ECOPETROL S.A.

In 2024, Ecopetrol introduced significant enhancements to the Code of Ethics and Conduct, aligning it with evolving business practices, market expectations, and the highest international standards of ethics and compliance.

The Code of Ethics and Conduct applies to the companies of the Ecopetrol Group, members of the Board of Directors, legal representatives, employees (and their families) at all levels of each of the affiliate companies, and the beneficiaries of the services provided by the Ecopetrol Group.

The most significant change introduced within the update was the release of a Code of Ethics and Conduct exclusively applicable to all individuals or legal entities that have any relationship with Ecopetrol, including contractors (as well as third parties hired by contractors), suppliers, agents, partners (including in joint ventures) and customers. Additionally, all our agreements with suppliers or third parties include a provision regarding compliance with applicable anti-bribery, anti-corruption, and general compliance regulations, to prevent and detect improper conduct in our business. In the agreements, we also require our suppliers and third parties to acknowledge our Code of Ethics and Conduct, as well as our compliance guidelines.

The Code of Ethics and Conduct establishes integrity as the guiding principle for all its recipients. Furthermore, the Code of Ethics and Conduct requires strict compliance with national and international laws, standards and provisions applicable in the countries where Ecopetrol operates, including the United States and Colombia, as well as adherence to internal regulations adopted by Ecopetrol.

The Code of Ethics and Conduct provides guidelines for the following aspects: conflict of interest; ethical conflict; prohibition of bribery, other forms of corruption and violations of the U.S. Foreign Corrupt Practices Act (FCPA); accounting integrity; prevention and rejection of money laundering, financing of terrorism and proliferation of weapons of mass destruction; gifts, hospitality, and entertainment practices; protection and responsible use of resources; information management; security and confidentiality; prohibition of insider trading; environmental policy; social responsibility; respect for human rights and rejection of discrimination; antitrust and anticompetitive practices; prevention and rejection of workplace sexual harassment; and examples of ethical behavior.

In addition, Ecopetrol’s Code of Ethics and Conduct explicitly forbids facilitation payments, political contributions and charitable contributions, lobbying, and the diversion of funds from social investment or sponsorships activities to political activities or unauthorized purposes.

The Code of Ethics and Conduct also highlights its ethics hotline to encourage reporting of any conduct that may breach the Codes or any of the Ecopetrol Group companies’ ethical and compliance guidelines. The Code of Ethics and Conduct emphasizes the protection of whistleblowers acting in good faith.

Our Code of Ethics and Conduct is available on our website.