Code of Ethics and Conduct

1. INTRODUCTION:

The General Management of Alvilla S.A.S., considering that it is essential for Alvilla S.A.S. to establish policies that enable the achievement of business objectives of the company, complying with ethical principles within the framework of the law, adopts and updates this Code of Ethics and Conduct, which includes policies and values that are subject to legal standards and principles that support sound business and industrial practice.

2. FIELD OF APPLICATION:

The rules set out in this Code are mandatory for all employees of Alvilla S.A.S. and all those who have no contractual relationship with the company perform functions of the company; all of them will put these values and principles to any other consideration of commercial or budgetary nature, it is clear that Alvilla S. A.S. aims to achieve the development of its corporate purpose, within the framework of the law, the application of sound business practices and prudence that should guide the culture of management of the different risks of the company (the company), within the framework of the law.A.S. aims to achieve the development of its corporate purpose, within the framework of the law, the application of sound business practices and prudence that should guide the culture of management of the various risks of the company (SARLAFT). Thus, the policies and rules contained herein prevail and guide the procedures and other determinations adopted by the company in the development of its corporate purpose.

CORPORATE VALUES:

• Commitment: In Alvilla S.A.S. we identify with our company and therefore we feel an integral part of its success. We are loyal to our work, our colleagues and our customers. The pride we feel in belonging to this company encourages us and motivates us to be better every day.
• Efficiency: In Alvilla S.A.S. we use optimally and intelligently all available resources in an agile and quality way, to offer our customers solutions that generate value and to achieve the proposed goals.
• Honesty: In Alvilla S.A.S. we act ethically and responsibly, generating security and confidence in our customers and ensuring the fulfillment of our work and personal achievements.
• Leadership: At Alvilla S.A.S. we work with an enthusiastic and winning attitude. We prepare ourselves every day to anticipate the needs of our customers, generating their preference to ensure our leadership.
• Respect: In Alvilla S.A.S. we value ourselves as people and accept each other in our integrity. We understand the differences and individualities so that they translate into understanding and tolerance in our interpersonal relationships and with our customers.
• Service: In Alvilla S.A.S. we know that service is a principle of life, our actions reflect our commitment to provide our customers with quality service, agile and timely, with a friendly and cordial attitude, allowing us to anticipate their needs and provide solutions that generate value.

4. GUIDING PRINCIPLE:

The company's operations and business must be framed and conducted within ethical standards, placing sound business practices before the achievement of commercial goals.

5. GENERAL PRINCIPLES OF BEHAVIOR:

• Compliance with Standards: The standards¹The standards of this Code contribute to maintaining ethical principles and values, as a guide for the activities that the company develops in its work of supplying goods and services, based on compliance with legal standards.
• Sound Business Practices: Sound business practices relate to compliance with legal regulations, prudent management of assets and public confidence, and the development of the company's operations within acceptable risk margins.
• Accounting Principle: The operations carried out in the company must comply with the procedures set forth in the manuals, be duly documented and recorded, and the support of the documents and files must be kept for the term established by law.
• Good Care and Information: All employees of Alvilla S.A.S. must perform their duties with responsibility, common sense and prudence, taking care to protect the assets that the company owns or those managed by third parties. Likewise, they must report promptly to the superior or the appropriate level of the company, the facts or problems that hinder the activities or pose a risk to the company.
• All company employees are obliged to inform their superiors of any abnormality they observe or detect in the behavior of their bosses, colleagues, customers or third parties that threatens the interests of the company or its customers.
• Consultation and Updating: This Code is complemented by other codes, manuals, policies, programs and specific operating processes, such as, Internal Work Regulations, Risk Manuals and all other manuals, circulars or instructions adopted by the company, compliance with which is equally mandatory. It is the function of each of those obliged to comply with this Code to consult and keep themselves updated on the internal regulations in force.

6. PRINCIPLES RELATED TO SARLAFT

The purpose of the Asset Laundering and Terrorist Financing Risk Management System, hereinafter SARLAFT, is to prevent the company from being used to give the appearance of legality to assets of illicit origin or to channel resources destined for terrorist activities.

