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GRUPO GARNICA PLYWOOD S.A.

Code of Ethics

Approved by the Board of Directors of GRUPO GARNICA PLYWOOD S.A. on 21 July 2015

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1. PURPOSE

2. SCOPE OF APPLICATION

3. ORIGIN, APPROVAL AND EFFECTIVENESS

4. MISSION AND VALUES

5. PATTERNS OF BEHAVIOUR

5.1 PRINCIPLES

5.2 BEHAVIOURAL STANDARDS

5.2.1 In relations with employees and interest groups

5.2.1.1. Professional performance and respect

5.2.1.2. Health and safety

5.2.1.3. Intimacy

5.2.2 Before situations of conflict of interest

5.2.2.1. Gifts, compensations, presents, assistance and other type of offerings

5.2.3 Treatment of information and law

5.2.3.1. Confidentiality

5.2.3.2. Transparency and disclosure

5.2.3.3. Law. Prevention of money laundering

5.2.4 In relations with the environment and other agents in its environment

5.2.4.1. With the environment and territory

5.2.4.2. With costumers and consumers

5.2.4.3. With suppliers and contractors

5.2.4.4. With partners

5.2.4.5. With respect to the competition

5.2.4.6. In the market, in institutional relations and in relations with third

parties

5.2.4.7. With legal and tax authorities

5.2.5 In relation to the assets and rights of GRUPO GARNICA PLYWOOD S.A. and

subsidiaries

6. RESPONSIBILITIES RELATED TO THE CODE OF ETHICS 6.1 SHARED RESPONSIBILITIES

6.2 ADDITIONAL RESPONSIBILITIES

7. ACCEPTANCE, COMPLIANCE AND SUPERVISION

8. DISCIPLINARY PROCEEDING

Annex 1

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1. PURPOSE

This Code of Ethics sets forth the fundamental principles and rules considered

essential to this purpose and they should serve as a behavioural guide for the

people to whom it applies in their professional relationships with third parties and

Society as a whole, thus consolidating a culture and a set of responsible behaviour

patterns that should be shared, accepted and endorsed by all.

This Code, together with the rest of the corporate documentation, is a commitment

with the law, good governance, transparency, responsibility, independence and

reputation, in terms of socially accepted ethical standards.

2. SCOPE OF APPLICATION

This Code of Ethics applies to all the members of the administration bodies and all

the employees of GRUPO GARNICA PLYWOOD S.A. and subsidiaries (interest

groups), regardless of the legal modality that determines their labour relationship,

the position they occupy or the geographic location in which they perform their

work.

Particularly and for the purpose of completing the Communications contained in

Annex 1, this Code of Ethics considers interest parties those that on a non-

exclusive basis, due to their position in the Group's organisation chart, perform

functions that bear responsibility over people and/or assets.

The total or partial application of this Code can be extended to any individual

and/or corporate body related to GRUPO GARNICA PLYWOOD S.A. and subsidiaries

when required to comply with its purpose and if possible due to the nature of the

relationship.

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3. ORIGIN, APPROVAL AND EFFECTIVENESS

This Code of Ethics includes a series of guidelines that the Group, since its origins,

has been applying and encouraging among its interest groups, understanding as

such, its employees, customers, suppliers, competitors, regulating bodies and

shareholders. This Code of Ethics is an inescapable reference for all its activities

and the conduct of its interest groups, as the reputation, credibility, independence

and success of GRUPO GARNICA PLYWOOD S.A. and subsidiaries depends largely

on all the interest groups respecting its content in an honest, civic, comprehensive,

strict, transparent and devoted way.

This Code of Ethics, to which all the companies that comprise the Group must

adhere, was approved in the meeting held by the Board of Directors on 21 July

2015, and it shall be published on the corporate website of GRUPO GARNICA

PLYWOOD S.A. with an indefinite duration.

GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall adopt the necessary

measures to implement the set of values and standards that comprise this Code, as

well as circulate the content among the interest groups and solve any queries that

may arise in its application.

However, the Code shall be reviewed and updated with the necessary frequency.

