respect and contribute to the legitimate and ethical objectives of the organization. Internal protocols must also be followed.

The company rejects all forms of corruption or bribery.

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4.2 Commitment to Human Rights

We respect human rights and reject any violation thereof.

We adhere to the principles of the United Nations Global Compact:
https://www.pactomundial.org

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4.3 Respect for Labor Rights

The company respects the labor rights of all employees as recognized at both national and international level.

A good working environment is essential for the development of both the business and its people.

Employees must treat colleagues, clients, suppliers, and collaborators with respect.

We have an internal workplace harassment protocol, as well as policies on diversity, equity and inclusion (DEI), digital disconnection, and compensation and incentives.

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4.4 Environmental Protection

Environmental protection, and especially ocean protection, is our mission.

We integrate the Sustainable Development Goals (SDGs) as our own and actively contribute to their achievement, particularly:
3. Good health and well-being
12. Responsible consumption and production
13. Climate action
14. Life below water
17. Partnerships for the goals

We have an environmental management system that applies not only internally but also across suppliers and clients. We also have an environmental policy.

We allocate 52% of available profits to ocean protection.

We apply selection criteria to determine beneficiary projects and rely on a committee of ocean experts to ensure the effectiveness of donations. We also publish an impact report detailing all activities carried out in favor of the ocean on our website.

We integrate sustainability criteria into product design and operations.

We follow a green office policy, carefully select suppliers, and apply strict recycling and resource reduction practices.

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4.5 Non-Discrimination and Equal Opportunity

Hiring and promotion are based on skills, knowledge, and experience.

We have a diverse team, which is part of our success. Everyone is responsible for fostering respect and creating an inclusive workplace environment.

The company does not tolerate discrimination based on race, color, age, gender, nationality, disability, religion, sexual orientation, or any other legally protected characteristic. The DEI policy establishes measures to ensure this.

Any form of hostile, humiliating behavior, abuse of authority, or harassment (physical or psychological) is strictly prohibited. We have a workplace harassment protocol with specific measures and processes to prevent and address such situations.

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4.6 Work-Life Balance Rights

We comply with labor regulations regarding maternity and paternity leave and dependents.

Our DEI policy and employee handbook include measures such as flexible working hours, remote work, and breastfeeding support.

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4.7 Privacy and Data Protection

We ensure compliance with privacy and data protection regulations.

We undergo voluntary audits to confirm compliance with data protection requirements.

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4.8 Training and Professional Development

The company aims to promote and develop employee skills.

We have an evaluation and development system for all team members and foster a cooperative work environment. Our DEI and incentive policies also include measures for training and professional growth.

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4.9 Health and Safety at Work

Working in a safe, suitable, and pleasant environment is essential.

We comply with occupational health and safety regulations and provide relevant training to employees.

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4.10 Product and Service Quality

We are highly demanding with our producers and collaborators. We aim to offer the best to our consumers and maintain a quality system that ensures product excellence.

We work with top-tier suppliers and rely on reputable scientific sources to ensure that all information shared across our channels is accurate and reliable.

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4.11 Fair Competition

We support the circular and collaborative economy. We aim to contribute to improving our environment through an innovative and social business model.

We act with loyalty and respect towards consumers, competitors, and all stakeholders, and we respect free competition.

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4.12 Tax and Accounting Transparency

Transparency is one of our core commitments.

We comply strictly with tax and accounting regulations and firmly reject tax fraud and corruption.

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4.13 Lobbying Activities

If the company participates in institutional dialogue or public policy initiatives, it will do so responsibly, transparently, and in accordance with applicable law, aligning such actions with its mission of ocean protection, environmental sustainability, and positive impact generation.

Ocean52 commits to maintaining consistency between its public positions, internal policies, and any future participation in public policy initiatives.

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4.14 Communication with Stakeholders

We provide an open web channel for suggestions, complaints, and other communications. Our compliance system also includes a whistleblowing channel.

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5. REVIEW AND UPDATE

This Code of Ethics will be reviewed at least every five years by the Management Committee, with the support of the sustainability department, in order to incorporate improvements and adapt its content to regulatory and strategic changes.

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6. TRACEABILITY AND CONTROL

Compliance with the Code is monitored through environmental and social KPIs, employee satisfaction surveys, and reviews with strategic suppliers. Any deviation will be analyzed and, where appropriate, corrective measures will be implemented.

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Approved by:
Santiago Mier Albert
CEO

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