CODE OF BUSINESS CONDUCT AND ETHICS

FOR
CINEMARK HOLDINGS, INC.
 TABLE OF CONTENTS

Page

Forward ...................................................................................................................................... iii

Introduction ................................................................................................................................ iv
Special Notice for Senior Financial Personnel ..................................................................v
1. Compliance with Laws, Rules and Regulations ................................................................1
2. Conflicts of Interest............................................................................................................1
3. Insider Trading ...................................................................................................................2
4. Corporate Opportunities.....................................................................................................3
5. Antitrust Laws ....................................................................................................................4
6. Discrimination and Harassment .........................................................................................4
7. Health and Safety ...............................................................................................................4
8. Record Retention ...............................................................................................................5
9. Accounting Policies ...........................................................................................................5
10. Confidentiality ...................................................................................................................6
11. Protection and Proper Use of Company Assets .................................................................6
12. Payments to Government Personnel ..................................................................................7
13. Purchasing Philosophy .......................................................................................................7
14. Bartering Cinemark Passes ................................................................................................7
15. Waivers of the Code of Business Conduct and Ethics .......................................................8
16. Reporting any Illegal or Unethical Behavior .....................................................................8
17. Compliance Procedures .....................................................................................................8

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Note: This Code and related policies are current as of February 14, 2018. In adopting and
publishing these guidelines, you should note that (1) in some respects our policies may exceed
minimum legal requirements or industry practice, (2) nothing contained in this Code should be
construed as a binding definition or interpretation of a legal requirement or industry practice, and
(3) any action by our employees or agents in violation of the law or this Code is beyond the scope
of such person’s authority or duty and is not an act by us or on our behalf.

To obtain copies of this Code, you may contact the Human Resources Department or access it
from the web at http://www.cinemark.com.

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FORWARD

To all employees:

Our company is founded on our commitment to the highest ethical principles and standards. We
value honesty and integrity above all else. Upholding these commitments is essential to our
continued success.

The law and the ethical principles and standards that comprise this Code must guide our actions.
The Code is, of course, broadly stated. Its guidelines are not intended to be a complete listing of
detailed instructions for every conceivable situation. Instead, it is intended to help you develop a
working knowledge of the laws and regulations that affect your job.

Adhering to this Code is essential. I have personally taken the time to study it carefully and I
encourage you to do the same. I have also signed a statement confirming that I have read this
Code carefully, and I expect you to do the same by signing the confirmation form that appears on
the final page.

Ultimately, our most valuable asset is our reputation. Complying with the principles and standards
contained in this Code is the starting point for protecting and enhancing that reputation.

Thank you for your commitment!

/s/ Mark Zoradi

Mark Zoradi, Chief Executive Officer

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INTRODUCTION

All of our employees, officers and directors must read and use this Code to ensure that each
business decision follows our commitment to the highest ethical standards and the law. Several
provisions in this Code refer to more detailed policies that either (1) concern more complex
company policies or legal provisions or (2) apply to select groups of individuals within our
company. If these detailed policies are applicable to you, it is important that you read, understand,
and be able to comply with them. If you have questions as to whether any detailed policies apply
to you, contact your supervisor or our compliance officer. Adherence to this Code and to our other
official policies is essential to maintaining and furthering our reputation for fair and ethical
practices among our customers, shareholders, communities and employees.

Situations that involve ethics, values and violations of certain laws are often very complex.
No single code of conduct can cover every business situation that you will encounter.
Consequently, we have implemented the compliance procedures outlined in this Code. The thrust
of our procedures is when in doubt, ask. If you do not understand a provision of this Code, or are
confused as to what actions you should take in a given situation, you should follow the compliance
procedures outlined in this Code. Those procedures will generally direct you to talk to either your
immediate supervisor or the Head of the Human Resources Department. Most situations can be
resolved if you discuss them with your supervisor or the Head of the Human Resources
Department in an open and honest manner.

After reading this Code, you should:

● Have a thorough knowledge of the Code’s terms and provisions.

● Be able to recognize situations that present legal or ethical dilemmas.

● Be able to deal effectively with questionable situations in conformity with this Code.

In order to be able to accomplish these goals, we recommend that you take the following
steps:

● Read the entire Code thoroughly.

● Think about how the provisions of this Code apply to your job, and consider how you
might handle situations to avoid illegal, improper or unethical actions.

● If you have questions, ask your supervisor or the Head of the Human Resources
Department

When you are faced with a situation and you are not clear as to what action you should
take, ask yourself the following questions:

 Is the action legal?