• SARLAFT Culture: It is a principle of the company to promote the SARLAFT culture. Thus, from the moment collaborators are hired, they are trained so that in the different processes developed by the company, the Asset Laundering and Terrorist Financing Risk Management System is applied.
• Observation, Surveillance and Control of SARLAFT: The Legal Coordinator, the company's General Management and the Administrative Management, and in general, all the company's collaborators, shall ensure the proper functioning of SARLAFT.
• Compliance with Laws and Policies: Alvilla S.A.S. and each of its employees will ensure compliance with laws, decrees, circulars, regulations, policies and controls adopted by the authorities and the company within the SARLAFT, in order to achieve the development of the institutional objectives of the company.
• Prevention and Control: SARLAFT consists of two phases: the first, which corresponds to risk prevention and whose objective is to prevent the introduction into the financial system of resources originating from illicit activities; the second, which corresponds to control and whose purpose is to detect operations that are intended to be carried out or have been carried out in an attempt to give the appearance of legality to operations linked to illicit activities.
• Collaboration and Compliance with the Recommendations of International Organizations: The company and its collaborators shall take into account, within the development of their functions, the OFAC and UN programs, as well as their recommendations, which shall be taken into account within the SARLAFT.
• Responsibility with the Company: Since money laundering involves assets of illicit origin, employees will make their best effort to prevent assets from any illegal activity from being handled through the company.
  Likewise, since the financing of terrorism is carried out with funds of licit and illicit origin, the company's employees will carry out prevention and control tasks on the destination of the money.
• Policies for the General Manager: The General Management is the body in charge of issuing SARLAFT policies in the company, consequently, the General Manager shall apply the principles outlined in this Code, in each of the activities they develop.
• Policies for Administrators: The company's administrators shall act and develop the corporate purpose of the company in accordance with the law, the bylaws and the policies set forth in this Code, which has been adopted by the General Management of the company, complying with the functions established through the rules that deal with SARLAFT.
• Policies for Customer Engagement: The company's policies are aimed at the knowledge of current and potential customers. Therefore, these rules are based on the Principle of Autonomy of Contractual Freedom and Knowledge of the client, whose application implies the verification of the data that allow the individualization of the natural or legal person; to know, in addition, its economic activity, the characteristics, amounts and origin of its income and expenses and its operations.
  Any person, whether natural or legal, wishing to join the company is required to provide reasonable information and documents to evaluate the economic solvency and legality of its activities or business. If there is any doubt in this regard, no matter how good the economic perspective offered by the company in terms of business possibilities and reciprocity, the operation, the supply of goods, the provision of services or the continuity of its business with the company will be declined.
  In the development of the principle of contractual autonomy, the company shall be free to accept or not to accept the engagement of customers who are not of its commercial objective, those who do not comply with the parameters established for their entry to the company or who, within the SARLAFT, are considered to represent an unacceptable risk for the company.
  The contract entered into with the potential customer shall only be deemed to be perfected and therefore the contract shall be effective for the parties, until the binding process has been properly complied with, namely:
  
  • Completion of the Alvilla S.A.S. Customer Registration Form.
  • Completion of the Customer Acknowledgment Form for Natural Person/Legal Entity in force.
  • Review of the format and documentation by the collaborator.
  • Confirmation of information.
  • Approval of customer bonding.
  • Consultation of OFAC and UN programs.
  • Conduct a face-to-face interview or visit to the client.
  • Minimum documentation required, attached by the customer for your knowledge.

Once these aspects are fulfilled, the contractual relationship shall commence.

• Publicly Exposed Persons (PEP): The definition of the national legislation and the FATF definition shall be taken into account, and the criteria for persons in any of the situations indicated in these standards shall be applied, such as:
  
  • Management of public resources: included in this category are persons who directly or indirectly are responsible for the management of resources of public origin. For example, directors of public entities, state contractors, governors, mayors, treasurers, among others.
  • Holding some degree of public power: this category includes people who have a level of influence over political decisions or strategies that impact society. These persons may or may not be directly or indirectly related to the public sector. For example, governors, mayors, diplomats, notaries, directors of trade unions, social or religious leaders with political influence, union leaders, among others.
  • Public recognition: a person is considered to enjoy public recognition when he/she is easily identified and associated with an economic and social profile at a national level. This includes singers, actors, sportsmen, broadcasters, ministers, important businessmen, among others.
  • The FATF defines a PEP as a "politically exposed person", which includes individuals who perform or have performed prominent public functions, extending it to their family members or close associates, due to the reputational and contagion risk they represent. Therefore, these persons must also be classified as PEP.
    These links may only be made with the express approval of the Manager; these accounts may only be constituted after completion of the internal procedure.

