Summary of the Interaction with Public Officials and Lobbying Procedure

Integrity is one of the fundamental principles that must guide the behavior of Aguas Group employees. This is established in the Code of Ethics, which disapproves of corruption in all its forms. In this sense, the company has implemented this Anti-Corruption Policy which aims to specify these principles and serve as a guide for the action of the Aguas Group employees at all levels, guiding them with respect to what the company expects and demands of their behavior when dealing with third parties, including business partners, the company's own employees and, in particular, public officials.

This policy is part of the company's Comprehensive System for Compliance and Anti-Corruption Management and is complementary to the Code of Ethics, the Compliance Policy and other internal policies, especially the Aguas Group’s Law No. 20,393 Crime Prevention Model.

This Policy applies to all companies that make up the Aguas Group (Aguas Andinas S.A., Aguas Cordillera S.A., Aguas Manquehue S.A., Empresa de Servicios Sanitarios de Los Lagos S.A., Gestión y Servicios S.A., Análisis Ambientales S.A., Ecoriles S.A. and Aguas del Maipo S.A.), and must be observed by all persons who are part of such companies at all levels (directors and employees), acting in Chile or abroad, as well as other third parties acting on behalf of the company.

In addition, it applies to all companies, subsidiaries and associations over which any company of the Aguas Group has control. In cases where the company does not have such control or has equal participation with other partners, they should be encouraged to adopt and implement policies and measures that contribute to preventing acts of corruption.

6.1. General

In carrying out its normal business, the Aguas Group maintains constant relations with public administration, state-owned companies and various public officials. In the context of such interactions, the company promotes transparency, and expects its employees to act within the limits of internal rules, respecting the Code of Ethics, Compliance Policy, Anti-Corruption Policy and related procedures, the Aguas Group’s Crime Prevention Model and other applicable internal regulations. Conflicts of interest and conduct that may be interpreted as an attempt to obtain undue consideration should always be avoided. In those cases in which the relationship with the public administration occurs within the framework of an external regulation, such as lobbying and interest management, this regulation shall serve as a reference and compliance shall be mandatory.

The purpose of this procedure is to specify the general principles of action of the Aguas Group, describing the criteria and norms that should guide the performance of employee functions and responsibilities in the context of interactions with public authorities and officials. In addition to the provisions of this document, employees should be aware of and strictly comply with the rules regarding public officials established in the Gifts, Invitations and Travel Procedure and in the Conflict of Interest Management Procedure.

In the Aguas Group, all forms of corruption and bribery are strictly prohibited. Bribery means offering, promising, giving, accepting to give, or requesting an undue advantage of any value to a person as an incentive or reward to perform or refrain from performing activities of his or her function or for having performed or omitted activities. It is also the conduct of those who request, receive or agree to receive a benefit under the conditions indicated.

In our country, private bribery can be a crime if it involves deception and prejudice to a person or company. Bribery of national or foreign public officials, for its part, is a crime that can be punished with a prison sentence and may lead to criminal liability of legal persons as provided by Law N° 20,393.

6.1.1. Prohibited Activities

With respect to national and foreign public officials, and without the following list being exhaustive, it is prohibited to:

1. Offer, give or accept undue benefits of any nature:
   1. So that officials perform any action that relates to the company, or for having performed them.
   2. So that another public official is influenced to make decisions that can benefit or compromise the company.
2. Exercise undue influence over a public official with whom there is a personal relationship (of kinship, friendship, mutual business, politics, etc.) in order to obtain a resolution from them beneficial to the interests of the Aguas Group.
3. Request or accept a benefit of any kind in exchange for unduly influencing an authority or public official.
4. Contribute to a public official to remove or divert funds that are in their charge.

6.3. Lobbying and Management of Interests

The Aguas Group defines lobbying and advocacy as the promotion of the interests of its entities through objective information, with the difference between the two activities being compensation for carrying them out (the lobbyist receives compensation for his activities, while the interest manager does not). At the end of the day, it is a matter of publicizing Aguas Group to promote its image, values, activities and services, as well as defend its interests.

When an institution or a country regulates the activity of the defense of interests, as in the case of Chile, the entities must respect these regulatory obligations and employ only registered and authorized lobby professionals. If third parties are to be contracted outside the company to perform this function and represent it in lobbying activities, they must commit and be subject to the Code of Ethics, Compliance Policy, Anti-Corruption Policy, this procedure and any other documents deemed pertinent, in particular, the Aguas Group Crime Prevention Model.

The activities regulated by the Lobby Law are those that seek to adopt or not adopt the following decisions and acts:

1. Elaboration, dictation, modification, repeal or rejection of administrative acts, bills and laws, as well as decisions taken by the authorities.
2. Preparation, processing, approval, modification, repeal or rejection of agreements, declarations or decisions of the National Congress or its members, including their commissions.
3. Conclusion, modification or termination of any contract by the authorities and necessary for their operation.
4. Design, implementation and evaluation of policies, plans and programs carried out by the authority.

Meetings that are not intended to influence the actions mentioned above should not be recorded as lobbying or private interest management activities.

Generally, when requesting a meeting with the obligated public officials, we will be required to proceed in the manner provided in this procedure. Otherwise, Aguas Group employees should demand that it be so. For purposes of the Lobby Law, this procedure must be applied with respect to the authorities indicated in Annex II of this document.

The following details the steps that must be followed to conduct a meeting, in accordance with the provisions of Law N° 20,730, which Regulates Lobbying and the Procedures that represent Particular Interests before the Authorities and Officials, or "Lobby Law."

6.4. Facilitation Payments

Facilitation payments are understood to mean payments made to public officials to expedite acts or routine public procedures, such as the processing of visas, permits, customs procedures, etc.

Facilitation payments are not legal in Chile, and are therefore prohibited in all places and circumstances. Regarding other countries, even if they are allowed, Aguas Group employees should not make facilitation payments in the exercise of their functions.

The Compliance Officer shall be responsible for ensuring compliance with this policy, and shall report at least every six months to the Board of Directors and to the Integrity and Compliance Committee regarding said compliance in its periodic report to senior management.

The Anti-Corruption Policy and its procedures will be reviewed and updated, if necessary, at least once a year.