Prevention of Discrimination, Sexual Harassment, and Workplace Harassment (3.1.3. DJSI)

 

Regulatory Framework for the Rejection of Discrimination, Sexual Harassment, and Workplace Harassment

Code of Ethics and Conduct (3.1.3 DJSI - Public policies against discrimination and harassment across the entire Group)

The Code of Ethics and Conduct is a compendium of rules that define the standards of behavior expected by the organization and guide the conduct of Ecopetrol S.A., the companies within the Group, and all recipients of the Code, under the ethical principle of Integrity and its drivers: commitment to life, respect, transparency, responsibility, and honesty.

This Code also contains a guide to behaviors, real-life situations, warning signs, and frequently asked questions to achieve a better understanding and internalization of the ethical principle of Integrity and its drivers.

The Code was developed taking into account the applicable regulatory framework, national and international standards, benchmarks from Oil & Gas companies worldwide, best practice guidelines, assessments of ethical and compliance issues, and the results of employee surveys. It was approved by the Board of Directors.

Code of Ethics and Conduct for Suppliers, Contractors, Subcontractors, and Business Partners (3.1.3. DJSI - Public policies against discrimination and harassment across the entire Group)

The Code of Ethics and Conduct for Suppliers, Contractors, Subcontractors, and Business Partners sets forth the mandatory ethical and conduct guidelines that define day-to-day conduct for all natural or legal persons identified as suppliers, contractors, subcontractors, and business partners, as well as the natural or legal persons that these groups engage under any modality for the execution of activities arising from contractual relationships with the Ecopetrol Group throughout the value chain.

This Code guides the conduct of stakeholders under the ethical principle of Integrity and its drivers: commitment to life, respect, transparency, responsibility, and honesty.

The Code makes explicit the expected behaviors regarding respect and rejects any form of discrimination. (3.1.3.1. DJSI - Zero-tolerance policy on discrimination)

1. Ecopetrol Group Code of Ethics and Conduct

Integrity: the starting point and its drivers

At the Ecopetrol Group, we have five drivers of integrity: commitment to life, respect, transparency, responsibility, and honesty. The integrity drivers, which are binding and enforceable, focus our path toward excellence. As recipients of this Code, it is our duty to uphold these drivers:

Respect, accepting and recognizing differences without belittling or discriminating based on gender identity, sexual orientation, ethnic affiliation, disability, nationality, origin, education level, sociocultural background, religion, worldview, or other characteristics inherent to our diversity.

Unwavering Against Discrimination, Ensuring a Gender and Diversity Approach

All processes and procedures of any kind carried out within the Ecopetrol Group must be characterized by non-discrimination and the rejection of any conduct that impedes, obstructs, or restricts the full exercise of people's rights due to their ethnic affiliation, nationality, gender identity, sexual orientation, disability, age, or any other characteristic of their diversity. Therefore, we are encouraged to seek inclusive language, avoiding terms that may be exclusionary, discriminatory, or violent, recognizing-within the equity framework-the particular differences and risks to which certain groups may be susceptible.

Through our procedures and practices, we promote a work environment that celebrates diversity in all its forms and encourages equitable participation in decision-making and equal opportunities for all individuals within this Group.

We Respect Human Rights (HR)

At the Ecopetrol Group, we actively acknowledge, respect, and promote Human Rights through the following actions:

• Compliance with applicable local and international standards related to fair labor practices and human rights, including prohibitions on forced and child labor.
• Voluntary endorsement of the United Nations Global Compact: an initiative that promotes the commitment of the private sector, public sector, and civil society to align their strategies and operations with ten universally accepted principles in four thematic areas (human rights, labor standards, the environment, and anti-corruption).
• Understanding and supporting the development of communities considered partners in the management, prevention, and-when necessary-mitigation and remediation of negative impacts generated by operations on people.

We share the conviction that business practices that ensure respect for Human Rights contribute to the creation of a more stable, equitable, and inclusive global market that fosters more prosperous and developed societies.

