Conduct Code

The Colombian Procurement Professionals' Association (ACOPC) is a Private, non-profit Civil Entity, duly registered before the respective Colombian authorities, and is subject to scrutiny, inspection and control by the corresponding Control Entities.

Founded in 2017, the Association's primary objective is to achieve the professionalization of the Supply / Procurement discipline and of all the people, professionals or technicians, who exercise it.

This Code of Conduct ("Code") establishes the expectations that ACOPC has for its members, associates, vendors, suppliers, contractors and others with whom ACOPC relates commercially (collectively referred to as the "Entities") regarding health, ethical, social and environmentally responsible practices.

For ACOPC, carrying out its activities with high ethical standards is essential. Within this framework, we have formalized this Code of Conduct to shape our expectations of those with whom we carry out operational and trade activities, including the activities of our Entities. ACOPC recognizes that the Entities operate in different legal and cultural environments. However, this Code establishes the minimum requirements that the Entities must meet to carry out activities with ACOPC. To comply with these requirements, Entities must communicate the principles of this Code to all interested persons 7 stakeholders.

In order to defend this fundamental priority, ACOPC reserves the right to carry out the controls it deems necessary to ensure that this Code is respected in all carried out processes. This may include self-assessments and audits of Entities, performed by ACOPC or by third parties. The ACOPC does not ignore that the Entities may need time to correct those areas where the Code is not yet being complied with. However, we believe that this compliance can be achieved through a process of continuous improvement over a period of time. Considering this, ACOPC invites its Entities to keep us regularly informed about their actions and improvement plans in relation to the Code of Conduct and welcomes any initiative by them to exceed the established minimums.

In case of any serious contraventions to this Code of Conduct, ACOPC reserves the right to make the respective complaints and / or apply the corresponding sanctions, as permitted by current legislation.

BUSINESS INTEGRITY

ACOPC is committed to the highest standards of business integrity. We do not tolerate any practice contrary to the principles of honesty, integrity, transparency and justice, wherever we do our activities. ACOPC seeks to identify the Entities that manage their businesses with ethical standards in line with ours. The ethical standards of ACOPC are reflected in our Statement of Business Integrity, which states in part:

• Obey all relevant laws and regulations

• Treat others fairly, with dignity and respect

• Perform all records of financial transactions with care and accuracy

• Report financial conditions and operations results, in an honest and timely manner

• Honest and fair treatment with customers, suppliers, consumers, Entities and financial partners

• Avoid conflicts of interest, real and potential

• Avoid giving and / or receiving gifts that do not apply

• Protect ACOPC's assets

• Protect ACOPC's confidential and proprietary information

• Protect ACOPC's reputation

• Separate personal political activities from ACOPC's activities

• Report any violation of applicable laws and regulations and ethical standards

• Entities must not engage in acts of unfair competition or bribes of any kind

FUNDAMENTAL RIGHTS AT WORK

ACOPC is committed to respecting human rights wherever it is present. We will make this commitment effective by working to implement and reinforce best practices and procedures in order to avoid, mitigate and, when necessary, correct the negative effects on human rights that may derive directly from our operations or that are directly related to our activities through our relations with the Entities. Our commitment, as well as the practices and procedures to apply it, are documented in international instruments, including the Universal Declaration of Human Rights, the ILO Declaration (International Labor Office) on fundamental principles and rights at work, and the UN Guiding Principles on business and human rights. We expect our Entities to carry out their activities in a manner that respects human rights and is consistent with the principles set forth below.

ELIMINATION OF FORCED OR MANDATORY WORK

Entities should not resort to slavery, servitude or involuntary forced labor. Entities must ensure that the work is done voluntarily, in exchange for legal compensation, and that it is not subject to a criminal sanction or actual or potential prosecution, violence, confinement, retention of identity documents, or loss of privileges or legal rights. Workers must have the freedom to access employment and leave it at any time, with prior notice in advance in accordance with the provisions of laws and regulations, collective agreements and applicable operational restrictions. The Entities should not allow forced labor induced by debts, which is that employers or hiring officers grant loans or advances to an employee or employee who will be reimbursed with their work or that of any member of their family.