4. MISSION AND VALUES

MISSION: Wherever GRUPO GARNICA PLYWOOD S.A. and subsidiaries operates, its

aim is simply to become, and then continue being, the best company, providing:

Its customers: Products and services with an excellent value

Its investors: A good return on their investment

Its employees: A gratifying job both personally and economically

Its suppliers: Valued contracts and fair trade

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Its community: Supporting implication and examples of good practices

The environment: Commitment to improve and respect

VISION: GRUPO GARNICA PLYWOOD S.A. and subsidiaries desires to be a reference

worldwide in promoting the use of wood as an element capable of improving our

quality of life, not only individually but also collectively. In addition, it wants to be

recognised for the level of eagerness and professionalism it displays in its

performance. Lastly, it intends to build a strong and solvent organisation that

withstands time by means of a solid relationship with all those that have an

interest and relation with it.

VALUES:

• Feel and be Garnica

• Continuous improvement and innovation

• Result-oriented

• External and internal customer-oriented

• Sense of collectiveness

• Commitment with the environment

• Above all, an ethical, professional, rigorous and systematic conduct

5. PATTERNS OF BEHAVIOUR

All interest groups shall behave in accordance with the principles of behaviour

listed below.

These principles establish the benchmark that should inspire the basic conduct of

all the interest groups, complying with the principles of loyalty, good faith and

respect for the law.

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5.1. PRINCIPLES

GRUPO GARNICA PLYWOOD S.A. and subsidiaries assumes a commitment to carry

out its business activities and encourage conducts in the interest groups that are in

accordance with the legislation in force and that are ethically respectable.

The activities carried out by GRUPO GARNICA PLYWOOD S.A. and subsidiaries and

the actions of the interest groups must be performed in a framework of healthy

competition and dignity, while complying with the law, especially the Human

Rights and Public Liberties, and the rights of third parties, especially in matters

such as the worker's rights and the industrial and intellectual property rights.

All the interest groups must observe an ethical behaviour and prevent any conduct

that, despite not being against the law, may harm the reputation of GRUPO

GARNICA PLYWOOD S.A. and subsidiaries or be detrimental to its interests,

reputation and public image.

Furthermore, all the interest groups must be aware of the laws and regulations

applicable to their specific professional activity and shall request the necessary

information, if appropriate, from their superiors or through the relevant bodies or

departments of GRUPO GARNICA PLYWOOD S.A. and subsidiaries, strictly in

adherence to the protocols established to detect or prevent, if appropriate, the

commitment of illegal activities within the activities of GRUPO GARNICA PLYWOOD

S.A. and subsidiaries.

No interest group shall knowingly cooperate with third parties in the infringement

of any law or collaborate in any actions that might endanger the principle of

legality or that might damage the reputation of GRUPO GARNICA PLYWOOD S.A.

and subsidiaries or represent a prejudice for the perception of the markets,

customers, suppliers or regulatory bodies, among others.

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Summarising, GRUPO GARNICA PLYWOOD S.A. and subsidiaries encourages

complying with the law and rejects any interest group affecting any third parties

with any illicit or unethical behaviour, especially if it affects any recognised legal

rights within the scope of intellectual property, intimacy, honour or the disclosure

of secrets.

GRUPO GARNICA PLYWOOD S.A. and subsidiaries assumes that in any relationship

with third parties, these should act with the same commitments towards the law,

the rights of any affected party, loyal competition and the respect for human

dignity.

5.2. BEHAVIOURAL STANDARDS

5.2.1. In relations with employees and interest groups

5.2.1.1. Professional performance and respect

In the management of human resources and the relationships between the

employees, GRUPO GARNICA PLYWOOD S.A. and subsidiaries imposes on itself and

the Group to always focus on the most thorough respect for the dignity and privacy

of people, following the principles of mutual confidence and respect.

Similarly, the relationships between the employees of GRUPO GARNICA PLYWOOD

S.A. and subsidiaries and those of the cooperating companies shall be based on the

above criteria, as well as on professional respect and mutual cooperation.

GRUPO GARNICA PLYWOOD S.A. and subsidiaries expressly prohibits any abuse of

authority and any kind of harassment, either of a physical, psychological or moral

nature, as well as any other behaviour that might give rise to an intimidating,

offensive or hostile work environment for any individual.

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Similarly, GRUPO GARNICA PLYWOOD S.A. and subsidiaries does not tolerate any

type of discrimination based on any circumstance.

