POLICY FOR COMMUNICATING WITH SHAREHOLDERS, INSTITUTIONAL INVESTORS AND PROXY ADVISORS AND FOR COMMUNICATING ECONOMIC- FINANCIAL, NON-FINANCIAL AND CORPORATE INFORMATION

  1. Principles
    In accordance with Article 21 of the Regulations for the Board of Directors of MAPFRE S.A. (hereinafter "MAPFRE" or the "Company"), the Board of Directors is the body responsible for establishing and supervising appropriate mechanisms for communication and relations with shareholders, ensuring equal treatment between them in order to avoid situations of privilege or market abuse, as well as with institutional investors, proxy advisers and the general public.
    The Company's communication with said groups shall be carried out in accordance with the following basic principles:
    1. Strict, timely and appropriate compliance with legally established communication and information obligations and corporate governance recommendations in this regard.
    2. Truthfulness, transparency, immediacy and respect for the principle of equality in the dissemination of information, so that shareholders receive all the legally enforceable economic-financial,non-financial and corporate information, as well as any other information that could be considered of interest, in a clear and accessible manner.
    3. Protection of the legitimate rights and interests of all shareholders.
    4. Implementation of a general strategy for communicating economic- financial, non-financial and corporate information through the communication channels provided for in this Policy, which will help to maximize the dissemination and quality of information available to the market, institutional investors and other stakeholders.
    5. Provision of the appropriate communication channels to shareholders so that they may exercise their right to information and harness the advantages of new technologies; thereby keeping the Company at the forefront in using new communication channels and social networks.
  2. Communication and contact channels
    In order to ensure compliance with the principles set out in Section 1 above and that information relating to MAPFRE is correctly disseminated to the market, the Company has the following communication and contact channels:

2.1. Spanish National Securities and Exchange Commission

The Company shall publish inside information and other relevant information under the terms established in current legislation the

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WARNING: The English version is only a translation of the original in Spanish for information purposes. In case of discrepancy, the Spanish version shall prevail.

Spanish National Securities and Exchange Commission (the "CNMV") website. Said information shall also be incorporated simultaneously in the Company's corporate website.

2.2. Corporate website

The Company's corporate website, www.mapfre.com, has a section specifically for its shareholders and institutional investors where it provides the legally enforceable economic-financial,non-financial and corporate information, as well as any other information that may be of interest to them.

In particular, the Company immediately publishes on its website:

  • All communications of inside information or other relevant information made to the CNMV and other official bodies, pursuant to current legislation;
  • All documents required by current legislation in relation to calling and holding Annual General Meetings, which will also be streamed live through this website; and
  • Any other information that must legally be published, as well as any corporate policies and any information that is deemed appropriate to share due to its usefulness to the aforementioned group.

Communications published on the corporate website regarding inside information and any other relevant information, as well as communications regarding information published on the website for the purpose of holding ordinary or extraordinary annual general meetings, it shall remain available to said groups and to the general public for a minimum period of five years or for the legally prescribed higher term, where appropriate.

2.3. Webcasts

The Company has a streaming channel featuring quarterly results presentations and other communications that are relevant for the market, which can be accessed by anyone who may wish to view them as a further means of staying informed of the Company's progress. This channel is also available on a deferred basis and is accessible through the corporate website.

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WARNING: The English version is only a translation of the original in Spanish for information purposes. In case of discrepancy, the Spanish version shall prevail.

  1. Meetings with shareholders and institutional investors
    The Company shall organize, at least on a half-yearly basis, informative meetings with shareholders and institutional investors from significant financial markets, in order to present the main aspects of the Company's economic-financial,non-financial and corporate information and its progress in terms of business, and to respond to their requests for further information, unless doing so concerns confidential information.
  2. Investor Relations Area
    The Investor Relations Area is the communication channel between the Company and its shareholders and institutional investors that is permanently open in order to respond to their inquiries and requests for information as soon as possible, giving absolute priority to the Company's interest and respecting current legislation on market abuse.
    The contact details for the Investor Relations Area, among others, will remain available on the Company's corporate website. These contact details include two email addresses (IR@mapfre.comand oficinadelaccionista@mapfre.com)and a toll-free number +34 900 10 35 33, which constantly address suggestions and comments as well as any questions that may be raised by shareholders and institutional investors.
    This Area also constitutes the communication channel for proxy advisors for the purpose of informing them and addressing their queries in relation to the agreement proposals made to the Annual General Meeting as a result of their recommendations.
  3. Other communication channels
    The Company encourages an active presence on social networks and on other media such as the press or television, whereby it seeks to share information of interest on MAPFRE'S progress and activities, fulfilling at all times its legal obligations of transparency, clarity and veracity when sharing information and taking into account current legislation and CNMV guidelines in this regard.
    In the event that the Company decides to use social networks to communicate inside information to the CNMV, whether simultaneously or as an additional or complementary channel, it shall comply with the following requirements:

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WARNING: The English version is only a translation of the original in Spanish for information purposes. In case of discrepancy, the Spanish version shall prevail.

  1. The information shared will be complete, objective and clear, and the original message will not require additional sources in order to be fully understood.
  2. The message will clearly indicate "Inside Information" and will remain separate from any promotional or marketing communications.
  3. Both the issuer (full company name) to whom the information relates and the communicator shall be clearly identified.
  4. The communication shall be carried out via a social network with a very wide reach and from accounts with a very large following.
  5. It shall be communicated formally and accurately, and no information shall be added or nuanced in responses or conversations that are essential to the understanding of the information.

2.7. Rules relating to the sharing of inside information and other important information

Special account shall be taken of the rules on processing insider information and other information pertinent to relations with shareholders and communication with the securities markets provided for in the Regulations for the Board of Directors, the Internal Code of Conduct relating to Securities issued by MAPFRE and other internal corporate rules for processing inside information and pertinent information.

In particular, inside information or other pertinent information may not be shared through any other means without said information having been previously published on the CNMV website and without prior authorization from MAPFRE's General Counsel, in particular, in terms of sharing said information on social networks.

Furthermore, the content of inside information or other pertinent information shared to the market through a communication channel other than the CNMV shall be consistent with that of the corresponding information published on the CNMV and shall comply with the sharing criteria outlined in this Policy.

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Approved on July 23, 2015

Last amendment approved on February 9, 2022 (effective as of March 11, 2022)

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WARNING: The English version is only a translation of the original in Spanish for information purposes. In case of discrepancy, the Spanish version shall prevail.

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Mapfre SA published this content on 17 May 2024 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 17 May 2024 13:27:03 UTC.