1. Code of Ethics and Conduct for Suppliers, Contractors, Subcontractors, and Business Partners

Integrity: the starting point and its drivers

At the Ecopetrol Group, we have five drivers of integrity: commitment to life, respect, transparency, responsibility, and honesty. The integrity drivers, which are binding and enforceable, focus our path toward excellence. As recipients of this Code, it is our duty to uphold these drivers:

Respect, accepting and recognizing differences without belittling or discriminating based on gender identity, sexual orientation, ethnic affiliation, disability, nationality, origin, education level, sociocultural background, religion, worldview, or other characteristics inherent to our diversity.

We firmly reject these behaviors that impact human rights, affecting the well-being, safety, dignity, and integrity of individuals.

Ecopetrol has a Guide for the Prevention and Response to Sexual Harassment and/or Discrimination in the Workplace, which addresses these situations comprehensively and provides protection, confidentiality, and tools that prevent re-victimization, while encompassing all measures to foster a safe environment for victims.

As recipients of this Code, we must have our own procedures to ensure the prevention and proper management of these situations. Under this framework, we are required to have a protocol for the care, management, and resolution of such situations, which must be part of our internal control and risk management system.

Unwavering Against Discrimination, Ensuring a Gender and Diversity Approach.

Recipients of this Code strive to develop processes and procedures characterized by non-discrimination and the rejection of any conduct that impedes, obstructs, or restricts the full exercise of people's rights due to their ethnic affiliation, nationality, gender identity, sexual orientation, disability, age, or any other characteristic of their diversity. Therefore, we seek inclusive language, avoiding terms that may be exclusionary, discriminatory, or violent, recognizing-within the equity framework-the particular differences and risks to which certain groups may be susceptible; furthermore, we eliminate barriers and promote inclusion in the workplace and in our engagement with stakeholders.

The Code of Ethics also highlights the rejection of any form of Sexual Harassment (3.1.3.1 DJSI - Explicit declaration prohibiting Sexual Harassment)

1. Ecopetrol Group Code of Ethics and Conduct

We Do Not Allow Workplace Harassment, Sexual Harassment, or Sexual Violence

Workplace harassment refers to persistent and demonstrable conduct exercised by an employer, a direct or indirect hierarchical superior, a coworker, or a subordinate, directed at instilling fear, intimidation, terror, and anxiety, causing workplace harm, generating demotivation at work, or inducing the resignation of the employee.

Sexual harassment is the behavior of a person-which may be verbal, gestural, physical contact, or insinuation-consisting of comments of a sexual nature, display of pornography, and verbal or physical sexual demands that affect the dignity of another person, where such acts are unwanted and offensive to the recipient.

Sexual violence occurs with any act of aggression or non-consensual sexual conduct that causes physical, emotional, psychological, or spiritual harm; for example, sexual abuse, unwanted physical contact, touching, physical approaches, physical sexual harassment, rape, or any other type of sexual coercion.

1.Code of Ethics and Conduct for Suppliers, Contractors, Subcontractors, and Business Partners

We Do Not Allow Workplace Harassment, Sexual Harassment, or Sexual Violence

Workplace harassment refers to persistent and demonstrable conduct exercised against a worker by an employer, a direct or indirect hierarchical superior, a coworker, or a subordinate, directed at instilling fear, intimidation, terror, and anxiety, causing workplace harm, generating demotivation at work, or inducing the resignation of the worker.

Sexual harassment is the behavior of any recipient of this Code, including personnel associated with any of them, which may be: verbal, gestural, physical contact, or insinuation, consisting of comments of a sexual nature, obscene language, display of pornography, sexist jokes and comments, and verbal or physical sexual demands that affect the dignity of another person, where such acts are unwanted and offensive to the recipient.

Sexual violence occurs with any act of aggression or non-consensual sexual conduct that causes physical, emotional, psychological, or spiritual harm; for example, sexual abuse, unwanted physical contact, touching, physical approaches, physical sexual harassment, rape, or any other type of sexual coercion.

2.Human Rights and Diversity, Equity, and Inclusion Policies:

Ecopetrol promotes Responsible Business Conduct throughout its operations, aligned with the highest national and international standards on Human Rights (HR) and Business. Therefore, the Company emphasizes the prevention of risks and impacts on rights-holders (people and the environment), in accordance with its due diligence process. Accordingly, Ecopetrol's management complies with the nine (9) principles for HR management set forth in the Guide on Human Rights and Business (2025): due diligence, redress, mainstreaming, complementarity, collaborative work, differential approach, territorial approach, and continuous improvement and application of the highest standard.