• Policies for the Supply of Goods and Services to Individuals and Legal Entities, National or Foreign: For the supply of goods and/or services, a prior consultation of the information of each client will be made, in order to verify that they are not included in the executive orders issued by OFAC, UN and other agencies, as well as to establish the origin of the resources, according to the supports provided.
• Collaboration with the Authorities: The company will collaborate with the Attorney General's Office and any other competent authority, in sending the legally requested information.
• Reservation of Reported Information: All employees who, in the performance of their duties, become aware of unusual or suspicious transaction reports, have the legal obligation to keep such information confidential and, consequently, may not disclose to persons who have carried out or intend to carry out unusual or suspicious transactions, that has been reported to the General Management or to the Financial Information and Analysis Unit UIAF, under penalty of incurring administrative sanctions or being linked to criminal proceedings, considering the conduct as collaborating or complicity with the perpetrator according to the Law, or to disciplinary sanctions.
  General Guidelines on Risk Factors and Risks Associated with ML/FT: Alvilla S.A.S. will use all the mechanisms, elements and instruments at its disposal to mitigate the exposure to ML / FT risk in the development of its corporate purpose arising from the relationship with the different risk factors and associated risks.
  
  For this purpose, it will take into account that the risk factors are the agents generating ML/FT risk, including: customers/users, products, distribution channels and jurisdictions.
  
  On the other hand, the associated risks are the risks through which the ML/FT risk materializes, among which are included:
  
  • Reputational risk: The probability of loss incurred by an entity due to loss of prestige, bad image, negative publicity, whether true or not, with respect to the company and its business practices, causing loss of customers, decrease in revenues or legal proceedings.
  • Legal risk: The possibility of loss incurred by an entity when it is sanctioned, fined or obliged to compensate damages as a result of noncompliance with rules or regulations and contractual obligations. It also arises as a consequence of failures in contracts and transactions derived from malicious actions, negligence or involuntary acts that affect the formalization or execution of contracts or transactions.
  • Operating risk: The possibility of incurring losses due to deficiencies, failures or inadequacies in human resources, processes, technology, infrastructure or the occurrence of external events. This definition includes legal and reputational risks associated with such factors.
  • Contagion risk: The possibility of loss that an entity may suffer, directly or indirectly, from an action or experience of a related party or associate. The related party or associate includes natural or legal persons that have the possibility of exercising influence over the entity.
    

7. ANTI-FRAUD AND ANTI-CORRUPTION POLICY

Fraud and corruption constitute a reputational risk for Alvilla S.A.S., and may affect not only its image, but also the trust of employees, investors, suppliers, customers, shareholders and in general the business scenario. Aware of these consequences, the company is committed to the highest ethical standards in the interrelations with its stakeholders and compliance with laws. In response to this commitment, Alvilla S.A.S. has implemented the Anti-Fraud and Anti-Corruption Policy that seeks institutional strengthening, in order to mitigate the risk of fraud and corruption, and thus close the doors to crime, through a strategy aimed primarily at control, through prevention, training, awareness and deterrence of the occurrence of these events, as well as monitoring and management of alerts for detection.

The Anti-Fraud and Anti-Corruption Policy is aligned with international regulations, practices and standards on programs and controls, in order to facilitate the management of fraud and corruption events and support Alvilla S.A.S. in achieving its operational, financial and compliance objectives. Under this framework, the policy includes the components of control environment, risk assessment, control activities, information and communication and monitoring activities.

The guidelines and definitions of this policy apply to all processes and sub-processes of the company; therefore, it is of competence and mandatory application for all employees of the company. In certain circumstances it applies to suppliers, customers and contractors, when so agreed or agreed.

The main objective of the Anti-Fraud and Anti-Corruption Policy is to integrate the elements or components of an anti-fraud and anti-corruption program to prevent and manage fraud and corruption events in Alvilla S.A.S. Compliance and monitoring of the Anti-Fraud and Anti-Corruption Policy directs and promotes the principles and values promulgated in relation to business ethics and related corporate or specific policies.

Likewise, the Anti-Fraud and Anti-Corruption Policy seeks to:

1. Promote an ethical culture within Alvilla S.A.S. aimed at mitigating the risks of fraud or corruption.
2. Integrate the elements of an anti-fraud program as general guidelines.
3. Establish the guidelines of the mechanisms to detect, investigate and remedy effectively and timely the events of fraud or corruption in Alvilla S.A.S.
4. Address the framework for mitigating fraud or corruption risks through an effective and timely process of identification, assessment and implementation of anti-fraud controls.

• Personnel Selection: Within the framework of the Anti-Fraud and Anti-Corruption Policy, Alvilla S.A.S. has selection and hiring procedures, through which it seeks to attract and retain the best talent with the personal, intellectual and professional conditions required to achieve its strategic objectives, striving for transparency and objectivity of such processes, and performs them without any discrimination or pressure on candidates.
  
• Protection of Company Assets: Alvilla S.A.S. has an asset protection guideline that seeks the appropriate use of all tangible and intangible assets of the company, according to the roles and responsibilities of each employee. The policy also seeks to protect the company's assets against loss, theft, abuse or unauthorized use.
  
