AIM.

The Board of Directors of COMERCIALIZADORA VIKINGOS, hereinafter, is committed to adhering to the highest quality standards and complying with all laws and regulations that govern its operations. The purpose of this Anti-Corruption and Anti-Bribery Policy is to instruct employees or those who work for or on behalf of the Company regarding the applicable anti-corruption and anti-bribery laws, as well as to publicize the declaration that it has as a company, guidelines and Defined sanctions for breaching your compliance policies.

SCOPE.

This policy applies to Directors, Collaborators linked by employment contract and other Linked third parties, including attorneys-in-fact, representatives, etc.

DEFINITIONS.

Final beneficiary : In accordance with article 631 - 5 of Law 2155 of September 2021, they are the natural person(s) who finally owns or controls, directly or indirectly, a a client and/or the natural person in whose name a transaction is carried out. It also includes the natural person(s) who exercise effective and/or final control, directly or indirectly, over a legal person or other structure without legal status.

Client : They are the natural or legal persons with whom the Company maintains a legal or contractual relationship for the supply of the products and/or services of the portfolio.

Company: COMERCIALIZADORA VIKINGOS

Counterparty: It is any natural or legal person with whom the Company has commercial, business, contractual or legal ties of any kind. Among others, the Company's partners, employees, customers, contractors and suppliers of Products and services are counterparties.

Contractor: Refers to any third party that provides services to the Company or that has a contractual legal relationship of any nature with it. Contractors may include, among others, suppliers, intermediaries, agents, distributors, advisers, consultants and persons who are parties to collaboration or joint venture contracts with the Company.

Conflict of interest : A conflict of interest is understood when:

• There are conflicting interests between a collaborator and the interests of the Company, which may lead them to adopt decisions or carry out acts that are for their own benefit or that of third parties and to the detriment of the Company's interests.
• When there is any circumstance that may diminish the independence, fairness or objectivity of the actions of any Company collaborator, and this may be detrimental to its interests.

Corruption : Any act, attempt, omission and/or abuse of the powers derived from a relationship of authority or trust to obtain an undue advantage, both in the public and private sectors.

C/ST: Corruption and Transnational Bribery.

Due diligence: It is the process by which the Company adopts measures for the knowledge of the counterparties, their business, operations, and products and the volume of their transactions.

Expanded Due Diligence.

• (DDA): It is the process through which the Company adopts additional measures and with greater intensity for the knowledge of the Counterpart, its business, operations, products and the volume of its transactions.

Donation: Refers to when a person or institution, out of liberality, transfers goods or services from their heritage to another, who accepts them.

Ethics Line: It is a communication channel defined so that employees, partners, contractors, clients, suppliers and their other publics can report confidentially and anonymously, corrupt behaviors, irregularities or any unethical act that goes against good conduct. and compliance with the Company's transparency program policies.

Compliance officer : It is the natural person appointed by the Board of Directors, who must comply with the functions and obligations established in Circular 100-000011 of August 9, 2021 regarding the Implementation and management of the Transparency and Business Ethics Program of the company.

Facilitation payments : A form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine government action. These facilitation payments tend to be required by Collaborators with weak ethical principles to offer an exceptional level of service and in this sense it can be considered an act of Corruption.

PEP: Politically Exposed Person . Politically Exposed Persons (PEP) are considered public servants of any system of nomenclature and job classification of the national and territorial public administration, when they have assigned or delegated functions of: issuance of rules or regulations, general management, formulation of institutional policies and adoption of plans, programs and projects, direct management of property, money or securities of the State, administration of justice or sanctioning administrative powers, and individuals who are in charge of directing or managing resources in political movements or parties. These functions may be exercised through expenditure management, public contracting, management of investment projects, payments, liquidations, administration of movable and immovable property. Decree 830 of 2021 specifies the positions that are considered PEP.

Also considered as Politically Exposed Persons (PEP) are those persons who perform prominent functions in another country, who are called Foreign Politically Exposed Persons and/or Foreign Public Servants.

Suppliers: Those counterparties that provide their services and/or provide resources for the development of the Company's corporate purpose.

PTEE: Transparency and Business Ethics Program . Transparency and Business Ethics Program: it is the document that includes the Policies and procedures aimed at identifying, detecting, preventing, managing and mitigating Corruption and Transnational Bribery Risks that may affect the Company.

SAGRILAFT: System for Self-control and Comprehensive Risk Management of Money Laundering, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction.