Diversity and Inclusion Policy

Human Rights Guide

 

3.Law 1010 of 2006 on Workplace Harassment and the Labor Coexistence Committee Guide (3.1.3.1 DJSI - Explicit declaration prohibiting workplace harassment - Non-sexual harassment)

Through Law 1010 of 2006, the Colombian State seeks to protect labor relations from situations that assault human dignity, with a scope of action both within and outside the company. Our function as an organization, pursuant to current regulations, includes informing, preventing, and correcting any form of conduct that may constitute any of the forms of workplace harassment established by law. At Ecopetrol S.A., in compliance with the provisions of the regulation, we have the Labor Coexistence Committee, which promotes a healthy work environment within the organization and addresses any conflicts that may arise in the context of labor relations; it seeks conflict resolution through the establishment of agreements in favor of those involved. If agreements are not reached, cases are referred to other bodies responsible for verifying the reported situations and imposing any applicable sanctions, such as the Office of the Attorney General of the Nation in the case of Ecopetrol S.A. employees.

The Ecopetrol S.A. Labor Coexistence Committee promotes Respect, Impartiality, Tolerance, Serenity, Openness to Dialogue, and Conciliation aimed at improving Labor Coexistence in an environment of complete Confidentiality. In this regard, improvement plans are developed and agreed upon by those involved, with follow-up and case closure, with the objective of building human relationships grounded in mutual well-being.

The organization rejects any form of workplace harassment, developed in accordance with the regulatory framework of the country of operation. For the Colombian context, pursuant to Law 1010 of 2006, the following forms of workplace harassment are contemplated:

Workplace mistreatment: Any act of violence against the physical or moral integrity, physical or sexual freedom, or property of a person serving as an employee or worker. This group includes physical, verbal, or moral mistreatment.

Verbal mistreatment: Any injurious or abusive verbal expression that harms the moral integrity or the rights to privacy and good reputation of those participating in a labor relationship, or any behavior aimed at undermining the self-esteem and dignity of those participating in a labor relationship.

Workplace persecution: Any conduct whose characteristics of evident arbitrariness seek to induce the resignation of the employee or worker, through disqualification, excessive workload, and permanent changes in schedule that may cause workplace demotivation.

Workplace discrimination: Any differential treatment based on race, gender, age, family or national origin, religious creed, political preference, or social status that lacks any reasonable justification from a labor standpoint.

Workplace obstruction: Any action intended to hinder the performance of work or to make it more burdensome or delayed, to the detriment of the worker or employee.

Workplace inequity: Refers to the assignment of duties to the detriment of the worker.

Workplace lack of protection: Any conduct intended to endanger the integrity and safety of the worker through orders or the assignment of duties without meeting the minimum protection and safety requirements for the worker.

Preventive Management Measures and Response to Discrimination and Sexual Harassment

Prevention

Training for All Personnel on Discrimination and Harassment in the Workplace and Other Stakeholder Groups (SHGs) (3.1.3.2 DJSI - Training for all personnel on discrimination and harassment in the workplace)

Ecopetrol conducts annual training sessions on the prevention of discrimination, sexual harassment, workplace harassment, and the prevention of gender-based violence, among other topics that reinforce the prevention of discrimination and harassment in the workplace.

2.Available Reporting Channels and Comprehensive Response Protocols (3.1.3.2 DJSI - Defined escalation process for reporting incidents)

Please note that it is essential that, if you are aware of or suspect a situation involving a person associated with Ecopetrol or any recipient of the Ecopetrol Group Code of Ethics and Conduct that leads to non-compliance with the conduct set forth in the Code of Ethics, it is a duty to report the incident through the designated channels.

Available channels for reporting discrimination or sexual harassment:

Ethics Line: http://lineaetica.ecopetrol.com.co

• International Line (Toll-Free International Prefix): 018009121013
• National Line in Bogotá: 3103158600 Extension 43900
• Ethics and Compliance Office: 3103158600 Extension 59052 - Office hours: Tuesdays and Fridays, 8:00 a.m. to 12:00 p.m.

All complaints received are analyzed in accordance with the Procedure for the Management of Ethical Matters (VEIP-001), based on the Ecopetrol Group Code of Ethics and Conduct, the Code of Ethics and Conduct for Suppliers, Contractors, Subcontractors, and Business Partners, and other applicable regulations, as applicable. This channel is corporate and operated by an independent international company, ensuring full transparency in the process.

