Business Ethics and Compliance at Doral

Doral is committed to the highest standards of business ethics. At the beginning of 2022, Doral began implementing the Code of Ethics that was adopted by the board members, management, and company employees. The Code of Ethics serves as a guiding principle for promoting ethical behavior in both professional and personal spheres, and its implementation is overseen by the Corporate Secretary. Doral places emphasis on ethical conduct throughout its operations, not only at the managerial level but also among employees and suppliers. Each new employee undergoes comprehensive training on the Code of Ethics and is required to sign a commitment to adhere to its principles upon joining the Company. Furthermore, in 2023, all Doral employees underwent annual training on business ethics and the Code of Ethics. In 2024, the Code of Ethics will be distributed to all of Doral’s key suppliers.

The Company provides channels for employees to express any concerns regarding potential violations of the Code of Ethics. Through the Company’s ‘open-door policy,’ employees can raise inquiries and share their concerns. Additionally, Doral maintains a physical box to enable anonymous submissions of inquiries. As part of the implementation measures, a seminar for directors and officers was held in 2023, including lectures on ESG topics, proper corporate governance, various issues of administrative enforcement, and updates in corporate and securities law. In 2023, no complaints or breaches of the ethical code were recorded.

Doral complies with legal, standard, and regulatory requirements in each country where it operates. As of 2023, Doral adheres to environmental laws and regulations, with no sanctions or fines imposed for non-compliance in this area. The Company strives to ensure proper conduct not only by meeting legal requirements but also by adopting an internal voluntary mechanism. Additionally, Doral promotes training related to legal and regulatory requirements and ensures compliance. In 2023, 100% of the Company’s employees in Israel underwent training on the prohibition of insider trading and the Code of Ethics. Similarly, 100% of Doral LLC employees and the Company’s employees in Europe received training on regulatory compliance, anti-bribery, anti-corruption, and insider trading. Moreover, 75% of the board members and officers attended training on ESG topics, proper corporate governance, various issues of administrative enforcement, and updates in corporate and securities law.

Doral, as a publicly traded company, has implemented an internal enforcement program as part of its risk management policy and commitment to securities laws. The program serves as a voluntary organizational mechanism, designed to enhance ethical conduct within the Company. Approved by the board of directors on August 29, 2021, this program complements legal requirements and can impose even stricter rules to uphold the Company’s ethical standards. All employees are subject to the program. While the CEO has supervisory responsibility for ensuring compliance and developing internal enforcement mechanisms, the audit committee plays a crucial role in formulating, adopting, and monitoring the program’s implementation. The Corporate Secretary is designated as the enforcement officer and is responsible for conducting training on the program’s principles and guidelines. On an annual basis, the enforcement officer provides a comprehensive report to the audit committee and the CEO. This report covers the progress in addressing compliance gaps identified through surveys, the effectiveness of the enforcement program during the previous year, and any noteworthy incidents that occurred.

The enforcement plan is designed to ensure compliance, prevent violations, and detect offenses within the Company and among its associates. It establishes a framework for implementing, supervising, and controlling the provisions of securities laws. The plan aims to address any violations or failures adequately, minimize damages resulting from such violations, and define the roles, powers, and duties of the various organs within the organization to achieve the objectives of the internal enforcement program. To achieve these goals, the plan consists of a set of clear and efficient work procedures, including a main procedure and ten additional procedures: board and committee actions, communication with the media and analysts, communication with the Securities Authority, preventing the misuse of insider information, immediate reporting, preventing bribery and corruption, related party transactions, reporting by interested parties and officeholders, prospectuses, and information flow within the Group.

In 2023, the audit committee held a discussion on the implementation of the Company’s internal enforcement program for that year and approved the update of parts of the program’s procedures, with 100% of the committee members attending the discussion.

Doral is subject to all legal and regulatory provisions that ensure the prevention of conflicts of interest within the Group and particularly within the Company. As part of its policy for proper management and business ethics, several internal measures have been taken to prevent conflicts of interest and ensure fair operations.

When appointing directors, they are required to complete a questionnaire and declaration addressing, among other things, connections and conflicts of interest. Additionally, as part of the internal enforcement program, the Company has adopted the “Interested Parties and Officeholders Reporting Procedure.” In this framework, prior to the annual financial report, the Company sends all officeholders questionnaires addressing connections and conflicts of interest.

Furthermore, the “Interested Parties Transactions Procedure” sets out that a list of the Company’s interested parties must be managed and recorded, including directors and related parties, such as family members, business connections, and companies in which they serve. All these procedures have been adopted and approved by the board of directors.