  The information security guideline states that the information can only be accessed by employees, shareholders, customers, third parties (including suppliers and contractors), control entities and related entities, according to their roles and responsibilities, have a legitimate business need.
  
• Alvilla S.A.S. has established guidelines for contracting and purchasing, through which the minimum requirements to enter into a contract or service order with a third party are detailed, including suitability, ethical and legal conditions, in accordance with internal policies.
  
  In order to mitigate the risks of fraud and corruption posed by third parties, the company includes the following clauses in its contracts:
  
  • Anti-bribery and anti-corruption commitment: The parties declare to be aware that in accordance with local and international anti-corruption and anti-bribery provisions, it is prohibited to pay, promise or authorize the direct or indirect payment of money or any other item of value to any public servant or government official, political party, candidate or any person acting on behalf of a public entity when such payment involves the corrupt intent to obtain, retain or direct business to any person to obtain an illicit advantage ("Public Sector Anti-Bribery and Anti-Corruption Rules"). Likewise, the parties recognize the existence of similar regulation on bribery in the private sector, understood as the bribery of any private person or private company to obtain an undue advantage ("Private Sector Anti-Bribery and Anti-Corruption Rules" and together with the "Public Sector Anti-Bribery and Anti-Corruption Rules").
  • In consideration of the foregoing, the parties undertake to know and abide by the Anti-Bribery and Anti-Corruption Rules and to refrain from any conduct that violates such Anti-Bribery and Anti-Corruption Rules at the local or international level. Failure to comply with the obligation contained in this clause shall constitute grounds for immediate termination of this agreement without any cause for default and without any indemnification whatsoever.
  • Right to unilaterally and immediately terminate the contract if there is suspicion of fraudulent or corrupt conduct by a third party, such as the payment of bribes or violation of the terms of the contract.

These guidelines seek to ensure that all transactions and contractual conditions established between Alvilla S.A.S. and its third parties, are made in compliance with the
provisions and regulations in force and likewise that the contractual terms specifically detail the services to be provided.

• Alvilla S.A.S. is aware of the importance of reporting identified incidents of fraud and corruption. An unreported fraud or corruption event may represent a cost even greater than the event itself. It is for this reason that Alvilla S.A.S. has implemented the ethics line, a mechanism through which its employees can communicate or report such events, using the following means:
  
  
  • Legal Coordination telephone number 601 3700088 extension 129.
  • Written communication addressed to the Legal Coordination of Alvilla S.A.S., calle 10 N° 32A-12 in Bogotá.
  • E-mail: federico.bonilla@alvilla.com.

Alvilla S.A.S. understands that all employees have an obligation to communicate or report an event of fraud or corruption involving a superior.
co-worker and / or third party. Through the mechanisms provided, any employee who reports or wants to report an event of fraud, corruption or unethical conduct
, shall have the right to do so anonymously and confidentially. The identity of the employee reporting the event, if established, along with the information and
evidence provided in the report, will be kept confidential.

• Reportable Conduct: Below are included, by type of fraud, some actions that may constitute fraud and/or corruption in Alvilla S.A.S. and therefore should be reported. It is clarified that this list is not exhaustive and does not limit the existence of any other fraudulent, corrupt, dishonest conduct or conduct that goes against the interests of the company:
  
  • Taking money or assets improperly or without authorization.
  • Diverting funds from a company account for personal benefit or for the benefit of a third party.
  • Obtain money from Alvilla S.A.S. or its subsidiaries by deception or dishonesty, by means of a fictitious expense statement.
  • Improper use of petty cash funds.
  • To obtain a benefit, aid or contribution by deception.
  • Falsifying or altering any type of document or record.
  • Abusive use or theft of company assets.
  • Making duplicate or unauthorized payments or incurring expenses that are not supported by formal documents.
  • Improper handling of cash surpluses.
  • Improper handling or use of the company's information assets for personal benefit or for the benefit of a third party.
  • Improperly altering or manipulating income and/or expense accounts to reflect performance that does not correspond to reality.
  • Making accounting records in inappropriate periods.
  • Inappropriately valuing the company's assets.
  • Inappropriate disclosure of information in the financial statements.
  • Making or omitting adjustments to the accounting records.
  • Intentionally concealing accounting errors.
  • Promise, offer or grant, directly or indirectly, to a third party an undue benefit that redounds to your own advantage, to that of another person or to that of the company.
  • Requesting or accepting, directly or indirectly, from a third party an undue advantage that benefits oneself, another person or the company.
  • Paying bribes to third parties (private or public)
  • Making contributions, in cash or in kind, to a political cause for the purpose of obtaining a commercial advantage.
  • To divert monies that have a social or sponsorship purpose.
  • Unlawfully altering a contractual procedure in a public, private or special solicitation process.
  • To favor, in the exercise of their functions, their own interests or those of a third party over the interests of the company.
  • Obtain, by any means whatsoever, a trade secret without the authorization of the company or its authorized user.
  • Selling, offering, disclosing or improperly using the company's trade and business secrets.
  • Altering, deleting or disabling computer programs or software.
  • Unauthorized copying, reproduction or distribution of computer programs or software.
  • Destroying, deleting, rendering useless or improperly using the Company's computer records.

