Preamble

Our investors are our priority and represent the most important part of Magallanes. We are conscious of our fiduciary responsibility in the management of the money of our clients. We manage and protect our clients’ money in a diligent, responsible and committed manner, subject to solid CODE OF ETHICS.

Code of Ethics

Member of Magallanes Value Investors SA SGIIC must:

• Founders and portfolio managers will invest an important part of their personal savings into the funds managed by Magallanes; accordingly, the rest of the employees of the company will be encouraged to do the same.

• Place the integrity and interest of our client above all.

• Act with integrity, diligence and accountability, with clients, employers, employees and other participants in the investment profession.

• Try to do our best and use all our expertise regarding technical capabilities when dealing with investment management decisions in order to give the best service to our clients.

• Protect and reinforce the reputation of the employer within our clients and other participants in the financial markets.

• Share an opened and honest communication within employees and clients, based on listening and transparency.

• Work and encourage others to work in a professional environment based on mutual admiration and respect, where confidence and generosity acts as drivers of team working.