 Does the action comply with this Code?

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  How will your decision affect others, including our customers, shareholders,
employees and the community?

 How will your decision look to others? If your action is legal but can result in the
appearance of wrongdoing, take alternative steps.

 How would you feel if your decision was made public? Could the decision be honestly
explained and defended?

 Have you contacted your supervisor or the Head of the Human Resources
Department regarding the action?

To reiterate, when in doubt, ask.

Please note that this Code is not an employment contract and does not modify the
employment relationship between Cinemark and you. We do not create any contractual rights by
issuing these policies, and we reserve the right to amend, alter and terminate policies at any time
as circumstances warrant.

Special Notice for Senior Financial Personnel

Our senior financial personnel, including our chief financial officer, controllers and
financial analysts, hold a special relationship of trust as stewards of our financial statements. Like
all of our other employees, our senior financial personnel are expected to familiarize themselves
with all sections of this Code. Nevertheless, they should pay particular attention to the sections of
this Code titled “Conflicts of Interests,” “Compliance with Laws, Rules and Regulations,” “Record
Retention” and “Accounting Policies,” as well as any more detailed policies concerning those
matters.

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 February 14, 2018

CODE OF BUSINESS CONDUCT AND ETHICS

CINEMARK HOLDINGS, INC.

INTRODUCTION

This Code of Business Conduct and Ethics (the “Code”), covers a wide range of business
practices and procedures. It does not cover every issue that may arise, but it sets out basic principles
to guide all employees of Cinemark Holdings, Inc. and its subsidiaries (the “Company” or
“Cinemark”). All of our employees must conduct themselves accordingly and seek to avoid even
the appearance of improper behavior.

If a law conflicts with a policy in this Code, you must comply with the law; however, if a
local custom, business practice or policy conflicts with this Code, you must comply with the Code.
If you have any questions about these conflicts, you should ask your supervisor how to handle the
situation.

Those who violate the standards in this Code will be subject to disciplinary action up to,
and including, termination of employment. If you are in a situation which you believe may violate
or lead to a violation of this Code, follow the guidelines described in Section 17 of this Code.

1. Compliance with Laws, Rules and Regulations

We strive to comply with all laws and governmental regulations applicable to us. All
employees must respect and obey the laws of the cities, states and countries in which we operate.
Although not all employees are expected to know the details of these laws, it is important to know
enough to determine when to seek advice from supervisors, managers or other appropriate
personnel or sources.

2. Conflicts of Interest

Employees should avoid any situation that may involve a conflict between their personal
interests and our interests. Examples of possible conflicts of interest are when an employee or a
member of his or her family has a financial or other interest in, or seeks personal loans or services
from, a company that does business with us. In general, conflicts of interest may arise when an
employee has interests that may make it difficult to perform his or her work for us objectively and
effectively. In dealing with current or potential customers, film distributors, suppliers, contractors
and competitors, employees should act in our best interests to the exclusion of personal advantage.
Employees are expected to make prompt and full disclosure of any possible conflicts of interest in
writing to the Head of the Human Resources Department or consult the procedures described in
Section 17 of this Code. This provision does not apply to situations where an employee has loans,
brokerage or investment accounts with banks or investment companies with whom the Company
does business.

Employees should avoid the receipt of gifts, gratuities, favors or other benefits that might
affect or appear to affect the exercise of their judgment on our behalf. Any substantial gift or favor

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offered by an actual or potential client, contractor, or provider of goods or services, lender, security
holder, or other affiliate, whether it be in tangible form or in the form of a service or individual
benefit, should be refused unless acceptance of such gift or favor has been approved per the
following guidelines:

a. Gifts or favors greater than $75 but $200 or less must be approved by the
department head; and

b. Gifts or favors greater than $200 must be approved by the President, Chief
Operating Officer or the Head of the Human Resources Department.

. The prohibition in this Section 2 is not intended to apply to ordinary courtesies of business
life, such as token gifts of insubstantial value (is $75 or below) modest entertainment incidental to
a business relationship, or the giving or receipt of normal hospitality of a social nature, provided
acceptance of such gifts do not conflict with the Company’s interests.

 Any actual or perceived violation of this Code of Ethics must be immediately reported
as provided in Section 17 of this Code of Ethics. Upon evaluation of the reported
violation and a determination that the reported act does, in fact, constitute a violation
of this Code of Ethics, the Company’s board of directors shall determine the
appropriate measures to be taken which may include, but are not limited to, further
investigation of the matter, consultation with outside counsel and disciplinary measures
up to and including dismissal.