• Principle of Anti - Retaliation Against Employees: Alvilla S.A.S. will seek to achieve protection against retaliation against an employee, officer or third party who communicates or reports an event of fraud or corruption, provides information in good faith about unethical conduct or cooperates with a duly authorized investigation.
  In case of retaliation, these would violate the fundamental obligation of all Alvilla S.A.S. personnel. to act with the utmost efficiency, competence and integrity, as well as to fulfill their duties and perform in the best interests of the company.
  
  To be eligible for protection, employees, officers or third parties must act in good faith and have reasonable grounds to believe that an event of fraud or corruption or unethical conduct has occurred, including, depending on the circumstances and to the extent possible, providing evidence or accurate information that leads them to conclude that there is unethical conduct, fraud or corruption contrary to the principles and values of the company. The transmission or dissemination of unsubstantiated rumors will not be protected. The communication of irregular or abnormal situations or the provision of deliberately false or misleading information will constitute unethical conduct and may be subject to administrative or disciplinary measures.
  
  Persons who believe they have been subjected to retaliation should communicate all information and documentation available directly to the General Management, the Administrative Management of Alvilla S.A.S. or the Legal Coordination through the mechanisms defined in paragraph 7.4 of this document.
  If it is established the existence of a reprisal against any person who has reported or reported an act of fraud, corruption or unethical conduct, Alvilla S.A.S. will take appropriate and necessary measures in order to remedy the negative consequences resulting from retaliation. The employee or manager who has exercised an act of retaliation, when an investigation shows its existence, may be subject to administrative or disciplinary measures, without prejudice to legal action where appropriate.
  

• Communication, Training and Education Plan: Aware that effective communication is a fundamental element for the implementation, internalization, maintenance and sustainability of an anti-fraud and anti-corruption program, Alvilla S.A.S. has developed an annual communications plan that seeks to promote and strengthen the anti-fraud and anti-corruption culture, in addition to making employees aware of the importance of preventing, communicating, reporting and detecting fraud and corruption.
  The communications plan includes internal campaigns, support material, written communications, e-mails, etc., highlighting the most relevant aspects of the anti-fraud program, its related guidelines and the importance of internal control.
  
  As part of the induction process for new employees and at least annually for former employees, training and/or updating on the anti-fraud program shall be conducted, which shall cover at least:
  
  • Alvilla S.A.S.'s commitment to fraud and corruption prevention.
  • The advantages of the anti-fraud program.
  • Events or conduct that may constitute fraud or corruption and must be reported.
  • Dissemination of the company's ethical line and the mechanisms through which a complaint can be made.
  • The harm of committing fraud or corruption, illegal acts or unethical conduct, and the disciplinary sanctions that this entails.

Training and coaching may be provided on an ongoing, virtual or face-to-face basis and selectively to Alvilla S.A.S. employees in order to
strengthen the concepts and ensure the continuity and sustainability of the anti-fraud program.

• Monitoring: There will be a periodic review of the objectives and components of the Anti-Fraud Program, including its Anti-Fraud and Anti-Corruption Policy or related guidelines, as well as a monitoring of the risks identified and the controls implemented in the different processes.
  The company's Internal Audit will periodically evaluate the Anti-Fraud and Anti-Corruption Policy, based on the effectiveness of the existing controls and the fraud or corruption events reported. Based on this assessment, an annual report will be submitted to the General Management.

• Research Process: The investigation mechanisms are designed to advance the necessary actions to clarify the possible events of fraud or corruption. Alvilla S.A.S. is committed to objectively investigate all events of fraud and corruption reported through the various mechanisms available and for this purpose will define criteria that will indicate the level of investigation thereof.
  
  The investigation process is the responsibility of the Administrative Management and may be carried out jointly with an independent third party or by whoever is internally designated, when so decided according to the criticality, circumstances, personnel involved, among other aspects.
  
  Investigations will remain confidential until such time as the result of the investigation is determined to be disclosed, reported and processed to the relevant internal and/or external authorities. Employees involved in the investigation process are obliged to keep the information confidential. The investigation process may require, among others, the following activities, as long as they do not go against the legal provisions of the Colombian legal system.
  
