Policy on Corruption and Transnational Bribery

The Company is strict in compliance with its corporate values ​​and principles, for this reason, it will not tolerate from its Shareholders, Administrators, Employees, Suppliers, Clients, any conduct that is contrary to transparency, integrity and ethics.

For this reason, the administrators promote a culture of integrity that seeks to guarantee that all actions in which the Company is involved are governed by ethical and transparent parameters, prohibiting any act related to Corruption and Transnational Bribery.

In this sense, the Company will require its Shareholders, Administrators, and Employees to sign a declaration of knowledge and express commitment to the Transparency and Business Ethics Program, which will state that none of them may, passively or actively, directly or indirectly, give, offer or promise to a foreign or national public servant i) sums of money, (ii) any object of pecuniary value or (iii) other benefit or utility, in exchange for him; (i) performs, (ii) omits, (iii) or delays, any act related to the exercise of its functions and in relation to a national or international business or transaction; conducts that also extend to the private sphere in the sense of not engaging in the same in relation to officials of private sector companies.

Likewise, a real commitment is expected from all counterparties to communicate, through the Ethics Line, any fact or irregularity that is contrary to the PTEE and current legislation and that affects or may harm the interests of the Company.

It is clear that violating any provision established in the PTEE and that represents damage or harm to the Company and/or its counterparties, will result in the immediate termination of the contractual or commercial relationship with the Company.

Policy for gifts or benefits from third parties

In accordance with the corporate values ​​and the statements made in this Manual, the Company defines its Policy for Gifts and benefits in the field of commercial and/or labor relations, the purpose of which is to clearly define the Company’s position regarding the attention to Employees, Suppliers, Clients and third parties through gifts or benefits, which allows for the consolidation of transparent relationships between them.

Being aware that giving and receiving gifts can be decisive for the beneficiaries of these to make influenced decisions that may affect the interests of the Company and could even represent an event of bribery or corruption, it is established as a General Principle of this Policy “not to promote the practice of giving or receiving gifts or gifts to Employees, Suppliers, Clients and third parties”, unless they meet the following characteristics:

• That its amount does not exceed 25% of a legal minimum wage.
• These are corporate gifts, that is, those that are given to promote the services offered by the giver, such as marketing activities.
• That they are not offered within a context that could evidently influence the decision of the person who receives it and in favor of the person who grants it.
• That corresponds to invitations made to promote or publicize products or services related to the commercial activity of the Company, which must have the written approval of the Employee’s hierarchical superior, along with due justification.
• Invitation to training or events related to the position or functions of the Employee within the Company, which must have the written approval of the Employee’s hierarchical superior, along with due justification.

Consequently, it is expressly prohibited to give or receive Gifts and Invitations that do not fall within the aforementioned exceptions and, especially, those that:

• They are materialized in trips, hotels, cruises, shows, sporting events.
• They come from a national or foreign public official.
• They correspond to cash, transfers, bonuses, discounts in commercial establishments to acquire goods or services, among others.

If in doubt about the possibility of giving or receiving a specific gift, or accepting or offering an invitation, the Compliance Officer should be consulted.

Due Diligence Policy

The Company, in its commitment to zero tolerance for Corruption and Transnational Bribery, establishes within its guidelines the need to know the parties with whom it does business or maintains labor and/or commercial relationships.

For this reason, a Due Diligence process of knowledge of the counterparties is defined that will be carried out before starting any contractual, labor or commercial relationship, together with the specific Due Diligence process for the PTEE, which will be applied when faced with a international transaction or negotiation of any type and amount.

Thus, Due Diligence, in light of the PTEE, verifies the conditions of the negotiation through an evaluation of the legal, accounting and financial aspects related to the transaction, to identify the existence of possible risks of Corruption and Transnational Bribery that may affect the Company. Said evaluation will be supported in the PTEE Due Diligence Format.

This analysis will be carried out prior to the signing of a business or international transaction, minimizing risks and generating traceability of the negotiation in favor of transparency and compliance with the PTEE.

The evaluation of the business or international transaction, together with the counterparty, will be updated annually, unless there is a significant change that requires immediate analysis, as deemed by the Compliance Officer, relying on established controls, mitigating current risks or anticipating them. .

The scope of Due Diligence for PTEE will vary depending on the object, complexity, value and geographic areas where the contracts will be executed, which will be determined by the Compliance Officer.

This Due Diligence includes the following phases:

• Phase of connection to the Company: SAGRILAFT policies will be complied with.
• Once this phase is completed, the PTEE Due Diligence procedure is activated to determine the viability of continuing with the contracting process, focused exclusively on international negotiations. In the event that the negotiation does not represent a risk for the Company, the contract or purchase/service order will be signed with all legal requirements met, including a declaration of knowledge and compliance with the PTEE.

