What is the scope?

This Code of Ethics and standards of conduct is the basis for compliance with our business ethics and transparency program and contains the rules that apply to collaborators at all hierarchical levels, direct and indirect, who are part of the work team of the companies Personal Soft LLC. company incorporated under the laws of Colombia and Prosoft Services S.A. Company established under the laws of Panama, which will be known interchangeably as Personal Soft LLC, and serves as a guide for decision-making in all our actions and the minimum expected behavior.

This Code is not and does not pretend to be exhaustive, nor to include all situations where an ethical conflict may arise. Therefore, situations not provided for in this Code of Ethics will be resolved in accordance with the principles of equity, justice and mutual respect, together with the general principles set forth in the Universal Charter of Human Rights, the Constitution and by the codes, regulations, internal policies and procedures, with said responsibility being the responsibility of the company’s steering committee.

GLOSSARY

Code of ethics: Series of rules, regulations and values that have been established to regulate the behaviors and attitudes of people who are part of the same context, whether with respect to a profession, organization or company.

Ethics: Study of human behavior, expressed in concepts such as right and wrong, good and bad, virtue, happiness and duty, as well as in the value systems that these categories support.

Values: Values are those principles, virtues or qualities that characterize a person, an action or an object that are typically considered positive or of great importance by a social group.

Confidentiality: Confidentiality is a property that holds some type of information and through which access to it will be guaranteed only to those people who are authorized to know it, and therefore it will not be revealed to those who do not have authorization to know it. .

Find out: Mass internal dissemination email, addressed to all the company’s collaborators, in order to disseminate information on topics related to the company and the people who make it up.

Corporate intranet: It is a private computer network that allows access only to authorized users within an organization. Frequently safeguarded with User IDs and passwords, they are used by companies to store general documents and other resources for internal use.

GIS Portal: It is an internal portal located on the corporate Intranet, where you can find the processes that the organization has.

PTEE: Transparency and business ethics program.

SAGRILAFT: Comprehensive self-control and risk management system for money laundering, terrorism financing and the financing of the proliferation of weapons of mass destruction or ML / FT / FPADM.

GENERAL GUIDELINES

Our company’s actions are aimed at internalizing and complying with our values and corporate philosophy, which are reflected in the quality of our relationships with clients, suppliers and collaborators, and in the development of our functions with transparency and integrity to provide the best solutions in our services, mediated by trust, integrity, excellence, respect and commitment.

CHAPTER I: FUNDAMENTAL PRINCIPLES OF RELATIONSHIP

With these guidelines, we highlight the fundamental principles that we take as a reference with the different interest groups when interacting, putting into practice the values and ethical actions adopted by the company.

We act in accordance with the values, corporate philosophy, policies; likewise, we establish administrative procedures for control and monitoring of our contractors and suppliers, so that, without prejudice to their administrative autonomy, they adopt practices and standards of conduct in accordance with our beginning.

UNIVERSAL HUMAN RIGHTS

At Personal Soft S.A.S, we are committed to respecting human rights. To that end, we seek to promote the following standards in accordance with current laws: Equal opportunities for employees at all levels, respecting cultural diversity, disability or any other characteristic protected by law. In addition to this, salaries that allow them to satisfy at least their basic needs, and opportunities for them to develop and enhance their skills and abilities.

We respect the legitimate freedom of association of collaborators; We recognize all legal and labor rights, as well as the correction of any situation that may violate Human Rights, such as child labor, forced labor or under conditions that may harm the physical and mental health conditions of people within Our company. Likewise, we encourage our collaborators to be responsible for ensuring that collaborative forms of work predominate, in which the skills of the different people in the company are combined.

NONDISCRIMINATION

We protect the integrity of each collaborator by guaranteeing and monitoring that they are free from any type of discrimination, in order to prioritize the principle of equal opportunities.

Each human being has the right to receive the same treatment, taking into account the different traits and behaviors that make up their personality, for this reason, in the processes of attraction and selection, hiring, promotion, promotions and organizational development, the characteristics of each person.

We do not allow the use of our own facilities or where our collaborators are assigned (Client headquarters, Teleworking places), to access material with discriminatory content, nor to disseminate through any communication channel, information that induces the adoption of behaviors that can be classified as arbitrary.