EFFECTIVE ABOLITION OF CHILD LABOR

Entities are prohibited from employing workers who are not of legal age to work in any country or local jurisdiction where the Entity conducts activities for ACOPC. If the minimum age of employment has not been defined somewhere, then the minimum age for employment will be set at 16 years old. Without prejudice to the legal minimum age to work, in cases where minors are authorized to work, we expect from our Entities to respect all legal requirements, especially those related to working hours, remuneration, minimum education and working conditions. Entities must establish and respect clear age limits for tasks that may be dangerous or harmful to young workers from a psychological, physical, social or moral point of view. "Young worker" means one who exceeds the legal minimum age, as previously defined, but is under 18 years old.

ELIMINATION OF DISCRIMINATION IN EMPLOYMENT AND OCCUPATION

Entities must not discriminate against employees in terms of hiring, promotion, remuneration, evaluation of results or any other term or condition of work, based on race, color, national origin, gender, identity, sexual orientation, religion, physical impairment, or based on any other discrimination prohibited by applicable laws and regulations.

FREEDOM OF ASSOCIATION AND EFFECTIVE RECOGNITION OF THE COLLECTIVE NEGOTIATION LAW

Entities must respect the right of their workers to join or not join the union they choose and collective conditions negotiation, without retaliation, intimidation or harassment. Workers should not be subject to intimidation or harassment in the exercise of their right to join or not join any labor organization / union.

REMUNERATION AND BENEFITS

Entities should not pay remuneration under the minimum wage in accordance with applicable laws and regulations. In the event that there is no minimum remuneration established by law or regulations, the Entities will pay at least the usual market remuneration. Entities must ensure that workers are paid for overtime performed according to the special conditions established by law, that they are not forced to work overtime to earn the minimum wage and that they receive all the benefits and insurance provided by applicable laws or regulations.

WORK HOURS

Entities must comply with all applicable laws and regulations regarding the working hours of their workers, including the maximum time limit and established work breaks. Entities should not, on a regular and scheduled basis, ask employees to work above the legal overtime thresholds, unless otherwise provided by law according to the nature of the work.

HEALTH AND SAFETY

Health and safety are a fundamental part of ACOPC'S mission. ACOPC is committed to achieving a culture of health and safety and optimal results in this regard. The commitment of our Entities is essential for us to continually improve until we reach this goal. Entities must provide their employees with a safe and healthy place and working conditions. Health, safety and other aspects of the workplace must comply, at a minimum, with all applicable laws and regulations. The Entities must adopt and maintain in force, at their expense, a compensation plan for occupational accidents, whether public or private (such as labor insurance), as stipulated by applicable laws and regulations, for all employees who provide or make products or services for ACOPC.

DISCIPLINARY PRACTICES

Entities should treat all their workers with dignity, and should not inflict or threaten to inflict corporal punishment or any other form of physical, sexual, psychological or verbal abuse or harassment to any employee. Entities must have a clear disciplinary process that prohibits violence, harassment and intimidation in any of their physical or emotional forms, and communicate it in a language that is understandable to employees.

ENVIRONMENT

Entities must comply with all applicable environmental laws and regulations. Entities must work to continuously improve their environmental protection measures, for example by implementing an environmental improvement program or action plan. Entities must work to sustain, protect and restore the environment, using means such as energy saving, recycling or proper disposal of waste and water management, as well as environmental recovery.

IMPLEMENTATION

Entities must take the correct measures to ensure that the principles of this Code are communicated to their employees and collaborators. Entities must establish the processes or mechanisms necessary for employees to raise issues that concern them without fear of reprisals or negative repercussions. ACOPC reserves the right to carry out the controls it deems necessary in order to ensure compliance with this Code. This may include self-assessments and audits of Entities conducted by ACOPC or by third parties. In the future, it will be necessary to establish a system of reports on the relevant actions carried out by each Supplier within the scope of its own operations. This Code will be updated periodically to keep it in force based on feedback from internal and external stakeholders.