This system guarantees:

• vailability throughout the year, 24 hours a day, 7 days a week

ii) Reports in Spanish and English

• Option to file anonymous complaints
• Confidentiality of information, in accordance with applicable international regulations

Please note that it is essential that, if you are aware of or suspect a situation involving a person associated with Ecopetrol or any recipient of the Ecopetrol Group Code of Ethics and Conduct or the Code of Ethics and Conduct for Suppliers, Contractors, Subcontractors, and Business Partners (described above) that leads to non-compliance with the conduct set forth in the Code of Ethics, it is a duty to report the incident through the designated channels.

Learn about the Guide for the Prevention and Response to Sexual Harassment and Discrimination in the Workplace

Learn about the Gender-Based Violence Prevention Toolkit

Available channels for reporting workplace harassment situations:

To contact the Labor Coexistence Committee, the case must be submitted-along with the respective evidence-to the email address comitedeconvivencia@ecopetrol.com.co, which is the sole channel for handling workplace harassment complaints, where the grounds for the grievance must be stated and supporting evidence provided.

Learn about the Complaint and Comprehensive Response Protocol for Workplace Harassment Situations (link)

1. Awareness of Reporting Channels

Measurement results on individuals' level of awareness of:

1.Case Reporting and Corrective Measures in Cases of Discrimination or Harassment (3.1.3.4 DJSI - Number of incidents of discrimination and harassment reviewed and corrective or disciplinary measures taken in the event of discriminatory behavior or harassment)

1The figures shown in this cell reflect the initial category assigned based on the information initially provided in the report. Reports received in 2024 and those under investigation as of January 1, 2024 are included.

2The figures shown in this cell reflect the initial category assigned based on the information initially provided in the report. Reports received in 2024 and those under investigation as of January 1, 2024 are included.

See COMPLIANCE PROGRAM FOR ECOPETROL AND ITS CORPORATE GROUP

Action

• Rejection, Prevention, and Sanctioning Measures (3.1.3.2. DJSI - Corrective or disciplinary measures taken in the event of discriminatory behavior or harassment)

Discrimination and sexual harassment:

The organization conducts ongoing monitoring of facts or circumstances that may constitute cases of sexual violence/harassment or discrimination. In accordance with the principles of transparency and Diversity, Equity, and Inclusion standards, reports are generated that provide information on the cases studied and managed, as well as, in aggregate form, the disciplinary measures imposed in applicable cases.

Sanctions are imposed in proportion to the severity of the incident and based on the protection of the victim, regardless of the position held by the party involved. These measures may range from a formal warning to termination, understood as the termination of the employment contract with Ecopetrol S.A., in addition to the disciplinary or legal proceedings described below:

• The Internal Work Regulations, which contain the internal disciplinary regime
• Employment Contracts, through which employees commit to acting transparently and to not violating the applicable Code of Ethics and Conduct.
• Variable Compensation Granting Procedure, which sets forth the grounds for non-payment of this benefit when ethical guidelines of the company are violated or internal control failures have occurred.
• Background checks and integrity testing for all employees of the organization.
• Onboarding for new employees on ethical topics, training, and communications.

Employee performance evaluation system that includes, in addition to work objectives, organizational competencies: passion for excellence, commitment to life, creativity - responsibility, collaboration-communication, and integrity.

Ecopetrol employees are invited to sign the commitment to integrity.

Workplace harassment:

Once the complaint is filed, the committee evaluates it and decides whether or not to admit the case. In either assessment, the result will be communicated to the complainant. If the complaint is admitted, a review will be conducted to determine the veracity of the case; in accordance with current regulations, individual and group meetings are held with the parties involved to facilitate an agreement between the parties.

If an agreement between the parties involved cannot be reached, the Committee must refer the case to the Office of the Attorney General of the Nation, the competent authority to conduct the corresponding investigation for alleged workplace harassment and, if conduct constituting harassment is substantiated, to impose the applicable legal sanctions on the offender, pursuant to the provisions of Law 1010 of 2006.

