Internal Rules of Conduct

1.- The present Internal Code of Conduct (hereinafter, ICR) sets forth the rules to which Eurovaloraciones, S.A., a company appraisal approved by the Bank of Spain on October 19, 1990 under code 4388, hereinafter, Euroval, is subject to as one of the mechanisms applied by the same to favour the independence of its activity appraisal and avoid conflicts of interest.

Its preparation is voluntary and will be applied in all cases, even when Euroval is not legally obliged to have an IRC, in accordance with the provisions of article 3.2 of Law 2/1981, of 25th March, regulating the mortgage market.

For the same purposes, it is noted that Euroval, at the date of approval of this
Regulation has a number of bank customers that individually or together represent at least 10% of its total net income.

2.- This IRC has been approved by the Board of Directors of Euroval in its session of 28 June 2016. This IRC replaces and cancels any previous version of the aforementioned document.

3.- The framework of professional, financial and operational relations between Euroval and its group
economic/influence group can be characterized as follows:
Euroval’s Operations Management Department will be the area in charge of the reception, registration, invoicing and delivery of the orders received, as well as the contact person assigned to communicate with clients in the event of any incidents that may arise during the performance of the work, as well as other commercial and/or information-related procedures on the services provided, all of which is without prejudice to the exclusively commercial procedures that may arise from the activity of Euroval’s commercial network.

4.- This IRC fully respects the legal rules established in this area by Law 2/1981, of 25 March, regulating the mortgage market, Royal Decree 775/1997, of 30 May, on the legal system for the approval of services and companies of appraisal , as well as Order ECO 805/2003, of 27 March, on rules for the valuation of goods real estatesand certain rights for certain financial purposes, the Bank of Spain Circular
3/2014, of 30 July and assumes as its own the content of the Code of Ethics approved by the Spanish Association of Value Analysis AEV, to which Euroval belongs.

5.- Euroval considers that it is essential that its valuations and other work of this nature provided by professionals and persons providing its services enjoy the full confidence of the direct users of the valuations and of the other parties interested in them. To this end, it is essential that these works have been provided by Euroval with the appropriate experience, professional skill and judgment, through a professional practice that is free from any undue influence or bias.

To this end, at least the following ethical principles, which are developed below, must be respected:

– Confidentiality: Euroval and the professionals providing services to it shall maintain professional secrecy with respect to the information obtained as a result of their professional and business relationships, and shall not disclose such information to third parties without the express authorization of the client unless there is a legal or professional obligation to disclose such information.

Nor may you use the information received for your benefit.

– Integrity: Euroval and its service providers will be direct and honest in their professional and business relationships and will be guided by the best interests of the client and, within the framework of mortgage market legislation or others that require it, by the underlying public interest.

– Independence and objectivity: The actions of Euroval and those who provide it with services in the field of its valuation activity must be governed exclusively by technical criteria. Euroval will not allow conflicts of interest, undue influence or bias to override or seriously impair its professional independence.

– Professional competence: Euroval will always have the necessary technical and human resources to ensure that its clients obtain a valuation based on the most advanced practice, the applicable legislation and the most appropriate techniques and methodologies. To the same end, it will maintain the professional knowledge and skills appropriate to the business environment in which it operates.

– Professional Behavior: Euroval and the professionals who provide its services will act with diligence in the fulfillment of the assignments, respecting what has been agreed and legally established, and the standards of the profession itself, trying to avoid the discredit of the profession.

– Transparency: The present IRC will appear on the corporate website (euroval.com) and will be available to any client who requests it.