In this respect, GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall ensure that

the companies with which it engages in its professional activities respect the

International Agreements on employment and the human rights standards,

expressly rejecting any commercial relationship with companies or individuals that

encourage opposite behaviours towards the rights of employees and foreign

citizens.

5.2.1.2 Health and safety

GRUPO GARNICA PLYWOOD S.A. and subsidiaries commits to providing a healthy

and safe working environment.

All the employees of GRUPO GARNICA PLYWOOD S.A. and subsidiaries will be

responsible for the thorough observance of the occupation health and safety

regulations, with the aim of avoiding, to the extent possible, any occupational risks

and accidents.

In this sense, it is forbidden to perform any tasks under the influence of alcohol or

any other legal or illegal substances that can hinder the level of safety required to

perform the required activity.

Likewise, GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall not tolerate any

type of activity that could involve the custody, storage or traffic of illicit goods in

legal relations.

GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall encourage among its

contractors and suppliers compliance with the legal standards on occupational

health and safety.

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5.2.1.3. Intimacy

GRUPO GARNICA PLYWOOD S.A. and subsidiaries commits to not disclosing any

information requested from employees or other interest groups, except for

personal information required by law or given with their consent.

Any employees or interest groups that have access to information as a result of

their activity commit to using this information correctly and in accordance with the

law, guaranteeing their confidentiality.

5.2.2 Before situations of conflict of interest

A conflict of interest will be understood as any situation where the personal

interests of any member of the interest groups and the interests of GRUPO

GARNICA PLYWOOD S.A. and subsidiaries directly or indirectly collide. The former

should avoid any situation that could involve a conflict of interest on a personal,

family or any other level. The interest groups should also abstain from

representing GRUPO GARNICA PLYWOOD S.A. and subsidiaries or include or

intervene in any decision-making where they or any person related directly or

indirectly has a personal interest.

5.2.2.1. Gifts, compensations, presents, assistance and other type of offerings

The employees and executives of GRUPO GARNICA PLYWOOD S.A. and subsidiaries

in the performance of their activity shall act giving priority to the interests of the

company against any personal or third-party interests that could influence their

decisions or actions.

The Employees of GRUPO GARNICA PLYWOOD S.A. and subsidiaries may neither

offer nor receive gifts in the course of their professional activities. Exceptionally,

the delivery and acceptance of gifts and presents will be authorised when, not

prohibited by the legislation, their economic value is irrelevant or symbolic and

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they respond to the customary courtesy or business habits while not affecting any

decision-making or professional performance.

Specifically, the employees of GRUPO GARNICA PLYWOOD S.A. and subsidiaries

may not give or receive, without valid legal grounds, any kind of bribery or

commission, originated or made by any other party involved, such as Spanish or

foreign civil servants, employees of other companies, political parties, customers,

contractors, suppliers and shareholders. This includes any direct or indirect offer or

promise of any kind of improper benefit, any instrument to conceal such benefit

and influence peddling.

If any employee or executive of GRUPO GARNICA PLYWOOD S.A. and subsidiaries

were to receive a gift or assistance with a relevant economic value that does not

answer to any usual business courtesy or attention and that does not affect any

decision-making or professional performance, on a general basis, the employee or

executive shall return it and explain the policy of GRUPO GARNICA PLYWOOD S.A.

and subsidiaries in this respect. If this were not possible due to reasons of culture

or any other, the gift or attention shall be forwarded to the department of Human

Resources for its delivery to renowned social associations, charities or non-

governmental organisations.

5.2.3 Treatment of information and law

5.2.3.1 Confidentiality

Professional secrecy shall be kept of commercial, economic or strategic

information belonging to GRUPO GARNICA PLYWOOD S.A. and subsidiaries or to

companies or people comprising it or with which it engages, except for when its

disclosure is allowed by law, when express authorisation has been provided or

when requested by law or court order.

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Strict confidentiality shall be respected in the use of operational processes, work

systems and any other internal procedure.

5.2.3.2. Transparency and disclosure

GRUPO GARNICA PLYWOOD S.A. and subsidiaries assumes transparency as a

principal of behaviour. This shall be understood as the commitment to transmit

reliable information to the market and Society as a whole, allowing them to obtain

a truthful picture of the activities, strategy and economic, social and environmental

performance of GRUPO GARNICA PLYWOOD S.A. and subsidiaries.

