I. INTRODUCTION

The code of ethics and conduct establishes a set of standards and practices that employees of The Company at any level of responsibility must adhere to in order to fulfill the commitment undertaken. It serves as the guiding framework for our business practices.

Actions are a crucial and essential part of how we conduct our commercial activities. The Company emphasizes the need to maintain the highest ethical standards in managing our activities and in our relationships with employees, directors, partners, including clients, associates, and suppliers, as well as governmental bodies, members of the communities in which we operate, and the general public.

When it comes to the values mentioned in the Code of Business Ethics and Conduct, everyone is accountable. Each individual must personally adhere to the Code and never forget their role in The Company, thus respecting the provisions of the code, including applicable laws, and confirming this commitment annually. With this goal in mind, anyone who, in good faith, reports a violation of the Code will not be subject to retaliation. Success as a company and employer is closely linked to our commitment to excellence, our reputation for high-quality work, and our adherence to these standards and values.

II. OBJECTIVE

Establish the provisions that employees must adhere to during the course of their activities and in their interactions with colleagues, peers, clients, suppliers, and authorities to prevent the occurrence of behaviors that may lead to conflicts of interest, mishandling of information, unfair practices, deception, abuse, harassment, and discrimination. These provisions complement the employees’ labor obligation to perform their duties with responsibility, care, and diligence appropriate to the tasks assigned by the Administration.

This code of ethics and conduct applies to:

• Employees of The Company.
• Clients of The Company.
• Suppliers, Contractors, and Consultants of The Company.

Any Employee, Client, Supplier, Contractor, or Consultant of The Company, by virtue of having a relationship with us, is obligated to align their behavior and activities with the provisions contained in this code. As specific situations not covered in this code of ethics and conduct may arise, and considering the broad range of topics covered, it should serve as a guide for evaluating unaddressed matters. Inquiries regarding its application should be directed to the HR department of The Company.

III. SCOPE

1.1 BUILDING AND MAINTAINING OUR REPUTATION

The Company has been built on the foundations of quality work and a good reputation.

Individual and collective actions can have a direct impact on our reputation. Therefore, it is essential to always comply with applicable laws and avoid behaviors that could harm our reputation and the way our clients, the public, and any third party perceive us. Everyone must strive to maintain and promote our excellent reputation in all our activities.

1.2 MUTUAL RESPECT AND INTEGRITY IN THE WORKPLACE

Everyone has the right to respect for their personal dignity, privacy, and rights. Our daily work requires us to interact with people of diverse cultures, religions, political beliefs, ages, disabilities, races, sexual orientations, and genders. From our inception, we have recognized the need to establish a multicultural workforce. In line with these values, we prohibit actions and behaviors that reflect discrimination, harassment, or violence.

1.2.1 DISCRIMINATION, HARASSMENT, AND VIOLENCE IN THE WORKPLACE

Discrimination occurs when a person or group of people is treated differently due to their personal traits, beliefs, convictions, or any other reasons prohibited by law, including: race, color, nationality or ethnic origin, place of origin, religion, age, sex, sexual orientation, and physical or mental disability.

Harassment, whether racial, sexual, psychological, or otherwise, occurs when:

1. The person is subjected to offensive behavior;
2. These situations occur:
   • Repeated and hostile or unwanted conduct, verbal comments, actions, or gestures; or
   • A single serious incident that has lasting effects on the individual;
3. The dignity or physical or psychological well-being of the person is affected; or
4. The work environment becomes harmful.

Workplace violence may include:

1. The use of physical force that causes or could cause physical harm; and/or
2. Actions, behaviors, or statements that could be reasonably perceived as a threat to personal safety or integrity in the workplace.

In the company, we act to comply with the guidelines supporting dignified and decent work, avoiding workplace violence, respecting the dignity, personal privacy, and freedom of our employees. Consequently, individuals cannot be subjected to discrimination based on gender, religion, race, political opinion, pregnancy, language, nationality, sexual preference, or disability. Physical assaults, threats of violence, and other incidents related to violence occurring in The Company’s workplaces must be reported to the relevant authorities.