Foreign Public Servant: Any person who holds a legislative, administrative or judicial position in a State, its political subdivisions or local authorities, or a foreign jurisdiction, regardless of whether the individual has been appointed or elected. A foreign public servant is also considered any person who performs a public function for a State, its political subdivisions or local authorities, or in a foreign jurisdiction, whether within a public body, or a State company or an entity whose decision-making power is subject to the will of the State, its political subdivisions or local authorities, or a foreign jurisdiction. Likewise, it will be understood that any official or agent of an international public organization holds the aforementioned capacity.

Transnational Bribery: Legal entities that, through one or more: employees, contractors, administrators, or associates, themselves or any subordinate legal entity, give, offer, or promise, to a foreign public servant, directly or indirectly: sums of money , any object of pecuniary value or other benefit or utility, in exchange for the foreign public servant; perform, omit, or delay, any act related to the exercise of their functions and in relation to an international business or transaction.

Declaration COMERCIALIZADORA VIKINGOS, is committed to adhering to the highest standards of compliance and business ethics and complying with all laws and regulations that govern its operations. The Company assumes its responsibility to build, hand in hand with its human team, a better society and future for all.

The Company has "Zero Tolerance" for any conduct that could be classified as bribery or that could, in any other way, be considered corrupt. At COMERCIALIZADORA VIKINGOS , corruption or bribery is strictly prohibited, either directly or indirectly through a third party that represents the Company. This prohibition includes bribery of a Politically Exposed Person (PEP) and commercial bribery between private parties.

The Company and its representatives are strictly prohibited from offering, paying, promising payment, authorizing payment, soliciting, receiving, or authorizing the receipt of money or anything of value, directly or indirectly, for the purpose of obtaining, withholding, or direct business to any person or for any other type of improper advantage. The term “anything of value” includes money, gifts, entertainment, travel, services and any other courtesies.

Delivery and offering of gifts or benefits to third parties.

Company Representatives and/or any of its collaborators may not offer, pay, promise payments, or authorize the payment of money or anything of value, either directly or indirectly, to any third party for the purpose of obtaining, to retain business or to obtain any other improper advantage; For this reason, prohibited gifts, hospitality and hospitality include, but are not limited to, travel, lodging, courtesies, discounted rates, gifts, dining, entertainment and charitable contributions. Such courtesies are permitted, provided they are reasonable in light of industry practices and in accordance with applicable anti-corruption laws, and are not made for the purpose of obtaining or retaining business or to obtain any improper advantage. In the specific case of the representative or collaborator who wishes to make a gift or attention to a PEP, they must request prior authorization from the General Management.

Acceptance of gifts, hospitality and hospitality by contractors, suppliers and customers .

Employees may not receive gifts, hospitality, or hospitality for their benefit from contractors, suppliers, intermediaries, consultants, or actual or potential customers, if they:

1. They give rise to a conflict of interest, as established in the Company's Manual for Handling Conflicts of Interest.

2. Violate the Company's values ​​and/or applicable national or international laws.

3. Influence or seem to influence any of their decisions in the fulfillment of their duties and/or responsibilities.

4. They are oriented with corrupt purposes.

5. Correspond to cash or its equivalent in other negotiable or exchangeable instruments.

6. They are the means to expedite procedures, obtain benefits or retain business.

7. They constitute some form of tip or reward for a function or management performed.

8. Could negatively impact the Company's reputation. All those situations that are outside the described guidelines must receive prior approval from the General Directorate.

Remunerations and payment of commissions to Employees .

The Company has defined a Remuneration Policy which contemplates the guidelines of salary equity and competitiveness in order to promote the productivity and sustainability of the organization in line with the corporate strategy. This policy is applicable to all workers of the subsidiaries (if any) of COMERCIALIZADORA VIKINGOS regardless of the type of employment contract they have.

Expenses related to entertainment, food, lodging and travel activities .

The expenses for food, lodging and travel of the collaborators must be due to the fulfillment of the activities and functions of the position. In this sense, they will be governed in accordance with the guidelines established in the Company's Expense Policy.

political contributions .

A political contribution is any economic assistance, even if it is not in cash, in favor of a candidate or a public office or political party, including special discounts or differential rates not offered to the general public. The Company, through its representatives, may not make contributions to political campaigns, either directly or indirectly, by making payments, promising to pay, or offering anything of value (whether in cash or not), to candidates for public office, political parties or officials of political parties, or to any other organization or person connected with an election for political office. It is not allowed to carry out political events or campaigns within the company.