The interest groups must transmit the information in a truthful, complete and

comprehensible manner. Under no circumstances shall they provide or allow the

generation of incorrect, inexact or imprecise information that could induce to error

in the recipients. The forgery, manipulation and deliberate use of false information

represent a fraud.

5.2.3.3. Law. Prevention of money laundering

All the operations and transactions performed by GRUPO GARNICA PLYWOOD S.A.

and subsidiaries must be strictly legal, especially ensuring the compliance of all tax

and social security obligations. They should all be posted in the accounting system

at the appropriate time and following the criteria of existence, integrity clarity and

precision. This shall be performed in conformance with the accounting standards

applicable at each moment and in such a way that all the financial information is

reliable and includes all the assets and liabilities of GRUPO GARNICA PLYWOOD

S.A. and subsidiaries.

Particularly, the employees and executives of GRUPO GARNICA PLYWOOD S.A. and

subsidiaries shall abstain from:

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a) Establishing accounts that are not recorded in the books

b) Not recording any performed transactions or posting them erroneously

c) Recording fictional incomes, expenses, assets and liabilities

d) Posting expenses with an incorrect indication of its purpose

e) Using false documentation

f) Deliberately destroying accountancy records before the period required

or established by law

g) Incorporating companies and opening bank accounts in tax havens

GRUPO GARNICA PLYWOOD S.A. and subsidiaries and the employees, as well as the

interest groups involved, must comply with the obligations imposed by the law on

money laundering and shall not illicitly or inappropriately use, in any case,

information related to customer payments.

Accordingly, it is forbidden to perform any activity that involves falsifying or using

fraudulently any payment mechanisms used by the customers and/or suppliers of

GRUPO GARNICA PLYWOOD S.A. and subsidiaries, such as credit or debit cards,

among others.

5.2.4 In relations with the environment and other agents in its environment

No interest group must collaborate with any third party in the violation of any law

or collaborate in actions that could compromise the principle of legality or that

could damage the reputation of GRUPO GARNICA PLYWOOD S.A. and subsidiaries.

5.2.4.1. With the environment and territory

GRUPO GARNICA PLYWOOD S.A. and subsidiaries is committed to the environment

and the situation of the territory, and it faces its environmental commitment by

looking after the compliance with the applicable legislation in any of its spheres of

activity.

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The interest groups shall perform their activities with the greatest respect for the

environment, complying with the applicable regulation in order to minimise the

negative environmental impact and optimise the use of the available resources in

all its spheres of activity.

Likewise, the interest groups shall pay special attention to the use of explosive or

potentially radioactive material, if any, with the purpose of avoiding any incident

that could affect its employees or any third parties.

In addition, the interest groups shall apply this commitment to the customers,

suppliers and all the people with which it relates in the scope of its activity, taking

as a basis the minimum standards established by the Spanish law.

5.2.4.2. With costumers and consumers

Independence shall always be safeguarded in any professional performance with

customers and consumers, avoiding any influence from economic or family links or

friendship. Specifically, independence shall be guaranteed in the granting and

establishment of conditions in any information or work or in any procurement of

goods or services in general.

Rigour in the treatment of the personal information related to customers shall also

be ensured. The access to customer information shall only be justified for legal

reasons, and its custody and use shall be performed with strict adherence to the

provisions established in the current regulation, specifically, in the law on personal

data protection.

The products and services shall be offered to customers and consumers through

sufficient and precise information.

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Under no circumstances shall the interest groups be encouraged to perform

actions that could result in direct or indirect advertising of illicit or potentially

fraudulent activities.

In particular, the interest groups commit to respecting customer information that is

especially protected from a point of view of intellectual or industrial property.

GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall search for the best formulas

in promoting respect for the content and principles of this Code of Ethics among its

customers, specifically, for the contents and principles that affect the safety and

the compliance with the law, accurate information, the respect for the rights of

third parties and the human dignity.

5.2.4.3. With suppliers and contractors

The relations with suppliers in GRUPO GARNICA PLYWOOD S.A. and subsidiaries

shall be performed in a framework of transparent collaboration that allows and

helps achieve the shared goals and the fulfilment of the social responsibility held

by GRUPO GARNICA PLYWOOD S.A. and subsidiaries, always complying with the

current legislation.