1.3 EXPECTATIONS FROM OUR DIRECTORS

Directors have additional responsibilities under the Code.

They are responsible for promoting a culture of compliance and integrity, including a positive working environment where individuals are treated with dignity and respect.

This goal will be achieved by:

• Always respecting the Code’s standards; leading by example, assisting those under their supervision in understanding and respecting the standards, policies, and practices established in our Code, and emphasizing the importance of participating in relevant training and certifications.
• Supporting individuals who, in good faith, raise a concern or report a suspicious issue, even if doing so means deviating from the chain of command.
• Avoiding taking or allowing reprisals against anyone who reports a concern in good faith. Following up when we become aware of or suspect possible negative conduct and never ignoring such behavior.

1.4 ENVIRONMENT

1.4.1 HEALTH AND SAFETY IN THE WORKPLACE

We are committed to providing safe and healthy working environments in all our offices and workplaces. The Company will ensure that current laws regarding workplace health and safety act as a minimum standard in all areas where we conduct our activities. When necessary, we will include special safety procedures as part of our overall safety program.

Our goal is to ensure risk assessment and promote awareness and elimination of potential hazards to the health, safety, and physical well-being of our employees in the workplace. The commitment of all will ensure that this goal is met, leading us to an injury-free working environment.

Everyone must work together to reduce the frequency and severity of incidents and injuries by identifying and eliminating unsafe or hazardous conditions in the workplace.

When it comes to occupational health and safety, everyone is responsible.

1.5 DRUG AND ALCOHOL CONSUMPTION

Individuals whose work capacity is affected by drug or alcohol consumption pose a threat to health and safety in the workplace.

No employee may possess, sell, buy, or consume illegal drugs at any time, or be under the influence of alcohol or drugs while working on any premises of The Company, in controlled facilities, or at a client’s (current or potential) or supplier’s facilities.

Making the right decisions is essential. Likewise, we are prohibited from consuming, selling, buying, or possessing alcoholic beverages on The Company’s premises.

1.6 ENVIRONMENTAL PROTECTION

All personnel of The Company must be committed to environmental protection and conducting business activities responsibly toward the environment.

Achieving these goals requires the involvement of everyone, including effective leadership from directors and the engagement of all employees. Whether in the project planning phase or during implementation, everyone must respect and comply with both laws and standards and practices adopted by The Company related to environmental protection. Everyone plays a significant role in achieving these goals through actions and behavior.

2.TRANSPARENCY IN ALL OUR ACTIVITIES

Despite the intense competition in the markets in which we operate, all our business activities must be carried out strictly in accordance with the laws and regulations in force. Any illegal conduct is strictly prohibited. In case of doubt about the interpretation of a law or regulation, it should be consulted with the Human Resources Department.

2.1 ANTITRUST AND FAIR COMPETITION LAWS/CONCLUSION

In The Company, everyone must commit to competitive and fair business practices in accordance with applicable laws related to antitrust and competition.

While the definition may vary from one jurisdiction to another, collusion is defined as the secret agreement between two or more parties for a fraudulent, illegal, or dishonest purpose. Laws dealing with such matters differ from country to country. For example, we cannot engage in discussions or reach agreements with our competitors to: fix or control prices, terms, or conditions; restrict competition or relationships with suppliers; restrict the export or import of goods supplied by The Company; divide or distribute customers, markets, territories, or production programs between The Company and our competitors; influence the resale prices set by our buyers; or submit false bids for tenders.

We must not seek to obtain competitive intelligence illegally through industrial espionage, bribery, theft, or electronic interception. Similarly, we must not communicate false information about a competitor that we know to be false.

2.2 ANTI-BRIBERY AND ANTI-CORRUPTION

2.2.1 OFFERS, PROMISES, AND BRIBES

The Company distinguishes itself from its competitors by the quality of its work, the services it offers, and its reputation. No one should directly or indirectly offer, promise, grant, or authorize the delivery of anything of value: money, gifts, entertainment, employment, contracts, or any other advantages, to a client, supplier, or any other third party to influence an official action or to obtain an undue advantage.