Likewise, we treat our clients and suppliers honestly, fairly and with respect, being responsible with non-discrimination based on personal characteristics or religious and political beliefs.

PROHIBITION OF PSYCHOACTIVE SUBSTANCES, ALCOHOL, TOBACCO AND DRUGS

We are interested in promoting the physical and psychological health of our collaborators, clients and suppliers, ensuring a work environment free of the consumption of alcohol, psychoactive substances, tobacco and drugs. With the aim of achieving and continuously maintaining the highest standards of physical and social well-being of employees, the possession, distribution, marketing and consumption of psychoactive substances, alcohol and illicit drugs, or being under the influence of these, is prohibited. during the work day.
Our purpose includes the well-being of people, therefore, taking into account that the consumption and abuse of these substances can cause serious risks to the safety of employees and their entire work environment, the use, consumption and marketing of these substances is prohibited. the same for the well-being of all, exceptionally in special internal events in the company (authorized in a particular way and not by general means), in which the General Management only authorizes moderate consumption of alcohol.

SECURITY AND HEALTH AT WORK
We seek to promote safe spaces and environments for employees, contractors, suppliers and visitors, contributing to well-being and health, through the early detection of incidents and work accidents. We provide all the technical, human and economic resources necessary for the development of the Occupational Health and Safety System.

Employees must commit to and adopt a lifestyle that minimizes latent work risks, occupational risks, injuries and illnesses that may affect both their productive capacity and their state of health.

Currently, the following committees are established that help us prevent and care for events that generate risk for employees:

For Colombia:
• Emergency Committee.
• Emergency Brigade.
• Joint Health and Safety Committee at work.
• Coexistence Committee for Panama.
• Hygiene and Safety Committee.

ENVIRONMENT AND SOCIAL RESPONSIBILITY

Each of our actions impacts the ecosystem, for this reason, we promote the protection of the environment and the appropriate use of natural resources, committing ourselves to permanently seeking means to reduce negative impacts through environmental policies that include solid waste management, proper use of water resources, efficient use of energy, CO2 emissions and any element that could potentially affect it.

In the same way, employees must adjust their behavior to the policies defined by the company:

• Do not leave appliances and electrical equipment on that you do not use.
• Opt for paper bags and cloth bags, instead of plastic ones.
• Make the most of sunlight so you can avoid electric lights.

• The air conditioning is controlled internally and remains programmed at 23º C.
• Don’t waste water, make good use of it, remember that our bathrooms and sinks help control water.
• Do not print emails that are not necessary.
• Use batteries and items that recharge with solar energy.
• Avoid traveling by vehicle, walking or cycling, in addition to taking care of the environment, will help you be healthier.
• Do not use disposable products, they are much more polluting.
• Use recycling bins correctly.

You contribute to the care and protection of the environment when:
• You comply with the laws, regulations and environmental commitments applicable to the tasks you perform and make efficient use of the resources you need.
• You promote, to the best of your ability, the application and compliance with national and international environmental protection standards.
• You promote awareness of respect for the environment, education, and environmental awareness within the personal, family, social and work core in which you interact.

It is the obligation of all collaborators to demonstrate environmentally correct behavior, as well as comply with and follow the standards, policies and procedures for environmental preservation established by the company, as well as report any potential environmental risk. All leaders are responsible for defining clear roles and responsibilities to protect the environment, provide appropriate resources, measure, review and continually improve the company’s environmental performance.

CHAPTER II: COMPANY PROTECTION AND SECURITY FOR CUSTOMERS, SUPPLIERS AND EMPLOYEES

PROTECTION OF THE PERSONAL INTEGRITY OF EMPLOYEES.

We prioritize actions aimed at preventing and detecting activities of workplace harassment or sexual harassment, where the individual freedom of collaborators may be attacked, for this reason it will be everyone’s commitment to report any type of discrimination, disrespect, threat, anguish and/or or intimidation that occurs.

We promote the prevention of workplace harassment behaviors, through work with decent and fair conditions, harmony between those who share corporate work life and a good environment in the company, likewise, we protect privacy, honor, mental health and freedom of people at work.

The above implies that no one can be injured or physically attacked, nor be a victim of mental or moral damage that prevents them from maintaining their psychological stability. If any employee sees their integrity affected by their leaders, colleagues or anyone from the interest groups, such as suppliers and clients, they may escalate the issue to the Workplace Coexistence Committee.

