1. TMGA

TERMINALES MARÍTIMOS DE GALICIA S.L., hereinafter TMGA, is a company dedicated to the provision of port service and commercial services for handling goods, including the exploitation, operation and maintenance of terminals.

2. The management system

TMGA has developed a management system that includes concepts such as social responsibility, quality, environmental issues, sustainability, energy efficiency, health and safety at work, industrial and information security, supply chain security, IT services, innovation and risks.

TMGA has decided to implement a Quality Management System in accordance with ISO 9001:2015, an Occupational Health and Safety Management System in accordance with ISO 45001:2018 and an Environmental Management System in accordance with ISO 14001:2015 and the requirements of Regulation (EC) No 1221/2009, Regulation (EU) 2017/1505 amending Annex I, II and III and Regulation (EU) 2026/2018 amending Annex IV, better known as the EMAS regulation.

The management system of TMGA is firmly based on controlling and managing risks in all relevant areas.

The Management Committee of TMGA has established the policies listed below as a benchmark for constructing the management system and a basis for goals.

At TMGA we undertake to maintain and continuously improve our management system. We are all responsible for meeting the requirements set out in the management system and those laid down in law and in the regulations applicable in each case.

Management system policies are made known to and are binding on all employees. They are also available to our suppliers and subcontractors to sign up to, and to any other individual or organisation that may request them.

3. Policies

3.1. Social Responsibility Policy

At TMGA we strive to achieve growth that is sustainable in financial, social and environmental terms. Our goal is to provide high-quality services as we strive responsibly and efficiently to foster financial growth and create value for our customers, shareholders, employees, collaborating firms, public administrations and society as a whole, encouraging the development of the social setting in which we operate and using the natural resources required for our operations in a rational manner.

In line with this social responsibility policy, we commit to:

• Setting up responsible hiring practices in an effort to create jobs and combat social exclusion.
• Fostering behaviour conducive to health and safety at work among our employees and monitoring contractors more closely in health and safety matters.
• Encouraging greater awareness and sensitivity among our employees to our environmental impacts.
• Complying with the principles set out in the UN Global Compact.

3.2. Occupational Health & Safety Policy

WE ARE COMMITTED TO YOUR SAFETY

TMGA sees health and safety management as a priority, strategic factor in achieving corporate results. It is a key factor in corporate leadership, and is based on the following points:

Commitment

To safeguard the health and welfare of the employees of TMGA and provide safe, healthy working conditions so as to prevent injuries and damage to health. This commitment is inalienable, so TMGA factors it into its operations and takes all necessary measures to ensure that it is fulfilled.

To foster a culture of prevention as the basis of the corporate culture, making health and safety an individual responsibility that conditions the future of the company and encouraging consultation and engagement on the part of employees.

Principles

People are our organisation’s most valuable asset, and there is nothing more important than their health and safety.

In all operations, nothing should have greater priority than people’s health and safety. All tasks must be planned and implemented with safety in mind.

Safety is the responsibility of every individual at TMGA, but especially of the senior management and of those who manage groups of people. As such it needs to be managed.

Accidents arising from management failures can be avoided by eliminating hazards and reducing risks.

All provisions of law and other regulations to which the company subscribes voluntarily must be complied with.

Attitude

Everyone at TMGA must be aware of and take on board their functions and responsibilities in matters of health and safety.

This policy is known to everyone at TMGA and is public knowledge, which means that it is available to anyone who requests it.

Health and safety management is based on a process of continuous improvement, with specific goals set for the purpose.

3.3. Quality Policy

Throughout its history, TMGA has proved capable of meeting the various challenges posed by the market and of developing and providing effective solutions to address the requirements of its customers.

Our idea of helping customers in their businesses is to identify how things should be. For TMGA this means teamwork and a challenge; for customers, it means tailor-made solutions.

Believe, Create, Grow is the motto that represents our corporate philosophy.