While the definition may vary from one jurisdiction to another, corruption is defined as “the abuse of power granted to obtain a personal benefit.”

Similarly, one should never offer or accept an “improper commission,” meaning the return of a sum already paid (or to be paid) as a reward for carrying out or promoting business agreements. No third party should be hired to perform an activity in which we are prohibited from participating.

When dealing with a government official, special attention must be paid to laws, regulations, and directives regulating matters related to gifts and entertainment given or offered. A “government official” nationally or internationally may include officials or employees, or anyone representing or acting on behalf of: any type of government (federal, provincial, state, municipal, or other); entities wholly or partially owned by the government; international public enterprises; political parties, employees of political parties, and candidates for official positions; or a person holding a legislative, administrative, judicial, or military office.

2.3 PAYMENTS FOR EXPEDITING SERVICES

Payments for expediting services are infrequent payments of small sums of money made to a government official to expedite government tasks such as issuing visas and work permits. Payments for expediting services are strictly prohibited.

In cases of imminent danger, payments may be needed to prevent immediate harm to employees. Any coercive payment must be accurately reported to the Legal Affairs Department or a compliance officer as soon as possible to ensure that it is accurately recorded in the books and records and can be reported to the relevant authorities.

2.4 POLITICAL CONTRIBUTIONS

Companies are allowed to make contributions to political parties or candidates for political office in certain jurisdictions, while in others, it is prohibited. Local law requirements must be strictly adhered to the extent that such requirements are not contrary to our Code.

When the law allows, individuals should, at their discretion, make personal contributions to the political party of their choice. No one should solicit or pressure others to make political contributions during working hours or on The Company’s premises or if they are prohibited by law.

2.5 WORKING WITH THIRD PARTIES

The Company believes it is important that third parties with whom the company engages, such as consultants and business partners, share its values and comply with all applicable laws. Therefore, such third parties are expected to act consistently with the Code and adopt and implement practices that:

1. Comply with all applicable laws and regulations.
2. Refrain from engaging in bribery and other forms of corruption.
3. Take responsibility for the health and safety of their employees.
4. Respect the human rights of their employees.
5. Strive to promote sustainable local development.
6. Strive to ensure that business activities are conducted responsibly for the environment.
7. Promote and reflect our commitment to the quality of our work.
8. Avoid conflicts of interest.

During the time of the relationship with The Company, it must be ensured that actions are in the interest of The Company.

Personal relationships, activities, and interests may give rise to actual or apparent conflicts of interest. Everyone must be able to identify situations in which they may be in an actual or apparent conflict of interest.

If there is any doubt about whether there is an actual or apparent conflict of interest, it should be discussed with the Human Resources Department of the company.

The following situations are some examples of actual or apparent conflicts of interest:

• Engaging in secondary employment relationships that restrict our ability to fulfill our duties at The Company.
• Accepting a director position in a third-party organization without informing and obtaining prior authorization from the immediate supervisor and the Human Resources Department.
• Establishing a business relationship with a competitor, business partner, supplier, or customer of The Company or owning a financial interest in any of them.
• Working with a family member or someone with whom we have a personal relationship.

Any activity that would constitute an actual or apparent conflict of interest must be promptly reported to our immediate supervisor and the Human Resources Department for follow-up.

4.PROTECTION AND MANAGEMENT OF COMPANY ASSETS, INCLUDING INFORMATION TECHNOLOGY ASSETS

Company assets must not be used inappropriately. The operational, financial, and information assets of the Company must be protected and preserved, including adherence to the current internal control policies.

Employees must also use the Company’s assets exclusively for legitimate business purposes.

Theft, negligence, abusive use, and waste directly impact our profitability. It is prohibited to use our assets for illegal or improper purposes or with the intention of gaining personal or third-party advantages or profits.

Email accounts, including those of the Company, and information systems and equipment provided to us during our employment with the Company, such as phones, photocopiers, computers, software programs, Internet/intranet, machines, and voicemail systems, will remain the exclusive property of the Company. The exchange of information through electronic means, such as email, Internet, etc., may pose certain risks related to the protection of our privacy, the confidentiality of the Company’s information, and the security of its IT assets. All precautions must be taken to ensure that the information exchanges we perform do not disclose private or confidential information to an unauthorized third party.