The interest groups shall not encourage or participate in any potentially illicit

activity, especially if there is a risk of a supplier harming any third party.

The selection and contracting of suppliers must comply with the internal standards

existing at any time, guaranteeing transparency, an equal treatment and the

application of objective criteria without any beneficial treatment.

GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall encourage and widespread

the contents and principles of this Code of Ethics among its main suppliers.

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In any case, the interest groups shall only contract with suppliers that offer

possibilities of complying with the current law and the provisions of this Code.

5.2.4.4. With partners

GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall encourage the awareness of

this Code of Ethics among its partners with the purpose of applying its contents in

the best possible manner.

5.2.4.5. With respect to the competition

GRUPO GARNICA PLYWOOD S.A. and subsidiaries is committed to free competition

and the compliance of the laws established in this field. It shall avoid incurring in

any action that involves an illicit abuse or restriction of the competition. The

interest groups shall honour this commitment and also avoid any action that

involves a disloyal behaviour in the markets. Particularly, they shall by not carry out

any misleading advertising of activities, products or services of GRUPO GARNICA

PLYWOOD S.A. and subsidiaries. All this with the aim of avoiding any conduct that

constitutes or could constitute an illicit abuse or restriction of the competition or a

legally disloyal practice or the use of a trade secret or any confidential information

belonging to a third party.

5.2.4.6. In the market, in institutional relations and in relations with third parties

The relations with institutions, bodies and public or private authorities must be

governed by institutional respect and must be performed strictly following the

criteria of legal compliance. Therefore, all the sections of this Code are applicable,

especially those cases referred to in section 5.2.2.1.

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5.2.4.7. With legal and tax authorities

GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall consider as wrongful any

action that involves a failure to comply accurately and faithfully with any legal and

tax obligations. The interest groups must conform their behaviour to the previous

criterion, and especially not perform any activity that is not within the scope of the

authorisation or licence applicable in each case.

Likewise, GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall collaborate with

the Public Authorities at all times, complying with its requirements regarding the

organisation itself and its requirements with respect to its employees or external

collaborators. In this regard, GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall

ensure entering rigorous and reliable information in its computer systems, thus

avoiding any collaboration with employees or third parties for fraudulent

purposes.

5.2.5 In relation to assets and rights of GRUPO GARNICA PLYWOOD S.A. and its

Group

The resources, means, goods and premises of GRUPO GARNICA PLYWOOD S.A. and

subsidiaries must be used in benefit of GRUPO GARNICA PLYWOOD S.A. and the

Group while complying with the Law. This shall be performed without harming any

third-party rights and without any particular intention or personal benefit or

benefit of third parties other than the purpose of GRUPO GARNICA PLYWOOD S.A.

and subsidiaries.

All interest groups must comply with the current law on Data Protection and

exclusively use and request the information that is strictly required. This obligation

includes the correct use of what should be done with corporate resources related

to information technology and communications put at the availability of those

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concerned, complying with the contents established in the applicable internal

procedures.

GRUPO GARNICA PLYWOOD S.A. and subsidiaries respects the personal

communications carried out using the Internet and other means of communication.

The interest groups, especially the employees, commit to a responsible use of the

Internet and other means of communication, the computer systems and, in general,

any other media made available by GRUPO GARNICA PLYWOOD S.A. and

subsidiaries.

In any case, all computer elements, such as personal computers, email, temporary

files, access to the Internet, etc. shall be considered work tools, and they shall be

used exclusively for professional purposes. In spite of allowing a reasonable

personal use of these systems, GRUPO GARNICA PLYWOOD S.A. and subsidiaries

shall adopt the necessary control measures on these work tools by using different

mechanisms and/or media, with the purpose of guaranteeing a suitable and

effective use.

The servers and other tools provided by GRUPO GARNICA PLYWOOD S.A. and

subsidiaries cannot be used for personal or illicit purposes (especially if seeking to

attack the competition), for downloading or taking advantage of unauthorised

information that is protected by copyright or industrial or intellectual property

laws when not holding the corresponding licence, or for taking advantage of

information with the aim of achieving an illicit purpose.

In this sense, GARNICA PLYWOOD S.A. and subsidiaries shall ensure that its

employees, executives and external collaborators do not infringe any third-party

industrial and intellectual property rights, in accordance with the applicable

legislation.