3. Insider Trading

Employees who have access to confidential information about the Company are not
permitted to use or share that information for securities trading purposes or for any other purpose
except the conduct of our business. All non-public information about the Company and
information which an investor would likely consider to be important in making a decision whether
to buy, sell or hold our stock or other securities should be considered confidential information.
Buying or selling our stock or other publicly-traded securities when you are in possession of
confidential information is prohibited. You are also prohibited from disclosing such information
to anyone else (including friends or family members) in order to enable them to trade on the
information. In addition, if you acquire confidential information about another company due to
your relationship with us or due to your relationship with someone who has confidential
information regarding that other company, you may not buy or sell that other company’s stock or
other securities until such information is publicly disclosed. Using non-public information for
personal financial benefit or to “tip” others who might make an investment decision on the basis
of this information is not only unethical but also illegal. If you have any questions, please consult
our General Counsel.

The following are general guidelines to help you comply with our insider trading policy:

 Do not share material inside information with people within our company whose jobs
do not require them to have the information.

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  Do not disclose any non-public information, material or otherwise, concerning our
company to anyone outside the Company.

 If you have material inside information regarding us or regarding any other publicly
traded company that you obtained from your employment with us, you must not buy or
sell, or advise anyone else to buy or sell, our securities or that other company’s
securities, until such information is publicly disclosed.

Penalties for trading on or communicating material inside information are severe. If you
are found guilty of an insider trading violation, you can be subject to civil and even criminal
liability. In addition to being illegal, we believe that insider trading is unethical and will be dealt
with firmly, which may include terminating your employment with us and reporting violations to
appropriate authorities.

For more information about our policies concerning the securities laws, you should refer
to our more detailed Policy Prohibiting Insider Trading and Unauthorized Disclosure of
Information to Others. Our directors, executive officers and certain other designated employees
are also subject to a Supplemental Policy Concerning Insider Trading. These policies are available
from our compliance officer. If you have any questions concerning the securities laws or about
our policies with regard to those laws, or regarding the correct ethical and legal action to take in a
situation involving material inside information, please contact your immediate supervisor or our
compliance officer.

4. Corporate Opportunities

Employees, officers and directors are prohibited from taking advantage of opportunities
that are discovered through the use of corporate property, information or position without the
consent of the Board of Directors. No employee may use corporate property, information, or
position for your own personal gain. Employees, officers and directors owe a duty to the Company
to advance its legitimate interests when the opportunity to do so arises.

Sometimes our employees desire to take additional part-time jobs or do other work after
hours, such as consulting or other fee-earning services. This kind of work does not in and of itself
violate our Code. However, the second job must be strictly separated from your job with us, and
must not interfere with your ability to devote the time and effort needed to fulfill your duties to us
as our employee. You cannot engage in any outside activity that causes competition with us or
provides assistance to our competitors or other parties (such as suppliers) with whom we regularly
do business. You should avoid outside activities that embarrass or discredit us or that affect your
impartiality, objectivity and efficiency in performing your duties for us. Outside work may never
be done on company time and must not involve the use of our supplies or equipment. Additionally,
you should not attempt to sell services or products from your second job to us.

Before engaging in an outside occupation, you should disclose your plans to your
supervisor to confirm that the proposed activity is not contrary to our best interests. You may also
contact our Human Resources Department for more information.

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5. Antitrust Laws

We and our subsidiaries do business globally in a very highly competitive industry. Our
activities are subject to the antitrust and competition laws of the United States and the various
states and countries in which we do business. In general, those laws prohibit agreements or actions
that may restrain trade or reduce competition. Examples of possible violations of these laws
include agreements with competitors to fix or control prices, to boycott specified suppliers or to
allocate products, territories or markets. Special care should be taken to ensure that any contact
with representatives of our competitors, film distributors, suppliers and others with whom we do
business will not be, or not be viewed as, a violation of any antitrust law.

You should also avoid making inaccurate or misleading statements about competitors,
suppliers, customers or their offerings. Antitrust laws may also apply in other circumstances, like
trade association meetings or strategic alliances involving competitors. Foreign countries often
have their own body of antitrust laws, so international operations may be subject to antitrust laws
of either the United States or foreign countries.

Unlawful agreements need not be written or even consist of express commitments.

