Recommendation VIII: Ensuring ethical behavior within the Issuer

Compliance: Total

Inform or Explain: Pampa has a Code of Business Conduct in place which states the ethical principles constituting the groundwork for the relationship between Pampa, its employees, customers, suppliers, shareholders, investors, the public sector and the community at large. Moreover, it provides means and instruments to ensure transparency in the handling of matters and issues that may affect Pampa’s adequate management.

The Code of Business Conduct is publicly available at the Company’s website and should be expressly accepted by all Company employees, directors and members of the Supervisory Committee. Furthermore, the Code is included as part of the general recruitment conditions.


Compliance: Total

Inform or Explain: Pampa offers the Ethics Hotline, an exclusive channel to report, on a strictly confidential basis, any suspected misconduct or breach to the Code of Business Conduct. This tool is available through different channels (toll-free telephone number, e-mail or web page) and is managed by a third-party supplier to ensure higher transparency and information integrity. Additionally, the Company has policies and procedures in place prescribing the way in which received complaints should be analyzed and dealt with. The responsibility over this channel rests with the Audit Committee, which delegates its administration to the internal audit area.



Compliance: Total

Inform or Explain: Pampa has an Anti-Fraudulent Practices Policy and a Procedure for handling complaints. Both documents contain a detailed description of the process to be followed from the reception of the complaint to the conclusion of the investigation and the application of the pertinent corrective action. At least quarterly, the Internal Audit area reports the received cases and the adopted decisions to the Audit Committee. The Audit Committee supervises the channel’s operations and the resolution of complaints in issues within its authority, and approves related regulations.