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6. RESPONSIBILITIES RELATED TO THE CODE OF ETHICS

The tasks entrusted to each employee shall be performed following criteria of

rigour and responsibility. A responsible professional behaviour abides by the

efficient contribution to applying the policies and reaching the objectives defined

by GARNICA PLYWOOD S.A. and subsidiaries.

Understanding and complying with the principles of this Code of Ethics is a general

responsibility of all the interest groups.

However, it is worth noting some differences in their responsibilities.

6.1. SHARED RESPONSIBILITIES

All the interest groups must fulfil the following responsibilities:

Comply with the principles and standards established in this Code

Comply with the laws, regulations and other rules of application to their jobs

Seek advice in the event of any doubts regarding the compliance with this

Code of Ethics

Participate in the training and assessment activities offered

Inform about any non-fulfilment or infringement of the rules included in this

Code

Collaborate in good faith with the carrying out of the controls and internal

audits performed to identify and correct any eventual deficiency and

weakness

6.2. ADDITIONAL RESPONSIBILITIES

Interest groups with directive powers have certain additional responsibilities:

- To lead through example. Their conduct must be a model of upright

behaviour

- To ensure that the employees under their responsibility understand the

requirements of the Code

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7. ACCEPTANCE. COMPLIANCE AND SUPERVISION

The condition of interested party involves the obligation of complying with this

Code. Its circulation and amendments shall follow the applicable internal

procedures.

GARNICA PLYWOOD S.A. and subsidiaries expects from the interest groups an

honest, strict and transparent behaviour that is aligned with the principles of this

Code.

Nobody, regardless of their position, is authorised to request anything contrary to

the contents established in this Code of Ethics or to protect a behaviour relying on

the position of a superior.

For this reason, all the interest groups must immediately inform, in conformance

with the provisions established at that time, of any non-compliance or violation,

especially when it could constitute an offence.

GARNICA PLYWOOD S.A. has implemented a specific communications procedure

known as Ethical Box that enables all interest groups, with a guarantee of

confidentiality and without fear of retribution, to easily and confidentially

communicate those actions that, at their sound judgement, constitute conducts or

actions that are inappropriate or breach the Code of Ethics or any other applicable

internal or external regulation.

The Ethical Box consists of a specific email address (buzonetico@garnica.one) and

a postal address: Dirección de Control de GRUPO GARNICA PLYWOOD S.A., Parque

de San Miguel, núm. 10 Bajo, CP: 26007 Logroño (La Rioja), and it can also be used

by any of the Group's interest groups whose companies are adhered to it.

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The communications received at the Ethical Box shall be treated confidentially;

therefore, all the necessary measures to guarantee this confidentiality shall be

implemented at all times.

However, in order to ensure the accuracy of the information received, only those

complaints in which the complainant is clearly identified will be accepted. The

Ethics Committee has been empowered to analyse and assess these complaints,

and it will reach its decisions by majority. This Ethics Committee shall be made up

of all the people defined in the internal documents of GARNICA PLYWOOD S.A. and

subsidiaries.

8. DISCIPLINARY PROCEEDING

As the behaviours included in this Code of Ethics are mandatory in GARNICA

PLYWOOD S.A. and subsidiaries, the Ethics Committee must assess every complaint

received. The General Directorate of Human Resources or the equivalent body of

each Group company must take the appropriate disciplinary measures that arise

from applying the Code of Ethics, while considering in all cases the applicable

bargaining agreements and regulations and the Manual for Prevention and

Response to Offences prevalent at the time.

Among the violations that can be subject to disciplinary measures are:

a) Breaching or inciting to breach any prohibitions or standards established in the

Code.

b) Refraining from the obligatory communication of a suspicion of a violation or

notable non-compliance of the standards established in the Code of Ethics of

GARNICA PLYWOOD S.A. and subsidiaries.

c) Not cooperating with the investigations carried out by GARNICA PLYWOOD S.A.

and subsidiaries in possible breaches of the Code.

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d) Taking retaliation against an employee or executive of GARNICA PLYWOOD S.A.

and subsidiaries for communicating a breach of the standards of the Code of

Ethics.

e) Lacking the leadership or being negligible in the duty of demanding adherence

to the Law and the standards of the Code of Ethics.