Supplier Code of ​Conduct

CODE OF ETHICS AND CONDUCT FOR SUPPLIERS, CONTRACTORS, SUBCONTRACTORS, AND ALLIES

This document embodies Ecopetrol S.A.'s unwavering commitment to fostering ethical, transparent, and sustainable practices across its entire value chain. Grounded in principles of integrity, respect for human rights, environmental stewardship, and social responsibility, the Code of Ethics and Conduct serves as a cornerstone for building trust and accountability with suppliers, contractors, subcontractors, and allies; through these guidelines, Ecopetrol reinforces its dedication to not only achieving business excellence but also driving meaningful contributions to the well-being of communities and ecosystems.

Ecopetrol demands the highest standards of ethical behavior, encouraging all stakeholders to act with honesty, fairness, and diligence in every aspect of their work; by adhering to this Code, suppliers and partners commit to upholding these values, ensuring compliance with international best practices and local regulations while advancing shared goals of sustainability and inclusivity.

The document reflects Ecopetrol’s holistic approach to creating value—one that harmonizes economic growth with environmental conservation and the promotion of social equity.

Some of the specific principles and commitments defined by de Code, are described below:

1. FORCED LABOR: The Code strictly prohibits forced, bonded, or involuntary labor in any form. Suppliers and contractors must ensure that all work is conducted freely, and employees have the right to leave employment after reasonable notice. Ecopetrol enforces this commitment by requiring detailed audits, robust whistleblowing mechanisms, and compliance assessments to eliminate any risks associated with forced labor practices.
2. CHILD LABOR: Ecopetrol enforces a zero-tolerance policy against child labor. Suppliers and contractors are required to adhere to local labor laws and international conventions, ensuring no individual under the legal working age is employed. The company collaborates with local communities to create educational programs and initiatives that protect children’s rights and ensure they are not subjected to exploitative labor practices.
3. WORKING CONDITIONS: Suppliers and contractors must provide fair and dignified working conditions, including reasonable working hours, appropriate wages, and benefits as per local laws and industry standards. Ecopetrol advocates for periodic evaluations of workplace conditions, ensuring all work environments are conducive to the mental and physical well-being of employees. The company provides resources and training to help its partners maintain and improve workplace standards.
4. OCCUPATIONAL HEALTH AND SAFETY: The Code underscores the importance of preventive measures to ensure occupational health and safety. Suppliers and contractors must adopt industry best practices, comply with local regulations, and report incidents transparently. Ecopetrol emphasizes creating a proactive safety culture, including continuous monitoring, safety training programs, and investment in state-of-the-art protective equipment to minimize workplace risks.
5. DISCRIMINATION AND HARASSMENT: Ecopetrol prohibits any form of discrimination or harassment based on gender, ethnicity, religion, political affiliation, or other personal attributes. Suppliers and contractors must foster inclusive and respectful workplaces, ensuring all employees are treated equitably and protected from harassment. The Code includes explicit guidelines for reporting and addressing complaints, supported by training to raise awareness about diversity and inclusion.
6. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING: The Code supports employees' rights to freedom of association and collective bargaining, as outlined in international conventions. Suppliers and contractors must respect these rights and facilitate dialogue between workers and management without retaliation or discrimination. Ecopetrol monitors compliance through stakeholder engagement and encourages open communication to resolve disputes constructively.
7. GREENHOUSE GAS EMISSIONS AND ENERGY CONSUMPTION: Suppliers and contractors are required to monitor, report, and mitigate greenhouse gas (GHG) emissions in their operations. Energy efficiency measures must be implemented to align with Ecopetrol’s climate goals and contribute to a lower carbon footprint. Ecopetrol provides technical support, sets reduction targets, and encourages innovation in renewable energy solutions to reduce emissions across its supply chain.
8. POLLUTION PREVENTION AND WASTE MANAGEMENT: Suppliers and contractors must adopt rigorous practices to minimize pollution and manage waste responsibly. This includes implementing technologies to reduce emissions and adopting strict measures for the proper disposal and treatment of hazardous and non-hazardous waste. Ecopetrol collaborates with its partners to ensure the adoption of circular economy principles, promoting recycling, reusing materials, and reducing landfill dependency. Furthermore, initiatives such as cleaner production methods, pollution audits, and awareness campaigns are integral to reducing environmental impact. Ecopetrol also enforces strict guidelines for water management to prevent contamination of water sources and requires partners to report regularly on waste handling and pollution control efforts. These measures aim to ensure the protection of ecosystems and community health.
9. RESOURCE EFFICIENCY: Efficient use of natural resources is mandatory. Suppliers and contractors are encouraged to integrate circular economy principles, reduce resource consumption, and implement innovative methods to optimize materials, energy, and water use. Ecopetrol supports projects that emphasize resource conservation, such as energy recovery systems, water recycling facilities, and sustainable procurement practices. These efforts aim to create a balance between operational demands and environmental stewardship.
10. BIODIVERSITY, NO DEFORESTATION, AND LAND CONSERVATION: Suppliers and contractors must protect biodiversity and adhere to land conservation practices. Activities that contribute to deforestation or harm ecosystems are strictly prohibited. Ecopetrol actively invests in reforestation projects and biodiversity conservation initiatives, working closely with local communities to restore natural habitats. The company’s policies emphasize the need for environmental impact assessments before initiating projects and promote sustainable land use practices to maintain ecological balance.
11. ANTI-CORRUPTION AND CONFLICT OF INTEREST: Ecopetrol has a zero-tolerance policy towards corruption, bribery, and fraud. Suppliers and contractors are prohibited from offering, accepting, or engaging in any form of bribery. Conflicts of interest must be disclosed and managed transparently, ensuring decisions are made in Ecopetrol’s best interest. Regular training programs, rigorous due diligence processes, and clear contractual clauses are in place to uphold ethical practices and protect against corruption risks.