Agreements can be based on informal discussions or the mere exchange of information with a
competitor. If you believe that a conversation with a competitor enters an inappropriate area, end
the conversation at once. Whenever any question arises as to the significance or application of
antitrust laws, you should consult with our General Counsel, and any agreements with possible
antitrust implications should be made only with the prior approval of our General Counsel.

6. Discrimination and Harassment

The diversity of the Company’s employees is a tremendous asset. Our Company is

committed to equal opportunity for all team members and applicants without regard to race, color,
religion, gender, sexual orientation, gender identity, age, national origin, ancestry, pregnancy,
marital status, disability, veteran status or any other characteristic protected by federal, state or
local laws. We are committed to providing a workplace free from all forms of discrimination,
including sexual and other forms of workplace harassment. We respect the right of individuals to
achieve professional and personal balance in their lives. We will not tolerate any illegal
discrimination or harassment of any kind. Examples include, but are not limited to, derogatory
comments based on racial or ethnic characteristics and unwelcome sexual advances.

7. Health and Safety

The Company strives to provide each employee with a safe and healthy work environment.
Each employee has responsibility for maintaining a safe and healthy workplace for all employees
by following safety and health rules and practices and reporting accidents, injuries and unsafe
equipment, practices or conditions.

Violence and threatening behavior are not permitted. Employees should report to work in
condition to perform their duties, free from the influence of illegal drugs or alcohol. The use of
illegal drugs or alcohol in the workplace will not be tolerated.

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8. Record Retention

All information you record or report on our behalf, whether for our purposes or for third
parties, must be done accurately and honestly. All of our records (including accounts and financial
statements) must be maintained in reasonable detail, must be kept in a timely fashion and must
appropriately reflect our transactions. All employees are expected to timely disclose all necessary
information to ensure that all transactions are recorded properly so that our books and records are
complete and accurate. Recording data in a timely and truthful manner protects our company
resources and meets the expectations of those people, including investors and customers, who rely
on the accuracy of our books and records to perform their jobs. Falsifying records or keeping
unrecorded funds and assets is a severe offense and will result in disciplinary action which may
include prosecution or loss of employment.

We will retain all books, records and statements in accordance with our record retention
policies and all applicable laws and regulations. From time to time we are involved in legal
proceedings that may require us to make some of our records available to third parties. Our
General Counsel and retained outside legal counsel will assist us in releasing appropriate
information to third parties and provide you (or your supervisor) with specific instructions. It is a
crime to alter, destroy, modify or conceal documentation or other objects that are relevant to
litigation or a government investigation. In the event of litigation or governmental investigation,
consult with our General Counsel prior to releasing any information. The law applies equally to
all of our records, including not only formal reports but all less formal data such as email, expense
reports and internal memos. If you are informed that information in your possession is the subject
of litigation or a governmental investigation, or if you have other reason to believe that such
information may be involved in a judicial proceeding or governmental investigation, no matter
whether you think it is relevant or not, you are prohibited from making any effort to alter, destroy,
modify or conceal that information. Your supervisor and our General Counsel will be able to help
you if you have any questions. For further information, you should also refer to our Document
Retention Policy. You may request a copy of the Document Retention Policy from our Legal
Department.

9. Accounting Policies

Consistent with our general record retention policy of maintaining records in reasonable
and appropriate detail, we must maintain accounting records of the highest possible quality. We
expect that you will record all financial transactions (such as sales, leases or purchases) truthfully,
accurately and in sufficient detail so that our accounting records are reliable and fairly reflect the
nature of the transactions. The information derived from these records is provided to our
shareholders and investors as well as government agencies. Thus, our accounting records must
follow generally accepted accounting principles and other laws and regulations such as those of
the Internal Revenue Service and the Securities and Exchange Commission.

All revenues, expenses, assets and liabilities must be entered into our books and records in
an accurate and timely fashion. You may not maintain any unrecorded or secret fund, asset or
account for any purpose. No false, fictitious or misleading entries may be made in our books,
records or accounts for any reason. You may not make any payment or transfer of funds or assets
with the intent that any portion is to be used for any purpose other than that described in the

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documents supporting the payment or transfer. No invoices believed to be false or fictitious may
be paid. All accounting personnel, financial officers and executive officers should follow
generally accepted accounting principles and administer company books and accounts in
accordance with our other established accounting policies and internal controls. The reports we
file with the Securities and Exchange Commission and other government agencies should contain
information that is full, fair, accurate, timely and understandable in light of the circumstances
surrounding disclosure.

