GOOD GOVERNANCE, RESPONSIBILITY AND INTEGRITY:

NOTEWORTHY ACTIVITIES 2022/2023

• During the period covered by this report, we updated our Strategic Sustainable Development Plan by integrating ESG criteria, and we revised the corresponding scorecard. This allows us to track the strategic objectives established, using indicators that help us monitor the company’s operational, economic, environmental and social performance.
• We also carried out an exhaustive review of the relevant issues that affect our context, making a SWOT analysis (strengths, weaknesses, opportunities and threats) of the company, and monitoring objectives aimed at meeting the expectations of our stakeholders.
• We also continued with the digitisation of processes and their communication through the MLO Portal. We would like to highlight the creation of the “MLO Identity” section on the Portal, which includes all the corporate information necessary for new hires and third-party communications in digital format.
• Moreover, we established an annual meeting plan to monitor the status of staff in each area together with the general management and human resources management. Among other points, it includes the evaluation of overall employee performance, the emotional situation, and monitoring of staff needs.

4.2 ETHICS AND INTEGRITY IN BUSINESS ACTIVITIES

To ensure integrity and ethics in all our activities, we implement a management model based on the following key elements:

• The existence of a Governance Policy that commits our employees and our contractors to following rules on policies against bribery, corruption and fraud, as well as the protection of human rights.
• We have a Code of Ethics that sets the standards and principles of professional and ethical conduct that must be followed by all persons within the company in the execution of their functions, and establishes the mechanisms for reporting complaints and protecting the complainant.
• Additionally, our prevention systems are designed to detect and prevent any illicit or criminal behaviour.
• Likewise, our oversight and control mechanisms allow us to ensure effective compliance with these regulations and policies.

NOTEWORTHY ACTIVITIES 2022/2023

• At the end of the period covered in this report, the definition of the monitoring process for the implementation of the Code of Ethics in our organisation is in an advanced stage. This involves the development of control and monitoring mechanisms and integration into our Integrated Management System and the scorecard.
• In order to promote a culture of transparency and accountability in all our actions, we have disseminated our Code of Ethics among all our stakeholders through our corporate website, which makes an accessible reporting channel available. This channel provides our employees, customers, suppliers and other stakeholders with a reliable means of reporting any conduct contrary to our values and ethical principles.
• In our on-going quest to promote a strong ethical culture within our organisation, we have developed an employee training and information session plan on our Code of Ethics that will be implemented early in the next period. These sessions are primarily aimed at ensuring that all members of our team are fully familiar with the principles and values that guide our business actions and explaining the channels and procedures available for making suggestions and complaints, emphasizing our commitment to transparency and accountability.

RISKS AND ANTI-CORRUPTION PROCEDURES

As part of our overall risk assessment process, we devoted particular attention to the specific issue of corruption by analysing all our operations. The result did not reveal any significant corruption risks.

During the last year of this period, we began the process of reviewing and updating the risks related to our Code of Ethics and our crime prevention manual.

The organisation’s anti-corruption procedures are available to all members on the MLO portal. We are working on the development of the training and information session plan for our employees; see above.

During the period explored in this report, we did not record any incidents of corruption.

4.3 PROJECT STRENGTH AND SOUNDNESS AND MAKING THE MOST OF OPPORTUNITIES

In a dynamic and constantly evolving world, value generation has become the cornerstone of our business strategy, oriented toward the present and the future. We recognise that, in order to generate sustainable value, it is imperative to engage our stakeholders in all areas of our business and make a strong commitment to them.

The essence of our business strategy is focused on innovation, renewal and sustainable growth, which are the pillars that underpin our commitment to sustainability, and the way these points contribute to the construction of a solid, resilient project.

In this sense, we have established a Responsible Procurement and Contracting Policy. We manage our resources efficiently and aim our investments toward sustainable development.

Resource optimisation, active participation in working groups in the sector, and the promotion of sustainable public transport, as part of a comprehensive sustainable urban mobility strategy, are specific actions that reinforce our capacity to generate economic value and furnish MLO’s project with strength and soundness.

NOTEWORTHY ACTIVITIES 2022/2023

• We integrated the risk and opportunity management of all the analysis groups into a single platform, “MLO Portal”, along with the process for managing changes and monitoring the actions generated by these changes.
• We reviewed our long-term investment plan for 2023-2036 in response to possible network obsolescence, improvements and optimisations.
• Our Crisis Manual was recently updated and published on the employee portal, following the guidelines of the UNE-ISO 22320:2013 standard. This manual, complementary to the Self-Protection Plan, was designed with the specific objective of ensuring a coordinated and effective response of all areas to situations of special relevance.
  
  In addition to this update, we developed specific action protocols for two critical scenarios: accidents involving serious injuries and/or victims, and extreme snowfall. These protocols not only cover the immediate response to such eventualities, but also include detailed monitoring of weather conditions that could affect our services. This way, we are prepared to anticipate and address service needs in the event of adverse weather events.
  
  To ensure clear understanding and effective implementation of these measures, we created an action guide that integrates all this information. This guide was published and communicated to all areas internally, ensuring that all teams are properly informed and prepared to act in a coordinated and effective manner in the event of a crisis or emergency.

NOTEWORTHY ACTIVITIES 2022/2023

• We published our third Sustainability Report following GRI Standards guidelines, incorporating an English edition.
• In our search to identify more effective communication channels and perfect the process of listening and responding to our stakeholders, we launched our channel on TikTok, in addition to finalising the study for the implementation of a customer service channel through our WhatsAppMLO.
• Additionally, we developed improved selection and planning of informative content aimed at passengers, which will be published through our various communication channels.
• In terms of our interaction with stakeholders, we evaluated the results of an internal survey and made substantial improvements. These improvements include digitising the relationship map on the MLO Portal, updating our communication channels, and planning specific actions in line with the needs and expectations identified.
• Regarding our “visitor” stakeholders, we perfected the protocol for managing these visits. This improvement includes the updating of information materials intended for them, including the program, safety information, and the implementation of a visit satisfaction assessment process to collect feedback and thus continuously optimise their experience.