Because only together, with the commitment and effort of each and every one of us, can we take our overall project forward. To grow we must create and to create we must believe; and in this there is only one recipe for success: work, work and more work. That is our commitment.

3.4. Environmental Policy

TMGA seeks to provide services for its customers in line with their needs and to be competitive on the market in which it operates while incorporating criteria of sustainable development, efficient resource management, environmental protection and respect for the demands of society.

Accordingly, we have published the principles that make up our environmental policy:

1. To meet the requirements of law regarding the environment and environmental requirements applicable to our operations and to the services that we provide.
2. To inform our suppliers, including contractors, of our environmental requirements and urge them to adopt environmentally-friendly practices.
3. To reduce our environmental impacts, including water and energy consumption, emissions into the atmosphere and improper waste management. This is the core task in our environmental management policy.
4. To encourage environmental protection and the prevention of pollution as a major responsibility that entails ensuring compliance with benchmarks suitable for our operations.
5. To continuously improve the efficiency of the management system so as to improve the environmental performance of the organisation.

Protecting the environment means that everyone at the organisation must behave responsibly, as required by current circumstances.

3.5. Safety & Security

At TMGA we see safety and security as integral aspects that must be factored into a risk analysis to ensure that each threat is addressed using the right resources so as to set mitigation mechanisms in place to reduce risks.

We therefore document, implement, maintain and continually improve our safety and security procedures so as to determine what measures need to be applied in each case.

Safety Policy

Effective safety must involve protective measures to prevent unauthorised access to facilities.

That is why at TMGA we have decided to implement safety measures including procedures to control access to our facilities by employees, suppliers, visitors and vehicles.

Information Security Policy

In knowledge-based societies, information is a strategic asset for organisations.

At TMGA we know how important it is to identify and protect our information assets to prevent the unauthorised destruction, disclosure or use of any information concerning customers, suppliers, strategies, management and other matters.

We are therefore committed to protecting our information resources at TMGA and to implementing the technology needed to safeguard against internal and external threats to the confidentiality, integrity, availability, lawfulness and trustworthiness of that information.

Personal Data Protection Policy

We undertake to exercise due diligence in processing all personal data to which we may have access.

All persons who have access to personal data are under obligation to comply with the provisions of the security document (which sets out technical and organisational measures consistent with the security regulations in force).

We provide the means for anyone who wishes to exercise their rights in law in regard to personal data on them which we process as controllers to do so.

Supply Chain Security Policy

At TMGA our priority is to draw up the best solutions for every customer who wishes to obtain a safe, efficient supply chain.

To that end, we seek to factor security management fully into the trading operations conducted in the supply chain.

At TMGA we are a transport and logistics platform operator. As such we undertake to provide all-round service in an effective, trustworthy, safe manner at all points in the supply chain, to help combat the main criminal activities that threaten operations (theft, smuggling, fraud, etc.), to ensure that we have personnel committed to using safe practices and safety/security parameters that foster the trustworthiness required to prevent the risks entailed by any irregular or suspicious activity.

3.6. Policy on Continuity of Operations and Availability of Information Systems

On the basis of good practices in continuity of operations and availability of information systems, this policy seeks to ensure the following:

• That there is a documented Continuity/Availability Plan in place (hereinafter called “the Plan”) to protect TMGA, its associates, customers, employees and resources against all threats, be they internal or external, deliberate or unintended.
• That all activities concerned with the Plan are carried out in an orderly, coordinated, consistent fashion.
• That the Plan is suited to the size, complexity and nature of the organisation and covers changing business needs at all times.
• That the management environment required to maintain the effectiveness of the Plan is set up.
• That the Plan is reviewed at least once a year to ensure that its provisions comply with the requirements agreed in all circumstances, from business as usual to serious loss of service.
• That the Plan is tested whenever there is a major change in the business environment.
• That the Plan is underpinned by back-up copies as established in the internal procedures of the organisation.

January 12, 2023

Patricio Erhardt Barrenechea