OMI Group's tax policy

Scope

This policy applies to all employees, directors, and administrators that perform their professional activities as members of OMI Group's organizational structure, regardless of their position, seniority, or geographical location. To this end, the following will be considered to be companies pertaining to OMI Group: Operador del Mercado Ibérico de Energía Polo Español, S.A., OMIP-Operador do Mercado Ibérico (Portugal), SGPS, S.A., OMI-Polo Español, S.A., OMIClear, C.C.S.A., OMIP-Polo Português, S.G.M.R., S.A., OMIP, S.A., OMEL Diversificación, S.A., and any other of their member companies.

Likewise, its application may be extended to individuals or entities that do not belong to the Group, provided that they have some business or professional relationship with the entity and that their performance entails a risk or responsibility for OMI Group or may directly or indirectly affect their reputation or good name.

Purpose

The purpose of OMI Group's tax policy is to ensure compliance with applicable tax regulations and to guarantee proper monitoring of this principle for each of its member companies, attending to equity stake and ensuring that business objectives are met, acting transparently, and promoting cooperative relationships with governments, preventing financial waste and risks in developing economic activity.

Principles anf fiscal strategy

OMI Group's fiscal strategy is based on the following principles of performance described below:

I. Responsibility in complying with tax obligations

The Group is aware that complying with required tax payments in countries where it operates is part of contributing to their social and economic advancement. To this end, it handles complying with tax payments and takes reasonable measures to interpret regulations in accordance with interpretative criteria established by the corresponding fiscal authorities.

II. Prudence in taking risks

The Group is committed to adopting careful criteria for taking risks in their activities, assessing the fiscal implications stemming from its decisions beforehand.

III. Transparency with fiscal information

OMI Group encourages transparent, responsible communication in order to clearly communicate relevant fiscal information that affects the Group’s activities to its various stakeholders.

IV. Cooperation with tax authorities

OMI Group is committed to strengthening a relationship with the tax authorities based on the principles of trust, transparency, collaboration, and seeking mutual understanding with the aim of facilitating applying the tax system, boosting legal security, and minimizing litigation.

To this end, it makes all information about actions and decisions regarding fiscal matters available to administrations as quickly as possible.

In applying the prior principles, the Group takes on the following tax practices:

• The Group will not create companies, nor will it carry out any transactions in tax havens, to evade tax payments.
• The Group will not use contrived tax structures unconnected to their operations to be used for tax evasion.
• The Group will not use opaque structures to be used to prevent or hinder the Tax Authorities in identifying the party ultimately responsible for activities or the last owner of goods and services in question.
• The Group will assess exposure to financial risk from decisions it may make, considering the fiscal impact in the long and short terms, the impact on the company's reputation, the impact for shareholders and clients, the impact regarding governments and tax authorities, and the impact on other areas of the organization.
• The Group will maintain a relationship with Tax Authorities that is based on the principles of transparency, mutual trust, and good faith by providing requested information and documentation that is of significance to taxes in the shortest time frame possible and in the appropriate scope, as long as it is reasonable.
• The Group will request services from reputable, independent tax experts in both the revision of financial criteria that are implemented as well as the verification of compliance with tax payments as necessary.
• The Group will work with the Tax Authority in inspection proceedings that may arise in order to, as much as possible and notwithstanding good business management and the legitimate right to disagree in the event of a dispute, come to agreements and compliances therein.
• The Group is committed to following recommendations from the codes outlining best tax practices that are implemented in countries where the Group's companies operate, taking the specific needs and circumstances of the Group into consideration.
• In Spain, the Company adheres to the code outlining best tax practices (the "Code") approved on July 20, 2010 by the plenary of the Large Companies Forum - established July 10, 2009, at the request of the Agencia Estatal de Administración Tributaria.