Purchasing Policy

The objective of the Purchasing Policy of TRANSGRUMA S.A. and BOMBEOS TRANSGRUMA S.L.U., hereinafter referred to as “TRANSGRUMA”, is to establish rules that guarantee objectivity, transparency, and excellence in the purchasing process.

1st. Supplier Selection: TRANSGRUMA has established the following selection criteria for its suppliers:

• Exclusive Suppliers: They are those that stand out in the market for their exclusivity in providing certain services for which there is hardly any competition.
• Certificationn: Those suppliers that demonstrate that their organisation has a Quality Management System are automatically approved.
• Supplies or test servicesa A trial supply or service is requested from the supplier, and the Quality Manager carries out an evaluation of it after the trial period.
• Trust They are suppliers recommended by the Managing Director's inner circle.
• Value for money They are those suppliers that offer the best value for money in terms of service quality and price.

In all procurement, the following ethical principles must be observed by TRANSGRUMA personnel who request the services of a third party:

• Transparency: Consider first the interest of TRANSGRUMA, in particular the commitment to ensuring the quality of the products and services to be supplied, information security, corporate social responsibility, as well as the benefit to TRANSGRUMA employees and customers
• IndependenceDo not accept gifts or perquisites of any kind from individuals or entities outside TRANSGRUMA, especially preferential treatment or gifts outside of those common in the market and sector, and which are aimed at influencing professional relationships of any kind in which one participates.
• ImpartialityBe impartial in the performance of your professional activity, especially in those situations that may involve a conflict of interest, which implies a potential personal benefit or a conflict between one's own interests and those of TRANSGRUMA.
• Compliance with internal regulations and legalityAlways act in accordance with the procedures and policy of corporate purchasing approved by the organisation, as well as current regulations. Every purchase or agreement with Suppliers must be expressly authorised by the body with the purchasing powers or authorities designated by senior management of TRANSGRUMA. The practice of buying first and asking for authorisation afterwards is not acceptable.

2nd.- Supplier Approval: TRANSGRUMA requires its suppliers to demonstrate impeccable ethical and legal conduct, particularly in compliance with regulations applicable to the supplier in their activity, occupational health and safety (OHS), the ability to deliver products and services under the required conditions, compliance with agreed service quality standards, maintaining commercial morality and an adequate financial situation, with full compliance with their obligations towards banks, suppliers, legal authorities, tax authorities and staff.

3rd.- Supplier Evaluation: TRANSGRUMA's suppliers are evaluated on their performance according to the following evaluation criteria:

• Meeting Deadlines.
• Quality of Service / Product.
• Recorded Incidents.
• Compliance with applicable legal and regulatory requirements.
• To be up to date with tax and Social Security obligations.
• Prioritise suppliers with financial health that guarantees supply during the established period.
• Prioritise suppliers holding ISO 9001, 14001 and 45001 certifications.
• Prioritise local suppliers to boost local trade, job creation, sustainable purchasing and to reduce the carbon footprint of the supply chain.
• Prioritise the acquisition of modern machinery with efficient technologies and a lower environmental impact in your production chain.

In addition, favourable and unfavourable aspects in each case will be taken into account as part of the selection criteria. For those suppliers that obtain an insufficient or negative rating, regularisation or termination action must be taken regarding their respective contracts, as appropriate.

4. Supplier Relations:  The business relationship with Suppliers must always be formal and agreements must be in writing. Suppliers must be responded to promptly and courteously. Suppliers must be paid in a timely manner in accordance with the conditions agreed in the respective contracts, without discrimination between Suppliers to speed up and prioritise the payment process, which must be known to the supplier. Finally, the practice of systematically and professionally listening to suppliers must be established, with the purpose of addressing their concerns, suggestions and complaints to enable the continuous improvement of the relationship with them. For these purposes, formal communication channels shall be established