  • Interviews with collaborators or external persons.
  • Collection and analysis of documentation or evidence.
  • Review of telephone calls.
  • Inquiries with financial institutions.
  • Access to physical and magnetic files.
  • Inspection of funds, goods or assets.
  • Inquiries or interviews with law enforcement, regulatory or supervisory agencies.
  • Transaction analysis.

Once the responsibility of the collaborator has been established, the Administrative Management, through the corresponding areas, will determine the disciplinary sanctions applicable to the
collaborator, manager or third party that commits fraud or acts contrary to the provisions of this Policy and its related policies. The application of sanctions will be
Once the responsibility of the collaborator has been established, the Administrative Management, through the corresponding areas, will determine the disciplinary sanctions applicable to the
collaborator, manager or third party who commits fraud or acts contrary to the provisions of this Policy and its related policies. The application of sanctions will be

Alvilla S.A.S., where appropriate, will bring to the attention of the competent authorities any event of fraud or corruption and will undertake and accompany the actions
judicial that are relevant.

• Definitions: In order to clarify certain terms in this policy and to avoid inaccurate interpretations, this glossary is included:
  
  • Senior Management: Shareholders' Meeting and General Management.
  • Administration: General Management, Administrative Management, Process Management, Sales Management, Chief Accountant, Statutory Auditor, Legal Coordination.
  • Collaborator: Workers, workers on assignment, trainees and interns.
  • Thing of Value: Under the Foreign Corrupt Practices Act (FCPA), "anything of value" means, in addition to cash payments, travel and expense reimbursement, scholarships and sponsorships, gifts in kind, school scholarships, donations or contributions, favorable contracts, investment opportunities, stock options, joint venture positions and subcontracts. Under the Act, no amounts or amounts are stipulated in the definition of "thing of value".
  • Fraud: Dishonest activity or intentional or negligent omission designed to deceive others and generate a loss for the victim and/or a profit for the perpetrator. Fraud can be contextualized, depending on its sources, as internal, external or mixed fraud:
    
    • Internal fraud: Fraud carried out within the company.
    • External fraud: Fraud carried out by persons external to the company, such as suppliers, contractors, customers and third parties in general.
    • Mixed fraud: Fraud committed with the participation of internal and external actors.
      
  • Some of the main types of fraud are:
    
    • Asset misappropriation: Theft or misuse of assets.
    • Accounting Fraud: Intentional alteration, distortion or false presentation of accounts, accounting records and disclosures in such a way that they do not reflect the fair value or the real reason for the operations and transactions carried out.
    • Corruption: Dishonest activity in which a Director, Executive, Collaborator or Contractor acts against the interests of the company and abuses his position to obtain a benefit.
      
      • Bribery, act of offering or accepting anything of value, in money or in kind (attentions, gifts, products and services), with the corrupt purpose of obtaining a benefit in favor of oneself or a third party.
      • Conflict of Interest: Situations in which the integrity of an action leads the employee to have to decide between acting for the benefit of the entity or for his or her own benefit.
        
    • Intellectual Property Infringement

When reference is made to "fraud", it shall be understood to include all the modalities described above.

• Public Official : "Public official" means any person acting in an official capacity or under the authority of a government (national, departmental, municipal, both at centralized and decentralized levels) to perform governmental responsibilities on behalf of the government, agency, department, regulatory authority, or any government-owned or government-controlled commercial enterprise.

8. FSC COC ALVILLA S.A.S. POLICY OF FUNDAMENTAL LABOR REQUIREMENTS.

• ALVILLA S.A.S., in applying the FSC core labor requirements, pays due attention to the rights and obligations established by national laws, while complying with the objectives of the FSC requirements.
  
• ALVILLA S.A.S. does not use child labor, therefore:
  
  
  • ALVILLA S.A.S. does not hire persons under 18 years of age.
  • In case of operating in countries where the national legislation allows the hiring of workers between 13 and 15 years of age in light work, ALVILLA S.A.S. will maintain its policy of not hiring people under 18 years of age.
  • All forms of child labor are prohibited.
    
    
• ALVILLA S.A.S. avoids any form of forced or compulsory labor, therefore:
  
  
  • The labor relations between Alvilla S.A.S. and its employees are voluntary and based on mutual consent, without the threat of punishment.
  • ALVILLA S.A.S. avoids forced or compulsory labor practices, including, among others:
    
    
    • Physical or sexual violence;
      
      • Bonded labor;Withholding of wages/including payment of employment fees and/or payment of a deposit to begin work;Restriction of mobility/movement;Withholding of passport and identity documents;
      • Threats of denunciation to the authorities.
        