The donations .

All donations must have a verifiable purpose and be carried out in compliance with the process defined by the Company and the Anti-Corruption and Anti-Bribery Policy. All donations made must be supported by the Certificate of Donation, Delivery Certificates or Corporate Agreements. Likewise, they must be registered in the accounting accounts that correspond to this item.

It is prohibited to make or give any type of donation to a National or Foreign public official with the intention of influencing any act or omission with a corrupt purpose of obtaining an inappropriate advantage.

Facilitation Payments .

The Company will not use intermediaries or third parties to make inappropriate payments. Facilitation payments are prohibited. Such payments will not be made to public officials, even if it is common practice in a given country.

Regardless of whether such payments can be authorized under the regulations of different countries.

Filing procedures, conservation and control of documents and accounting records related to Businesses or International Transactions

COMERCIALIZADORA VIKINGOS, adhering to good practices and regulations, must prepare and maintain books, records and accounts that give an exact and faithful account of the transactions with reasonable detail. As well as designing and maintaining a system of internal accounting controls sufficient to provide reasonable assurance that transactions are properly authorized, executed and recorded. In such a way that they allow the evaluating entity of the system to verify the accuracy of the accounting and ensure that, in the transfers of money or other goods, direct or indirect payments related to bribes, gifts, kickbacks or other corrupt behaviors are not hidden. Thus, falsifying the books and records is strictly prohibited by this Policy. Company Representatives must never make false or misleading statements in any Company records or to anyone about the Company's financial and other business activities.

Documents and records related to compliance with C/ST prevention regulations will be kept within the Company's file for 5 years, after which they will be kept in the historical file for a minimum of five (5) years in physical and/or or digital, for a total of 10 years. Each area of ​​the Company will be responsible for the custody and conservation of each record related to its own activities established in this manual, and will be subject to the document management provisions that the Company has.

Agreements or contracts with third parties.

All contracts or agreements entered into by the Company must contain clauses, declarations or guarantees regarding anti-bribery and anti-corruption conduct, including the declaration of knowledge of this program, its sanctions and the applicable anti-corruption laws and regulations. The legal area or whoever acts in its place must be responsible for including said clauses in all contracts or, failing that, the revision of contracts that are close by third parties so that they contain said clauses. In any case, the person in charge of the negotiation must ensure that the clauses are included before signing the contracts or agreements, if they are not observed they must request them from the aforementioned areas.

Sanctions for violating the Anti-Corruption and Anti-Bribery Policy .

Collaborators who fail to comply with the provisions of the PTEE will be subject to internal disciplinary actions, with a decision to terminate labor contracts for just cause, in accordance with current labor legislation in the country where the collaborator is hired and criminal sanctions in accordance with the applicable law for each case.

Responsibility for denouncing acts of Corruption and/or transnational bribery .

The Company, its administrators, partners and collaborators encourage internal and external reporting of C/ST acts and/or irregularities that violate good conduct and compliance with the Company's transparency program policies. The Company will not tolerate retaliation against anyone who reports such concerns in good faith. However, it is unacceptable and it is considered a violation of this Policy to make a report or provide information knowing that such information is false or malicious.

Update and publication .

This Compliance Policy and the PTEE will be updated at least once every two (2) years and/or every time there are regulatory changes or in the Company's activity that alter or may alter its degree of C Risk. /st. The company, in order to make it easier for its Contractors, collaborators and Shareholders to have access, know and are trained on the Compliance Policies and the PTEE has documented and published these documents in corporate communication media and its official website. Any change will be communicated to all Collaborators, as well as to the interest groups to which it occurs. In the same way, the Company will translate the PTEE and the Anti-Corruption and Anti-Bribery Policy into the official languages ​​of the countries where International Business or Transactions are carried out or activities are carried out through Subsidiary Companies, branches or other establishments, or even Contractors in other jurisdictions. , when the language is not Spanish.

Related documents

• Circular 100-000011 of August 9, 2021.
• Remuneration policy.
• Policy for the treatment and protection of personal data of COMERCIALIZADORA VIKINGOS.
• Expense Policy.
• Policy for the treatment and protection of personal data

VERSION

DATE

REASON FOR UPDATE

1

05/30/2023

Phase 1 of Creation of the document, guided by Circular 100-000011 of August 9, 2021

ELABORATED

REVISED

Maria del Carmen Carmona

Claudia Cristina Carmona