The Compliance Officer will carry out annual reviews of compliance with the PTEE in order to adjust the components that the program requires for effective mitigation of the risks of Corruption and Transnational Bribery.

Policy on Remuneration and Payment of Commissions to Suppliers and Employees, regarding international businesses or transactions.

1. Remunerations and payment of commissions to Suppliers: All international negotiations or transactions must be in writing and will be analyzed in accordance with the provisions of the Due Diligence policy as part of the controls defined to minimize the risk of Transnational Bribery.

If within the framework of the negotiation the parties establish the recognition and payment of commissions, there should be no doubt about their nature, and it will be necessary that the way in which the generating event and payment of the same are agreed are clear. And do not leave room for interpretation. The above will prevent hidden payments from being made through commissions, a practice that is expressly prohibited.

Payments for these concepts will be made through bank transactions, being duly supported by invoices, collection accounts prepared according to the terms established in the contract or purchase order, in such a way that they are recorded in the bank account registered by the contractor at the time of payment. Time to complete the linking process.

No payment is allowed to third parties other than those involved in the contractual relationship.

2. Remunerations and payment of commissions to Employees: The remunerations and commissions that may be generated in favor of Employees are regulated by the provisions of the employment contract and the Commission Policy for the commercial area.

The trips made by Employees and Senior Managers, at the expense of the Company, must strictly obey the exercise of their functions within the Company. In this sense, for the recognition of travel expenses, strict compliance with the “Travel Policy” must be followed.

Once the trip is completed, all Employees must submit the list of expenses in the expense report defined by the Company to verify that the internal process that indicates the maximum amounts they can incur for these concepts was complied with.

Policy on Contributions to political campaigns, parties or candidates

The General Manager will be the only one authorized to approve contributions intended to finance candidates, campaigns, parties or political movements. These contributions will be made following the guidelines and ideologies of the Shareholders, understanding that under no circumstances do they seek to obtain benefits in favor of the Company’s own interests.

The decision and approval of the political contribution will be recorded in a minute, and will be reported to the Compliance Officer.

Policy on Filing Procedures and Conservation of Documents that are Related to Businesses or International Transactions

The Compliance Officer will guarantee the integrity and conservation of the documents generated when international business or transactions are carried out. In this way, it is the obligation of the respective positions to have the following supports:

Likewise, there will be support from the documents that make up the PTEE:

• Approval record of the PTEE.
• This Manual.
• Support for updates made to the Program.
• Reports presented to the Board of Directors
• Support of training carried out for employees.
• Presentations made to various interest groups.
• Communication plan and strategy to create and strengthen the commitment to transparency
• C/ST Risk Matrix
• The reports delivered by the Statutory Auditor, along with the respective response and the activities they support.
• The reports received through the Ethics Line and their final result.
• Supports compliance with established policies and audits carried out to verify compliance.

The documents will be archived for a period of 10 years applying the methodology established by the Company. In any case, their destruction will require the express approval of the Compliance Officer.

Donation Policy

The Company committed to social responsibility will make donations, as long as they are authorized by the president, after verification of the following conditions by the Compliance Officer:

1. That it has been approved by the Financial Management
2. That due diligence has been carried out to obtain real and exhaustive knowledge of the beneficiary entity.
3. That the tax aspects of the donation have been evaluated.
4. There must be a formal donation request from the beneficiary entity, unless the initiative to donate comes directly from the presidency.

Once the donation is approved by the General Manager, it must be supported in the Donation Certificate, Delivery Minutes.

Internal Report

The Company had an ethics line as a reporting channel through which Shareholders, Administrators, Employees, Suppliers, and Clients will report any improper conduct that constitutes or may constitute transnational bribery or any corrupt practice associated with the Company.

Reports may be made anonymously; However, if personal information is provided, total confidentiality will be guaranteed and the identity of the complainant, the accused and other people who are part of the case will be protected.

Additionally, Employees may use this channel to consult about the application of the PTEE or to obtain advice in the event of a possible situation that involves bribery or any other conduct associated with corruption.

The channel used to make reports to the ethics line will be:

• Email: lineaetica@personalsoft.com

External Report

All Shareholders, Directors, Employees, Suppliers and Clients may submit complaints related to Transnational Bribery through the channel provided by the Superintendency of Companies at the following link: https://www.supersociedades.gov.co/es/web/asuntos- corporate-economic/transnational-bribery-complaints-channel

For those complaints concerning corrupt practices or conduct, they will be reported to the Transparency Secretariat at the following link: https://www.secretariatransparencia.gov.co/observatorio-anticorrupcion/portal-anticorrupcion