Ecopetrol’s Code of Ethics and Conduct establishes a robust framework to ensure ethical, sustainable, and transparent practices throughout its supply chain. Compliance is mandatory, and violations may result in contractual and legal consequences. By adhering to these principles, suppliers, contractors, and allies contribute to Ecopetrol’s mission to drive excellence and sustainability in its operations.

Additionally, in 2024, Ecopetrol deployed the sustainability decalogue that contemplates the following management aspects:

SUSTAINABILITY DECALOGUE

Ecopetrol also counts with a Code of Ethics and Conduct defines the standards of conduct expected by the organization and guide the actions of Ecopetrol S.A., of the Group Companies and of all the recipients of the Code, pursuant the highest ethical principles of integrity, responsibility, respect, and commitment to life.  

The accountability of the Code covers the activities and conduct of Ecopetrol´s suppliers and contractors, as it is mentioned on the official document. Therefore, the knowledge and application of this Code will be mandatory for the suppliers working alongside the Company or any of its subsidiaries, who must ensure that their actions are always framed within its rules. 

Principles of Ecopetrol´s Code of Ethics and Conduct: 

INTEGRITY 

Some of the actions or behaviors expected for this principle are: 

• Work with righteousness, loyalty, justice, honesty, and transparency. 

• Impartiality in the decisions and actions, not intending to seek privileges, or personal benefits.  

• Report conflicts of interest, inabilities, and incompatibilities.  

• Zero tolerance to events implying compliance risks. 

(fraud, bribery, corruption, money laundering, terrorist financing, violation of the FCPA)  

RESPOSIBILITY 

Some of the actions or behaviors expected for this principle are: 

• Responsibility of actions and omissions and compliance with local and international regulations and internal provisions applicable to the activities executed.  

• Compliance with the internal and external regulations applicable, the internal work regulations, the culture principles and agreed obligations, and its enforcement. 

• Accountability of mitigating business and activity risks, abiding by the pertinent controls and its respective execution.  

RESPECT 

Some of the actions or behaviors expected for this principle are: 

• Not discrimination or harassment for being of different sex, orientation, race, national or family origin, language, gender, religion, political or philosophical opinion, disability situation, or any other situation that goes against the diversity and inclusion policy adopted by Ecopetrol. 

• Rejection any act of sexual harassment at work. 

• Promotion of equality among my colleagues and the rejection of unfair competition.  

COMMITMENT TO LIFE 

Some of the actions or behaviors expected for this principle are: 

• Respect and promotion of human rights. 

• Protection of the environment, preservation and improvement of environment and the social milieu.  

• HSE policies compliance and enforcement; reporting incidents related to non-compliance with HSE rules. 

Ecopetrol has voluntarily signed the Global Compact of the United Nations, an initiative that promotes the commitment of the private and public sector and the civil society to align their strategies and operations with ten principles that are accepted universally on three thematic areas: Human rights and labor standards, Environment, and Business ethics: 

Human Rights and labor standards: 

Ecopetrol acts in a proactive and differentiated manner through the contractual and commercial relationships with its suppliers to respect, promote and guarantee the following rights and freedoms: 

• Life, integrity and personal liberty. 

• Freedom of union association and collective bargaining. 

• Elimination of forced and compulsory labor. 

• Abolition of any form of child labor. 

• Dignified, favorable and adequate working conditions. 

• Equality and elimination of discrimination in employment and occupation.  

• Health and safety at work. 

• Participation of ethnic groups through prior consultation. 

• Collective and environmental rights. 

• Freedom of expression. 

• Privacy and protection of information and personal data. 

Ecopetrol ratifies its committed to the promotion, respect and assurance of Human Rights, guided by Political Constitution, the applicable national regulations, as well as Ecopetrol´s Human Rights Guide in which the Company adheres to: 

Ecopetrol recognizes the importance of the commitment with International Human Rights Law not only by its own operation but also its suppliers performance since their actions impact territories and communities where Ecopetrol operates. Therefore, it implemented the strategy of declaration, promotion, and appropriation of Human Rights, promoting in its suppliers and workers: 

• Have a public declaration of respect and promotion of Human Rights and commitment to Diversity, Equity, and Inclusion. 

• Implement practices or processes to prevent negative impacts on Human Rights, generated by the principle of due diligence. 

• Promote respect for Labor Rights: decent, favorable and adequate working conditions, freedom of union association and collective bargaining, equality in employment and occupation, equal remuneration, abolition of any form of child labor, prohibition of human trafficking and of slavery, among others. 

• Have practices to promote Diversity, Equity, and Inclusion, and prevent any form of violence, sexual harassment, workplace harassment or discrimination, with special consideration for vulnerable population groups that face greater barriers to social and labor inclusion. 

• Strengthen prevention mechanisms for care and situations that affect Human Rights, violence, discrimination or sexual or workplace harassment. 

Ecopetrol also counts with internal polices, guidelines and normative which seeks to strengthen the supplier´s commitment with this crucial thematic: