1. Message from the Board

“To serve is first to love.” — Arrigo Cipriani

This Code of Ethics and Integrity (hereinafter, the “Code”) reflects the commitment of Cipriani Punta del Este (hereinafter, “Cipriani” and/or the “Company,” interchangeably)—comprising all companies connected to the project (Casino, Hotel, Beach Club, Croupier Academy and other operating units), belonging to the Cipriani Group—to the highest standards of conduct, integrity, transparency and respect for people across all its operations.

This Code is addressed to all stakeholders with whom Cipriani interacts: directors, managers, employees, suppliers, contractors and related third parties. It constitutes the ethical foundation on which the reputation and sustainability of the business are built, in line with the heritage, Italian traditions and service vocation that have defined the Cipriani Group since 1931.

We trust that its knowledge, understanding and application will contribute to strengthening an organizational culture based on ethics, responsibility and mutual respect.

2. Mission

Inspired by our Italian heritage and traditions, our hospitality is, and will always be, an expression of love.

At Cipriani Punta del Este, this mission translates into delivering an outstanding hospitality, entertainment and service experience, combining international luxury standards with a transparent, safe operation aligned with applicable regulations, generating sustainable value for customers, shareholders, employees and the community.

3. Vision

To be the best hospitality company in the world.

In Punta del Este, Cipriani aspires to be an international benchmark in the hospitality and entertainment industry, recognized for its integrity, quality of service, innovation and regulatory compliance, consolidating the Cipriani brand as a synonym of trust and excellence.

4. Our Pillars

The four pillars of the Cipriani Group guide the ethical and professional conduct of all members of Cipriani Punta del Este and constitute the cultural framework within which the corporate values and policies of this Code are established:

4.1 Culture

Art, history and literature inspire everything we create. We cultivate knowledge, aesthetic sensitivity and respect for traditions as the foundation of hospitality with identity.

4.2 Authenticity

Our smile reflects what is within. We do not just look; we see. We act with honesty, consistency and truth, caring for the human quality of our relationships with customers, guests, employees and third parties.

4.3 Simplicity

There is freedom in simplicity. Our service imposes nothing. We seek clarity, transparency and restraint in processes, decisions and communications, avoiding unnecessary complexity.

4.4 Elegance

We complement the essence of our guests with the finest ingredients, materials and services. Elegance is also expressed through ethical conduct, discretion, respect and operational excellence.

5. Corporate Values

Based on the pillars of the Cipriani Group, Cipriani Punta del Este adopts the following corporate values, which guide the ethical and operational conduct of all its employees and suppliers:

• Excellence in service and hospitality.

• Integrity, ethics and good faith.

• Legal and regulatory compliance.

• Reputation, trust and responsibility.

• Culture, authenticity, simplicity and elegance (foundational pillars).

• Respect, dignity and diversity.

• Equality, non-discrimination and gender perspective.

• Responsible gaming and protection of people in vulnerable situations.

• Social responsibility and sustainability.

• Teamwork and cordiality.

• Innovation in the service of tradition.

6. Purpose and Scope

This Code establishes the principles and standards of conduct that govern the actions of all members, employees and suppliers of Cipriani Punta del Este and the companies connected to the project.

It is framed within the regulations in force in Uruguay (Laws No. 19,574, 20,469, 18,331, 18,561, 16,045, 17,817, 19,580, 19,684, 5,032, and Decree No. 128/016, among others) and the international standards of FATF/GAFILAT and the International Labour Organization (ILO).

This Code complements—without replacing—the Internal Work Regulations of Cipriani and the Collective Bargaining Agreement of Group 12 – Hotels, Restaurants and Bars, Subgroup 1 – Hotels, apart-hotels, motels and inns, applicable to Cipriani’s activity. In the event of any conflict between this Code and mandatory labor regulations, the latter shall prevail.

6.1 Who This Code Applies To

• Employees: directors, managers, permanent or temporary employees and interns of Cipriani Punta del Este S.A. and related companies, for whom compliance is mandatory throughout their professional and employment activity.

• Suppliers and contractors: individuals or legal entities contractually linked to the Company, who must comply with the ethical principles established herein as a condition of the commercial relationship maintained with Cipriani, as set forth in the agreement entered into with the Company.

• Related third parties: includes consultants, agents, business partners and any other person who interacts with Cipriani or acts on its behalf or in its name.

7. General Principles of Conduct

All recipients of this Code, within the scope of their relationship with Cipriani Punta del Este, undertake to comply with the following principles, by way of example and not limitation:

• Act with honesty, integrity and good faith, in line with Cipriani’s pillars of authenticity and simplicity.

• Comply with the regulations in force applicable to their relationship with the Company.

• Protect the reputation, cultural identity and image of the Cipriani Group.

• Promote a respectful, inclusive, safe, equal and discrimination-free environment, free from harassment, cyberharassment and mistreatment.

• Reject all forms of corruption, bribery and influence peddling.

• Preserve the confidentiality of technical, commercial and financial information.

• Act objectively and impartially, avoiding actual, potential or perceived conflicts of interest.

• Respect fundamental rights and the dignity of all persons.

• Safeguard the assets, good name, trust and reputation of the Company.

8. Prevention of Sexual Harassment, Workplace Harassment, Cyberharassment and Mistreatment

Cipriani promotes a positive work environment based on mutual respect, cordiality, collaboration and support among employees and suppliers. Any form of sexual harassment, workplace harassment, cyberharassment, discrimination and mistreatment among employees and/or suppliers of the Company is strictly prohibited, regardless of hierarchy, function or contractual modality, and regardless of whether the conduct occurs on Cipriani’s premises, outside them or through digital media.

8.1 Legal Framework

This Code is framed within the provisions of the Constitution of the Republic (Articles 7, 8, 10 and 72), Laws No. 5,032 and 18,561 and Regulatory Decree 256/017, ILO Conventions No. 155, 161 and 190 and Recommendation No. 206 on violence and harassment in the world of work, as well as Decrees 291/007 and 127/014.

8.2 Company Obligations

• Prevent, discourage and eradicate any conduct constituting harassment, cyberharassment, discrimination and/or mistreatment.

• Investigate all reports in a confidential, objective and impartial manner.

• Protect the privacy, dignity and psycho-physical integrity of complainants, reported persons and witnesses.

• Prohibit and sanction any retaliation against good-faith complainants or witnesses.

• Prepare an Action Protocol on sexual harassment, workplace harassment, cyberharassment and mistreatment, communicate and disseminate it among employees, suppliers and third parties related to the Company, and implement a Reporting Channel for reporting such conduct.

8.3 Equality, Non-Discrimination and Gender Perspective

Cipriani is committed to building a work environment free from all forms of discrimination, in compliance with the Constitution of the Republic and Laws No. 16,045, 17,817, 18,561, 19,580 and 19,684, and ILO Conventions 100 and 111.

Cipriani prohibits all forms of discrimination based on race, color, national or ethnic origin, sex, sexual orientation, gender identity, age, religion, political opinion, marital status, family status, pregnancy, disability, physical appearance, socioeconomic status, union membership, or any other condition. Furthermore, the company is committed to complying with laws regarding inclusion and diversity, as well as protecting individuals affected by sexual harassment, workplace harassment, cyberbullying, and abuse, safeguarding their dignity and psychological and physical well-being, thereby ensuring a healthy and safe work environment.

8.4 Periodic Training and Education

Cipriani Punta del Este will periodically train all its employees on the prevention of sexual harassment, workplace harassment, cyberharassment, discrimination and mistreatment, as well as on equality and gender perspective, through training delivered upon each employee’s entry into the Company and through periodic sessions, as provided in the Annual Training Plan approved by the Human Resources Department.

Likewise, Cipriani may use courses provided by the National Institute of Employment and Professional Training (“INEFOP”), the National School of Public Administration (“ENAP”), or other courses that may be contracted in the private sector, consistent with the prevention and dissemination objectives established in this Code and compliant with the requirements set forth in the law and regulations.

9. Anti-Corruption and Anti-Bribery Policy

Cipriani Punta del Este maintains a zero-tolerance policy toward any form of bribery, fraud, influence peddling, facilitation payments, or corruption by its employees and/or service providers, in accordance with Law No. 17.060, the UNCAC, the OAS Inter-American Convention, and applicable international standards.

The Company shall provide annual anti-corruption training for its employees and service providers.

Likewise, Cipriani shall conduct periodic internal audits and preventive controls in matters related to anti-corruption and anti-bribery.

9.1 Fundamental Rules

• It is prohibited to offer, promise, provide, and/or accept money, gifts, commissions, or any other undue advantages intended to influence decisions.

• Enhanced due diligence shall be conducted when engaging third parties, suppliers, and intermediaries.

• Enhanced due diligence shall be conducted when engaging third parties, suppliers, and intermediaries.

9.2 Obligations of Service Providers

• Comply with all applicable anti-corruption laws.

• Not offer or make payments intended to improperly influence decisions related to the Company.

• Cooperate with any audits and investigations that the Company may conduct.

• Report any suspicious situation involving bribery or corruption through the institutional Whistleblowing Channel.

10. Gifts, Courtesies and Hospitality Policy

Employees and service providers of the Company may only give and/or accept gifts and hospitality within the limits of reasonableness, transparency, and good commercial faith, provided that such gifts or hospitality do not influence or condition the decisions to be made. Full policy: Gifts and Hospitality Policy (CMP-POL-OBS-001).

10.1 Applicable Rules

• General rule: It is not permitted to offer or receive gifts, gratuities, discounts, or advantages that may compromise professional and workplace objectivity and independence.

• Permitted gifts: Promotional, protocolary, or corporate gifts of symbolic and occasional value.

10.2 Absolute Prohibitions

• Acceptance and/or provision of gifts consisting of cash or cash equivalents, including prepaid cards, crypto assets, or similar instruments.

• Acceptance and/or provision of gifts during tendering, awarding, audit, and/or inspection processes.

• Acceptance and/or provision of any gift to public officials that exceeds what is strictly protocolary.

11. Conflict of Interest Policy

A conflict of interest shall exist when a person’s personal, family, and/or financial interests are capable of influencing — or appearing to influence — the objective performance of the duties of a Cipriani employee and/or service provider, and/or the execution of their relationship with the Company.

11.1 Situations to Be Avoided by Cipriani Employees and/or Providers

• Acting as a director, officer, consultant, agent, and/or employee of a supplier, client, and/or competitor that conducts business with the Company.

• Engaging in activities that interfere with the obligations assumed under the agreement entered into with Cipriani and/or that involve competition with the activities carried out by the Company.

• Influencing Cipriani’s purchase and sale transactions, contracts, and/or leases for personal benefit and/or for the benefit of third parties.

11.2 Obligations of Cipriani Employees and/or Providers

• Report in writing to Cipriani any actual, potential, or perceived conflict of interest within the Company. Failure to report such situation may result in disciplinary measures, or contractual and/or legal consequences, as applicable.

• Refrain from participating in any decision-making process where a conflict of interest exists.

11.3 Conflict of Interest Reporting Procedure

For purposes of ensuring traceability and consistent handling of conflict-of-interest reports, each employee and/or service provider who identifies an actual, potential, or perceived conflict shall follow the procedure set forth below:

• Submit the report in writing using Form CMP-FOR-CDI-001 – Conflict of Interest Report, within five (5) business days of becoming aware of the situation.

• Submit the report to Cipriani’s Compliance Officer, with a copy to the Human Resources Department and the immediate hierarchical supervisor.

• Directors, managers, and employees of Cipriani’s sensitive areas — including Procurement, Commercial, Finance, Casino, Security, Human Resources, and Compliance — shall also sign an Annual Conflict of Interest Declaration, managed by Cipriani’s Compliance Officer.

• The information contained in the Annual Conflict of Interest Disclosure will be treated as confidential and will be filed in a restricted-access file, kept by the Compliance Officer, with access granted to the Human Resources Department, the General Manager, and corporate management.

• Cipriani’s Compliance Committee shall assess the Annual Conflict of Interest Declarations submitted and define any mitigation measures that may be necessary, such as abstention, reassignment of duties, monitoring, reinforcement of controls, or any other measures deemed appropriate.

• The institutional Whistleblowing Channel shall be reserved for reporting breaches or other conduct contrary to the Conflict of Interest Policy; it shall not replace the obligation to submit a conflict of interest report in the event that an actual, potential, or perceived conflict is identified.

12. Prevention of Money Laundering, Terrorist Financing and Proliferation Financing (AML/CFT/CPF)

Cipriani Punta del Este, through Cipriani Punta del Este S.A. as an obligated entity in matters of PLAFT/FPADM, undertakes to apply the highest standards for the prevention of money laundering, terrorism financing, and proliferation financing, in accordance with Uruguayan regulations — Law No. 19.574, Law No. 20.469, Decree No. 379/018, and SENACLAFT Resolution No. 61/2026 — as well as GAFI/GAFILAT standards.

The Company undertakes to apply Know Your Customer (KYC) policies, transactional monitoring, and the reporting of suspicious transactions to the UIAF–BCU. Cipriani’s employees and service providers are required to cooperate with due diligence measures.

13. Responsible Gaming

Cipriani promotes responsible gaming as a corporate value, applying policies on:

• Prevention of gambling addiction and protection of individuals in vulnerable situations.

• Voluntary self-exclusion available to clients upon request.

• Transparent information regarding gaming conditions.

• Prohibition of entry to the Casino by underage individuals.

• Specific personnel training for the early detection of problematic behaviors.

14. Personal Data Protection and Confidentiality

14.1 Personal Data Protection

Cipriani undertakes to protect the personal information of its employees and service providers in accordance with Law No. 18.331 and its complementary regulations, under the supervision of the URCDP.

The data controller responsible for the processing of the personal data of the Company’s employees and service providers is Cipriani Punta del Este S.A. The data provided shall be retained for the duration of the existing contractual relationship and until all legal obligations arising therefrom have been fulfilled.

Data subjects shall have the right to access their personal data, as well as to rectify, update, include, or delete the personal data concerning them that is contained in a database, upon verification of any error, inaccuracy, or omission in the information of which they are the data subject.

Likewise, data subjects may limit the processing of their personal data and revoke their consent at any time.

Under no circumstances will the Company collect or process data that could be considered “sensitive,” that is, personal data revealing racial or ethnic origin, political opinions, religious or moral beliefs, trade union membership, or information regarding health or sex life.

To exercise ARCO rights, please write to the following email address: privacidad@casinocipriani.com, or refer to the Personal Data Protection Policy.

14.2 Confidentiality

Confidential information (hereinafter, the “Information”) shall be understood to include all data or knowledge, whether in written, verbal, magnetic, or any other form, to which employees and service providers have access during the course of their relationship with Cipriani, and which is directly or indirectly connected to the Company’s activities and to its respective employees, clients, and guests.

In the event of any doubt as to whether certain data falls within the scope of the Information, employees and service providers shall treat it as such, unless the Company expressly confirms otherwise in writing.

Employees and service providers shall: a) maintain strict and absolute confidentiality regarding the Information; b) use the Information solely for the performance of their duties and in accordance with the purpose established for such Information; c) refrain from disclosing or transmitting the Information, directly or indirectly, in whole or in part, without the Company’s prior, express, and written consent; and d) immediately report to their superior any breach by another employee and/or service provider of the Company of any of the confidentiality obligations set forth herein.

This confidentiality obligation shall remain in force even after the termination of the relationship.

14.3 Use of Social Media and Digital Channels

The activities, comments, and posts made by employees and service providers on social media and other digital platforms, whether in a personal capacity or on behalf of the Company, shall at all times comply with the principles of good faith, respect, and responsibility that govern this Code, as well as with the provisions of Cipriani’s Internal Regulations.

In particular, employees and service providers shall:

Refrain from publishing, disclosing, or commenting on confidential, restricted, or proprietary information of the Company, its clients, suppliers, or related third parties, in compliance with the confidentiality obligation established in the preceding clause.

Avoid making comments, posts, or statements that may affect, damage, or undermine the reputation, image, brand, or good name of the Company, its employees, clients, or suppliers;

Respect the rights to honor, privacy, personal image, and other personal rights of third parties, refraining from making discriminatory, defamatory, offensive posts, or any posts that may in any way violate such rights;

Expressly clarify, where applicable, that the opinions expressed on social media or digital platforms are personal in nature and do not represent the official position of the Company, unless expressly authorized to act on its behalf; and

Comply with applicable regulations concerning personal data protection, intellectual property, and any other legal provisions applicable to the use of digital platforms.

15. Safe and Healthy Environment

Cipriani ensures occupational safety, hygiene, and health, in accordance with Law No. 5.032 and ILO Conventions 155 and 161.

The consumption of alcohol and any other type of drugs is strictly prohibited during working hours, at the workplace or in connection with work, during breaks, and at any time while on company duty. It is expressly permitted, however, for business and work-related purposes within the scope of one’s job duties. This applies in particular to management positions in the food and beverage sector and in the sales department for business purposes.

Entering the Company under the influence of such substances is prohibited, as is the possession, distribution, and/or sale of alcoholic beverages and other drugs on the Company’s premises and workplaces.

16. Reporting Channel

Cipriani Punta del Este has an institutional Whistleblowing Channel to confidentially report any breach of this Code.

16.1 Reporting Channel Principles

• Confidentiality of the whistleblower’s identity.

• Possibility of anonymous reporting.

• Protection against retaliation for anyone who reports in good faith.

• Impartial and independent management of each report.

• Respectful treatment of every person involved.

16.2 Access Methods

16.3 Communication of the Reporting Channel

For purposes of ensuring effective communication and broad awareness among employees and service providers, the Whistleblowing Channel shall be permanently disseminated through the following means:

• Internal notice boards located in common areas of the Casino, Hotel, Beach Club, and other operational units of the Company.

• Corporate intranet and institutional website.

• Institutional welcome email and periodic communications from Human Resources and Compliance.

• Induction sessions, periodic training, and informational materials provided to employees, service providers, and related third parties.

17. Consequences in Case of Non-Compliance

17.1 Employees

Failure by Cipriani employees to comply with the provisions contained in this Code may result in the application of the disciplinary measures set forth in the Company’s Internal Work Regulations, without prejudice to any civil and/or criminal actions that may apply.

The severity of the disciplinary measures to be applied shall depend on the seriousness and recurrence of the misconduct, as well as on the individual employee’s personnel record.

17.2 Providers and Contractors

Failure by suppliers and contractors to comply with the provisions contained in this Code may result in the application of contractual measures, including the suspension, review, and/or termination of the commercial relationship, without prejudice to any legal actions that may apply.

18. Communication, Receipt and Acceptance

18.1 Employees

This Code of Ethics shall be communicated to all Cipriani employees upon their joining the Company, as well as during periodic training sessions, and shall be disseminated through the corresponding internal channels: corporate intranet, institutional notice boards in common areas, institutional email, and informational materials provided during induction.

Each employee shall sign the separate document CEI-AX-I v.1.0 – Acknowledgment of Receipt, Awareness, and Commitment to Compliance, which shall be filed in their personnel record, either in paper format or by electronic signature in accordance with Law No. 18.600.

Additionally, Cipriani undertakes to provide periodic training on ethics, anti-corruption, harassment prevention, equality, data protection, PLAFT/FPADM, and the Whistleblowing Channel, in accordance with the Company’s Annual Training Plan.

18.2 Providers and Contractors

Suppliers and contractors engaged with Cipriani are required to comply with the provisions set forth in this Code, as established in the respective agreements entered into with Cipriani.

In this regard, suppliers and contractors are specifically required to, including but not limited to:

• Be aware of, accept, and comply with the ethical, anti-corruption, anti-bribery, PLAFT/FPADM, and personal data protection principles set forth in this Code.

• Extend such obligations to their personnel, subcontractors, and third parties involved in the performance of the agreement entered into with Cipriani.

• Report through the institutional Whistleblowing Channel any situation contrary to the provisions contained in this Code.

• Cooperate with any audits, investigations, and requests for information made by the Company within the framework of this Code.

Failure to comply with the provisions contained in this Code shall entitle the Company to suspend, review, and/or terminate the contractual relationship maintained with the supplier and/or contractor, without prejudice to any civil and/or criminal actions that may apply.

18.3 Publication

This Code shall be published on the Company’s institutional website, www.casinocipriani.com/etica, and disseminated through Cipriani’s official communication channels.

19. Governance and Review

• Approval: Board of Directors and, where applicable, the companies associated with the Cipriani Punta del Este project.

• Administration: Human Resources, corporate authorization, and coordination and implementation with the compliance officer.

• Review: Annual review, with the next ordinary review scheduled for July 2027, or extraordinary review in the event of regulatory changes or relevant events.

• Interpretation: The criterion that provides the greatest protection to human dignity and fundamental rights shall prevail, in line with Cipriani’s pillars of Culture, Authenticity, Simplicity, and Elegance.

20. Contact

• Corporate website: www.casinocipriani.com