Our internal and external auditing functions are integral components that help ensure that
our financial books, records and accounts are accurate. Therefore, you should provide our
accounting department, internal auditing staff, audit committee and independent public
accountants with all pertinent information that they may request. We encourage open lines of
communication with our audit committee, accountants and auditors and require that all our
personnel cooperate with them to the maximum extent possible. It is unlawful for you to
fraudulently induce, coerce or mislead our public accountants for the purpose of making our
financial statements misleading.

If you are unsure about the accounting treatment of a transaction or believe that a
transaction has been improperly recorded or you otherwise have a concern regarding a
questionable accounting practice or audit matter, you should confer with your supervisor, the
corporate controller or our chief financial officer, or you may submit your concern, on an
anonymous basis, to our General Counsel or the audit committee of our board of directors.

10. Confidentiality

Employees must maintain the confidentiality of confidential information entrusted to them

by the Company or its customers, except when disclosure is authorized by the Legal Department
or required by laws or regulations. Confidential information includes all non-public information
that might be of use to competitors, or harmful to the Company, its employees or its customers, if
disclosed. It also includes information that suppliers and customers have entrusted to us. The
obligation to preserve confidential information continues even after employment ends.

11. Protection and Proper Use of Company Assets

All employees should endeavor to protect the Company’s assets and ensure their efficient
use. Theft, carelessness, and waste have a direct impact on the Company’s profitability. Any
suspected incident of fraud or theft should be immediately reported for investigation. Company
equipment should not be used for non-Company business, unless approved by the President, the
Chief Operating Officer or the Head of the Human Resources Department. However, incidental
personal use of telephones, fax machines, copy machines, computers, email and similar equipment
is generally allowed if there is no significant added cost to the Company, it does not interfere with
your work responsibility and is not related to an illegal activity or outside business. Our assets
may never be used for any unlawful purpose.

The obligation of employees to protect the Company’s assets includes its proprietary
information. Proprietary information includes intellectual property such as trade secrets, patents,
trademarks, and copyrights, as well as business, marketing and service plans, designs, databases,

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records, salary information and any unpublished financial data and reports. Unauthorized use or
distribution of this information would violate Company policy. It could also be illegal and result
in civil or even criminal penalties.

12. Payments to Government Personnel

The U.S. Foreign Corrupt Practices Act prohibits giving anything of value, directly or
indirectly, to officials of foreign governments or foreign political candidates in order to obtain or
retain business. It is strictly prohibited to make illegal payments to government officials of any
country.

In addition, the U.S. government has a number of laws and regulations regarding business
gratuities which may be accepted by U.S. government personnel. The promise, offer or delivery
to an official or employee of the U.S. government of a gift, favor or other gratuity in violation of
these rules would not only violate Company policy but could also be a criminal offense. State and
local governments, as well as foreign governments, may have similar rules. Our General Counsel
can provide guidance to you in this area.

13. Purchasing Philosophy

It is a good business practice to have more than one person involved in vendor relationships
and when making a purchase or soliciting proposals for professional services. Accordingly, the
Company’s Purchasing department will assist in reviewing any material business relationships.
The role of the Purchasing department is to lend negotiating support and expertise and to minimize
the potential for conflict of interest situations. Cinemark team members must actively work to
ensure that any vendor he or she is primarily responsible for also has relationships and contacts
outside of the primary contact’s department. No negotiations or “requests for services” should be
conducted in an exclusive manner.

Any major order, purchasing or leasing contract or agreement (one time or commitment to
expenditures of greater than $25,000) must be reviewed by the Executive Vice President-
Purchasing and the Chief Operating Officer, or the Chief Financial Officer. Expenditures, or
commitment to expenditures of greater than $1,000 and less than $25,000 must be reviewed by the
Executive Vice President-Purchasing.

Any questions regarding purchasing practices should be directed to Executive Vice

President-Purchasing.

14. Bartering Cinemark Passes

Certain Company suppliers may request Cinemark complimentary passes in exchange for
goods or services. All such “trades” must be approved in accordance with the Company’s
Employee Movie Card and Guest Pass Policy. It is expressly forbidden to barter passes or
concession items or any other Company asset for personal favors or services without required
approval.