We must not use the Company’s property for personal use or other purposes that may be questionable; for example, sharing, storing, or processing content that:

• Is prohibited by law (such as illegal downloading of copyrighted material).
• Promotes or incites harassment.
• Could be perceived as racist, atrocious, sexist, or pornographic.
• Could tarnish the reputation of the Company.

The Company reserves the right to become familiar with any content exchanged, stored, or processed on its property.

These communications may also be subject to disclosure to the police or relevant authorities. Therefore, it is understood that we waive any right to confidentiality we may have regarding any information exchanged, stored, or processed on Company equipment to the extent permitted by law.

Unless authorized by the Company, it is not permitted to record records, files, video or audio, or reproductions using Company equipment or facilities if the activity is not directly related to the Company’s activities.

4.1 INFORMATION PROTECTION

Accurate and reliable financial information is indispensable for the company.

This information is the basis of financial statements and other data communicated to the public, clients, partners, and other stakeholders. Our business decisions and strategic planning are also guided by this information.

The basis of accurate and reliable financial statements lies in respecting our internal controls and accurately accounting for transactions and elements of the Company’s assets and liabilities in the Company’s accounting books. Therefore, all our accounting books must be complete, accurate, and reliable.

4.2 INTELLECTUAL PROPERTY

Copyrights, trademarks, designs, inventions, improvements, discoveries, and any other form of intellectual property (such as protocols, procedures, technical processes, research methods, etc.) created or modified during the course of our relationship with the Company will become the exclusive property of the Company.

Furthermore, intellectual property developed outside the relationship with the Company belongs to the Company if its development arises from the acquisition of confidential information acquired during the course of our relationship. In such instances, we will be required to sign documents demonstrating the ownership of the Company.

4.3 CONFIDENTIALITY OF COMPANY INFORMATION

We all understand that, during the course of our relationship with the Company, we may come into contact with information that could be considered secret and confidential and is not known to the public.

We must not use or disclose such secret or confidential information belonging to the Company or third parties with whom the Company deals.

Secret or confidential information belonging to the Company may include:

• Details related to our company, clients, prices, markets, equipment, sales, profits, internal reporting figures, and other matters related to our business.
• Information related to research and development.
• Technical information related to our products, services, and processes.
• Information related to our marketing strategies and services.
• Details related to current or potential mergers, acquisitions, or buying and selling of assets.
• Information related to employees and human resources.

The obligation regarding the confidentiality of trade secrets and confidential information applies both during the course of our relationship with the Company and after its termination.

4.4 PERSONAL AND PRIVATE INFORMATION

The Company is committed to respecting our right to individual privacy and has taken the necessary measures to ensure the accuracy and security of data.

Any personal information disclosed to or collected by the Company during the course of the relationship will remain private and confidential. The personal information disclosed to the Company will only be used for the purposes for which it was obtained. However, the Company may disclose personal information contained in a resume to its clients for the purpose of submitting a bid or proposal.

There may also be situations where the law requires the disclosure of such information. Disclosure may also be required for the administration of a program by a third party. Information may also be disclosed to clients and third parties as part of project or contract audits.

In any other situation, the Company will ensure that your consent is obtained before disclosing such information. Furthermore, it will ensure that the information is not used for any purpose other than for which it was disclosed and will require the third party to provide a guarantee for this purpose.

The use of personal email for professional purposes is not recommended. In case it cannot be avoided, we must send a copy of any work-related email sent from a personal account to our Company email account.

4.5 EXTERNAL COMMUNICATION

Opinions or information requested by external groups or organizations should be channeled through the Human Resources Department to receive a response.

Anyone expressing opinions to such external interests on matters unrelated to the Company’s activities should be aware that their comments are strictly personal and therefore must be careful not to compromise in any way.

The Human Resources Department is the official contact for any media member seeking an interview, opinion, comment, or suggestion on any topic that may affect the Company’s business activities.