Corporate Governance Code

GRUPO NUTRESA S. A. is a Colombian company incorporated on April 12, 1920; it is located in Medellín. Its shares are registered in the Colombian National Securities and Issuers Registry.

Its main economic activity is the investment of shares, quotas or portions of interest, especially in food – sector companies specializing in the coffee, cold cuts, chocolate, biscuits, ice cream and pasta businesses.

This Code is a key element in the development of the most relevant global practices in corporate governance that have been adopted by Grupo Nutresa S. A. and represents a flexible instrument that permits compliance with the corporate philosophy and performance.

The Corporate Governance Code establishes the guidelines for behavior for daily activities in the Grupo Nutresa national and international companies. It also determines the commitment to respect ethical principles regarding the State, the community, the shareholders and other investors. These principles are mandatory criteria to interpret and apply this Code, as well as the vision, mission, corporate philosophy and strategic objectives.

The Company’s conduct regarding the State is to obey and support the legitimately established agencies and authorities and to actively cooperate with them, for the straightforward application of the law.

As concerns the community, the Company takes action in professional guild, sector or national issues; it pursues a better quality of life; uses technology that represents little risk to the environment; and participates in charity work and events of common social benefit.

Regarding shareholders and other investors, the Company will always propose a profit distribution according to the conditions established by the Company; shareholders and other investors will enjoy equal treatment; their legitimate rights will be respected; and they will be fully informed of the Company’s current situation, in a timely, truthful, transparent manner.

Likewise, this Code consists of the attachments, the Human Rights, Anti – Fraud and Anti – Corruption Policies; the Money Laundering and Financing of Terrorism Policy; and the Code of Conduct for Suppliers; which frame the principles of performance in the relationships with Nutresa Business Group third parties and ensure that the negotiations and operations with our related groups are conducted with ethics, transparency, respect and corporate social responsibility.