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15. Waivers of the Code of Business Conduct and Ethics

Because our commitment to this Code is so strong, we will only grant waivers of it under
the most unusual or compelling circumstances. Therefore, we expect that waivers will be granted
very infrequently. If you would like to request a waiver of this Code for any reason, you must
submit a detailed written statement to Head of the Human Resources Department describing the
nature of your request and explaining why you believe the waiver is appropriate. The Head of the
Human Resources Department may deny a request for a waiver, but cannot approve one; only the
independent non-employee members of our board of directors may approve a request for waiver.
The Head of the Human Resources Department will forward appropriate waiver requests to the
independent members of our board of directors for consideration, and they will have the ultimate
authority to decide whether to grant the waiver. We will publicly disclose all waivers of this Code
as required by law or other applicable regulations.

16. Reporting any Illegal or Unethical Behavior

Employees are encouraged to talk to supervisors, managers or other appropriate personnel

about observed illegal or unethical behavior and when in doubt about the best course of action in
a particular situation. It is the policy of the Company not to allow retaliation for reports of
misconduct by others made in good faith by employees. Employees are expected to cooperate in
internal investigations of misconduct.

17. Compliance Procedures

Asking for Help and Reporting Concerns

We take this Code seriously and consider its enforcement to be among our highest
priorities, but we also acknowledge that it is sometimes difficult to know right from wrong. That
is why we encourage open communication. When in doubt, ask. Whenever you have a question
or concern, are unsure about what the appropriate course of action is, or if you suspect that a
violation of the law or this Code has occurred:

 Please talk with your immediate supervisor. He or she may have the information you
need, or may be able to refer the matter to an appropriate source, including our General
Counsel as circumstances warrant.

 If you are uncomfortable talking with your immediate supervisor, you may also contact
any manager in the Company with whom you feel comfortable or the Head of the
Human Resources Department. Your supervisor or manager is responsible for alerting
other appropriate corporate personnel as necessary.

 In addition, if you have concerns about questionable accounting practices or audit

matters, we will not retaliate against anyone who, in good faith, notifies us of a possible
violation of law or this Code, nor will we tolerate any harassment or intimidation of
any employee who reports a suspected violation. Additionally, we will initiate a
prompt investigation following any credible indication that a breach of law or this Code

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 may have occurred. We will also initiate appropriate corrective action as we deem
necessary, which may include notifying appropriate authorities.

 Make sure you have all the facts. In order to reach the right solutions, we must be as
fully informed as possible.

 Ask yourself. What specifically am I being asked to do? Does it seem unethical or
improper? This will enable you to focus on the specific question with which you are
faced, and the alternatives you have. Use your judgment and common sense; if
something seems unethical or improper, it probably is.

 Seek help from Company resources. In the rare case where it may not be appropriate
to discuss an issue with your supervisor, or where you do not feel comfortable
approaching your supervisor with your question, contact our Human Resources
Department or the General Counsel’s office at (972) 665-1000. If that is also not
appropriate, call the Business Help Line at (800) 461-9330 for callers in the U.S. and
Canada. For persons outside the U.S. and Canada, call collect at (720) 514-4400.
Callers should follow normal collect call procedures in their country. The Business
Help Line is a toll-free telephone line or collect call, as applicable, dedicated solely to
accepting anonymous complaints, questions and concerns from employees. All calls
to the Business Help Line are centrally answered by an independent third-party service.
This service is available 24 hours a day, seven days a week. For those employees that
do not speak English, there are operators available who speak other languages. The
Business Help Line is an important resource for employees. Employees are encouraged
to use it. If you prefer to write, address your concerns to: Cinemark Holdings, Inc.,
Attn: General Counsel, 3900 Dallas Parkway, Suite 500, Plano, Texas 75093.

 You may report ethical violations in confidence and without fear of retaliation. If your
situation requires that your identity be kept secret, your anonymity will be protected.
However, please remember that anonymous calls sometime make it difficult to conduct
investigations, answer questions and solve problems. The Company does not permit
retaliation of any kind against employees for good faith reports of violations of this
Code.

 Always ask first, act later: If you are unsure of what to do in any situation, seek
guidance before you act.

If you violate any provision of this Code, you may be subject to disciplinary action, up to
and including discharge. Please be aware that we may seek civil remedies from you, and if your
violation results in monetary loss to us, you may be required to reimburse us for that loss.

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 CONFIRMATION CERTIFICATE

I have been provided with a copy of the Code of Business Conduct and Ethics of Cinemark
Holdings, Inc. I acknowledge that I have read the Code and understand my responsibilities under
it. I further acknowledge that I should follow the compliance procedures described in the Code if
I have any questions or concerns.

Printed Name:
Date:

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