• ALVILLA S.A.S. takes care to avoid any type of discrimination in employment and occupation; the execution of the related activities is non-discriminatory.
  
• ALVILLA S.A.S. respects the freedom of association and the effective right to collective bargaining, therefore:
  
  • Workers may create or join workers' organizations of their choice.
  • It respects the full freedom of workers' organizations to draft their bylaws and rules.
  • It respects the rights of workers to engage in, or refrain from, lawful activities related to the establishment, affiliation or attendance of workers' organization and does not discriminate against or punish workers for exercising these rights.
  • Negotiates with legally established workers' organizations and/or their elected representatives in good faith and making every effort to reach such a collective bargaining agreement.
  • Collective bargaining agreements are implemented, whenever they exist.

9. CONFLICTS OF INTEREST

Alvilla S.A.S. has a conflict of interest guideline designed to protect the interests of the company, help management and its employees to achieve high ethical standards and trust and prevent them from being in situations of this type.

In order to prevent the company's employees from becoming involved in situations that generate incompatible interests, none of which may be privileged in view of their legal or contractual obligations, the following are the main rules that must be applied by all company employees and the policies that, if violated, will result in disciplinary sanctions for the employee.

• Definition of Conflict of Interest: A conflict of interest is understood as any situation or event in which the personal interests, direct or indirect, of the Administrators or Collaborators of the company, are in opposition to those of the company, interfere with the duties incumbent upon them, or lead them to act in their performance for motivations other than the correct and loyal fulfillment of their responsibilities, affecting the impartiality that should govern all our actions in the development of the corporate purpose of the company.
• General Policies Related to Conflicts of Interest: The following is a definition of the policies that the Company's Administrators and Employees must abide by to avoid the configuration of situations of conflicts of interest:
  
  • It is company policy to prevent, eliminate and overcome any conflict of interest that may arise in the development of the financial activity in the ordinary course of business. Therefore, under penalty of incurring the penalties provided by law and in the Internal Work Regulations, all Directors and/or Employees with access to privileged information have the legal duty to refrain from carrying out any operation that may give rise to a conflict of interest. Should a conflict of interest arise, the mechanisms provided by the Superintendence of Corporations to remedy it, as well as the qualification made by said control entity, shall be complied with. Likewise, the guidelines established in the Internal Work Regulations and in this Code of Ethics and Conduct shall be complied with.
  • It is the responsibility of the directors, legal representatives, statutory auditors and in general all collaborators to act under the principles of loyalty, integrity, impartiality, objectivity and competence in the performance of their duties.
  • Directors, legal representatives, statutory auditors and in general all employees must use their time outside the company in activities that do not promote or tolerate a conflict of interest to the detriment of the company's interests or impair the proper development of the company's business purpose or its good name.
  • The employees of the company, on the occasion and in the performance of their duties, may NOT offer, request, or accept gratuities, commissions or any other form of personal remuneration from third parties or interested parties, except the compensation plan or promotions authorized by the company; to achieve or not, the realization of business involving the company, except for awards in cash or kind that the company itself gives on the occasion of the efficient performance as a collaborator of Alvilla SA S.A.S.
  • Exceptionally, they may receive gifts, hospitality or gratuities provided that the following conditions are met:
    
    • Do not exceed 5% of the value of the salary of the executive or collaborator who receives it, and without such amount exceeding two legal monthly minimum wages in force.
    • Promotional gifts such as umbrellas, caps, pens, calendars, etc., that are representative of Alvilla S.A.S. or the companies with which the company has business or could have business.
    • Invitations to events related to the purpose of the business.
    • That the gifts or hospitality are not inappropriately intended to influence the employee's performance of his or her duties.
    • Gifts and invitations received by employees on occasion and in the performance of their duties, outside the socially customary, that exceed the aforementioned value, whose value is not determined or is impossible to determine, or if there is any doubt as to whether or not to receive it, must be reported to their immediate superior, who will inform the General Management, the Administrative Director or the Legal Coordinator.
      