Comprehensive Management for the Prevention and Promotion of Ethical Conduct, Human Rights, and Diversity, Equity, and Inclusion

Compliance Program System

The Compliance Program System establishes comprehensive guidelines for risk management, internal control, and compliance (fraud, corruption, bribery, money laundering, terrorist financing, financing of the proliferation of weapons of mass destruction, violations of anti-bribery regulations such as the FCPA, protection of free competition), promoting comprehensive ethical behavior within the organization in accordance with internal regulations, legal provisions, and adopted best practices, as well as the control environment necessary to identify potential deviations.

Its main objectives are to continue consolidating ethics and compliance within the organization, under the value of integrity and its ethical drivers (responsibility, respect, transparency, care for life, and honesty), and to promote the correct execution of processes through the identification of risks and the definition of controls and/or mitigants that prevent their materialization, as well as to ensure compliance with legal and voluntary obligations related to ethical and compliance matters.

Learn more about the Compliance Program: https://www.ecopetrol.com.co/wps/portal/Home/sostecnibilidad/gobernanza/eticatransparencia/ProgramaCumplimiento

Human Rights Program:

Ecopetrol's management is framed within the four principles established in the Human Rights guidelines: Due diligence, mainstreaming, complementarity, and collaborative work.

Based on this understanding, the Human Rights Action Plan is developed, which sets forth the actions to be undertaken under a Plan-Do-Check-Act (PDCA) approach to ensure management in line with the standards in this area. As a result of the periodic human rights risk analyses conducted, an exercise was carried out to identify outstanding issues-issues that the Company must address for the prevention and mitigation of human rights risks and impacts. This Plan includes:

• Equality and non-discrimination
• Equal opportunity for access to employment

Learn more about the Human Rights Program

Human Richness Policy

Ecopetrol's Human Richness Policy (diversity, equity, inclusion, and belonging) contributes to preventing any form of discrimination and harassment by developing a holistic approach to integrating DEI into our strategy and sustainability processes, as well as into all 7 of our stakeholder groups, particularly employees, the community, and suppliers.

Our strategy consists of 6 perspectives, which include: 1. Gender, 2. Disability, 3. Reconciliation: Victims of Internal Conflict, Veterans, and Former Combatants, 4. Ethnic, 5. Generations; 6. Sociocultural Groups.

Learn more about the Human Richeness Policy

Coexistence Committee Management for the Prevention of Workplace Harassment

The Ecopetrol S.A. Labor Coexistence Committee promotes respect, impartiality, tolerance, serenity, open dialogue, and conciliation aimed at improving labor coexistence in an environment of absolute confidentiality. Under this framework, cases are analyzed, monitored, and closed through consensus with improvement plans, with the objective of establishing relationships based on mutual well-being.

Coexistence Committee Management Report

In 2025, the Ecopetrol S.A. Labor Coexistence Committee managed a total of 26 complaints, of which: 14 are in the process of analysis and listening to the parties, 2 complaints are under agreement monitoring or agreement establishment, 2 cases were referred to the Office of the Attorney General of the Nation, and 10 cases were closed.

Of the total number of cases brought before the Ecopetrol S.A. Labor Coexistence Committee, none has been legally structured as workplace harassment under the terms of Law 1010 of 2006, nor has it been learned that this has occurred in cases that have been referred to the Office of the Attorney General of the Nation, the oversight authority competent to adopt the applicable disciplinary sanctions for the disciplinary offense of workplace harassment.

Below is the General Summary of Complaints Submitted to the Labor Coexistence Committee:

Below is the Summary of Cases Managed from 2015-2025 and the management details:

It is also important to note that, in response to the entry into force of Resolution 3461 of 2025 of the Ministry of Labor, which repealed Resolutions 652 and 1356 of 2012 to establish updated guidelines for the composition,operation, and responsibilities of the Labor Coexistence Committee-in line with ILO Convention 190 and Law 2466-Ecopetrol is implementing the adjustments required by said regulation. This includes:

Reconfiguration of the Committee in accordance with the size and number of work centers.

Update of confidentiality regulations and protocols for information management and defined timelines for the preventive and conciliatory handling of complaints.

Guarantee of technical, financial, and logistical resources for its operation.

Ongoing training in conflict resolution, assertive communication, gender perspective, and psychological first aid.

Strengthening of report management, monitoring of commitments, and presentation of reports to senior management.