PROTECTION AND FAIR TREATMENT OF OUR CUSTOMERS AND SUPPLIERS

We serve clients and suppliers with equitable and honest treatment, providing the products and services that correspond to them with the highest quality and opportunity available to them. Likewise, we ensure the confidentiality of the information that each one provides to the organization. We compete vigorously, complying with all laws and regulations, ensuring the equal participation of suppliers and an impartial selection of them, based on criteria of management systems, time on the market, quotes, delivery times and commercial references.

Furthermore, we ask Personal Soft S.A.S. suppliers to comply with all applicable laws and regulations of all countries in which we operate or acquire goods or services, including laws related to commercial conduct, product quality, environmental standards, occupational health and safety, labor and employment.

FAIR COMPETITION

All those who have contact with people belonging to companies recognized as competitors must show a professional attitude, attached to the philosophy and values of the company we represent, based on respectful treatment with moral values, avoiding unethical circumstances that violate integrity. and human dignity or the use of culturally offensive symbols that refer to gender, race, nationality, religion, social class or political preference.

In this way, the company’s actions will be governed by commercial loyalty, so it can only compete with excellence in service and creativity in the services provided, likewise, the actions of its collaborators will be supported by transparency and corporate values.

CORPORATIVE SECURITY

Proper use and care of assets and goods

We are responsible for protecting and putting to good use the fixed assets, which are provided once a collaborator arrives at the company, not only those assigned for the development of individual or group tasks, but also those made available to everyone. collaborators in general, such as furniture and facilities.

Considering the importance of fixed assets for the operation of our business, we will sanction the conduct of collaborators who, by action or omission, lead to the loss or unauthorized disposal, or misappropriation by third parties, of assets and property of the company. company, and we will report to the competent authorities any malicious or fraudulent conduct of which we are aware and that may be classified as a crime, taking into account the Fixed Assets Policy and the guidelines set forth therein.

PROTECTION OF INTELLECTUAL PROPERTY

We are committed to the care of the Company’s Intangible Assets, which contain the intellectual property of patent rights, names and trademarks of goods or services, domain names, reproduction or copy rights, including the rights of reproduction of software, design rights, rights over databases, rights over specialized technical knowledge, trade secrets and own or third party information held by the company, whether confidential or not.

CHAPTER III: COEXISTENCE AND CODE COMPLIANCE COMMITTEE

COMPLAINT RECEPTION AND PROCESSING SYSTEM

We have a Coexistence Committee, in order to promote a work environment in dignified and fair conditions, we have created a support group so that they can openly report matters regarding violations of the Code of Ethics, conduct and situations that they consider unethical. , and that go against the rules or non-compliance with procedures, policies and possible acts of workplace harassment.

The Coexistence Committee is made up of two representatives democratically elected by all employees and two representatives chosen by the Chief Executive Officer, guaranteeing that each member has their respective substitute for proper management. This committee, through quarterly meetings, must analyze the management of said complaints and also take the respective measures to guarantee their closure.

In this way, we will be aware of the best practices and we will take the necessary corrective measures to process claims, concerns and situations that arise. If any collaborator has questions, requires advice or needs to reveal any information, they can do so by email at sst@personalsoft.com

Reports made through the aforementioned email must be made directly by the person who wishes to process the complaint. In any case, the information provided will be kept confidential. Confidentiality means that the name of the complainant will not be revealed and that the reported facts will only be made known to those who are strictly necessary to carry out the investigation and respond to its findings.

SANCTIONS FOR NON-COMPLIANCE WITH THE CODE AND PROTECTION OF THE WHISTLEBLOWER.

We reject any breach of the Code by collaborators, clients or suppliers. In the event that the non-compliance is towards the collaborators, it will be evaluated and sanctioned according to the situation and in accordance with the terms of the signed contracts. If a collaborator has doubts about their actions, they must understand that they must always be guided by the corporate values established in the corporate philosophy and in this Code.

There will be no repression against people who, in good faith, disclose irregularities that lead to investigation processes. Except for legal exceptions, no Manager or collaborator linked by an employment contract, who in the exercise of his or her function is aware of the complaints or allegations, may disseminate them in whole or in part.