  • Alvilla S.A.S. prohibits employees, managers and members close to their families up to the second degree of consanguinity, first degree of affinity or first civil, request or receive money, bonuses, fees, commissions, advances, travel allowances, checks, debit cards, securities or any other document that can be convertible into money, from a person, corporation or society with which the company has business or with which it could have business with the purpose of or as consideration for the performance or omission of any activity or control that means a break or imbalance to the company's policies.
  • It is forbidden for all company employees to manage, through a contractual relationship, the personal business of customers or suppliers of the company that involve a conflict of interest.
  • The company's employees may not be counterparties or representatives of clients before the company and, consequently, are forbidden to carry out transactions on behalf of them.
  • Employees are not allowed to use their site and work elements to manage or promote business on a personal basis or for the benefit of third parties.
  • It is forbidden, without exception, for its Directors and collaborators to make any kind of public or political contribution or to support electoral initiatives of any kind on behalf of the company.
  • It is forbidden for employees to offer products or services that have not been authorized by the company or that are not in their portfolios.
  • In order not to generate any commitment of a personal nature with customers, suppliers or third parties related to the company, it is forbidden to request or remunerate favors to them.
  • No employee who has access to company information may reproduce, exploit, copy or disclose it for purposes other than those established in the functions he/she performs.
  • Shareholders, administrators and collaborators, in the development of their duty of collaboration for the achievement of the corporate purpose of the company, shall be obliged to act with loyalty and in the event of a possible conflict of interest with the company, they shall act giving priority to the interests that benefit the company, rather than their own interests.
  • Except for academic activities and in order to promote integrity for the services provided to the company, Alvilla S.A.S. does not allow its employees to have employment contracts with other entities or companies, which develop similar functions to those performed in the company or affect their performance.
    
  • Public or Political Contributions: Alvilla S.A.S., in compliance with local and international anti-fraud and anti-corruption regulations, prohibits making or giving any type of donation or contribution to a national or foreign public official, influencing any act or omission, with the corrupt purpose of helping the company to obtain an improper advantage.
    
    Additionally, the company prohibits without exception to its employees to perform on behalf of Alvilla S.A.S., or on its own behalf with company resources, or in search of benefits for the company, any kind of political contribution or any kind of support for electoral initiatives.
    
    Similarly, employees are prohibited from engaging in political activism within the company's facilities or during working hours.
    
• Procedure for Resolving Conflicts of Interest: All directors, administrators and collaborators who are faced with a conflict of interest or consider that they may be faced with one, must report the situation in writing to their hierarchical superior, providing all relevant information, who in turn will inform the Administrative Management or, failing that, the General Management.
  
  • Conflict of Interest Resolution for Employees: When employees report a conflict of interest situation through their hierarchical superior, each case will be particularly evaluated by the Administrative Management or, failing that, by the General Management, which will determine the actions to be taken.
  • Resolution of Conflicts of Interest between a Director or Administrator: When a director or administrator is in a situation involving a conflict of interest with respect to the company, he/she shall request that a Shareholders' Meeting be called to present his/her case and shall provide that corporate body with all the information relevant to the decision to be made. The vote of the director or administrator must be excluded from the respective decision. In any case, the authorization of the Assembly may only be granted when the act does not harm the interests of the company.
  • Resolution of Conflicts of Interest between a Director or Administrator and a Shareholder: Directors or administrators may not disregard, limit or restrict in any way the rights of any shareholder, who shall have all the powers conferred by law for the exercise of such rights.
    When a conflict of interest arises between a director or administrator and a shareholder, compliance with current regulations and the interests of the company shall prevail.
    Conflicts that arise between the company and its shareholders shall be resolved by direct settlement.

10. ATTRIBUTIONS AND COMPETENCIES TO MONITOR COMPLIANCE WITH THIS CODE

Each employee of the company shall have the powers and faculties established by law, the bylaws and the company's functions and operations manuals, regulations and policies applicable to him/her; to the extent that he/she does not act within them, he/she shall be accountable for the conduct displayed.

Each employee is responsible for self-monitoring his or her own compliance with the rules of this Code.

Within the concept of supervision that each leader must exercise over his or her direct subordinates, he or she shall exercise reasonable verification of compliance with the basic principles contained in this Code.

The Administrative Director, the Legal Coordination, the General Management and the Human Resources Area shall verify, in accordance with the procedures and in the development of their evaluation and follow-up programs, compliance with this Code and the pertinent standards.

11. PENALTIES

It is the duty of employees to abide by the rules of this Code and others that are in force within the manuals and instructions of the company. Non-compliance constitutes a failure to comply with the obligations that correspond to each employee.

In view of the above and in appropriate cases, the procedures and sanctions established by law and in the internal work regulations shall be applied.

For the purposes of the application of labor, legal or internal regulations, any violation of the Code of Ethics and Conduct is considered a serious offense and will have the consequences derived from such type of offenses.

12. ENVIRONMENTAL PROTECTION POLICY

Alvilla S.A.S. aware of the need to preserve, protect and conserve the environment, has promoted among its employees, practices that help to fulfill this purpose, which are aimed at implementing recycling programs, energy saving, water saving and reduction in the use of paper, which seeks to contribute to the improvement of ecological conditions.