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Responsibility

The Code of Ethics and Conduct (hereinafter, the "Code"), is the formal expression of the values and principles which shall govern the conduct of the Entities comprising Grupo Ortiz (hereinafter, the "Group") and the persons subject to same, during the development of their activities and execution of their duties, and during their workplace, commercial and professional relationships, with the purpose of establishing universally accepted business ethics.

For the purposes of this Code, "Group" or "Ortiz" shall refer to Ortiz Construcciones y Proyectos, S.A. and the group of companies led by said company, which includes all companies it controls either directly or indirectly. "Control" shall be understood as holding the majority of voting rights of the Administrative Board.

This Code is an example of the professionalism the Group displays in its activities and that which is expected of its employees and collaborators.

This Code is aimed at reflecting and consolidating an ethical culture which is already present in our company and should serve as a guide to the best way of doing things.

This Code does not attempt to include all potential situations that may occur. Its purpose is to offer a reference framework which can be used to measure any activity.

The Group places the utmost importance on fair treatment of all employees, clients and suppliers, authorities, investors and the general public.

Certain mandatory standards might comprise, in part or in full, some of the principles of this Code, but it is the intention of the Group with its approval to go beyond such standards and respect and require compliance therewith, regardless of legal provisions at any given time.

Where a law, practice or internal procedure applicable to natural and legal persons subject to this Code is stricter than its provisions, the former shall prevail.

Ortiz shall ensure that the principles established in this Code are observed in all Companies in which it participates.

Code of Business Conduct GRUPO ORTIZ

© 2011 Grupo Ortiz. All rights reserved