Policy on the system of self-control and comprehensive risk management of money laundering, financing of terrorism and the proliferation of weapons of mass destruction

The Company's Money Laundering, Terrorist Financing and Proliferation of Weapons of Mass Destruction (AML/FT/FPADM) self-control and risk management system policy  states the following guidelines:
 

• The Company must comply with local regulations and leading international reference frameworks in the area of prevention of Money Laundering, Financing of Terrorism and the Proliferation of Weapons of Mass Destruction, in order to contribute to the realization of the purposes of the Governments against the fight against these illicit activities and to protect the Company's reputation.
• The guidelines, manuals and procedures related to the Money Laundering and Terrorist Financing Risk Management System are mandatory for all counterparties.
• The Company will not have contractual ties with any natural or legal person that is linked or related to Money Laundering, Terrorist Financing and/or the Proliferation of Weapons of Mass Destruction activities at a local or international level. 
• If during the contractual relationship it is known that the counterparty was related to illegal activities or included in restrictive or binding lists, national or international, the Compliance Officer will evaluate the situation and issue a concept on the continuation or termination of such relationship.
• It is the responsibility of the Senior Management and Compliance Officer to promote within the Company a culture of prevention and knowledge of the customer, supplier, collaborator and other Stakeholders involved with the Company through training and any other available means.
• The Company must only establish contractual links with natural or legal persons that allow their identification and knowledge, as a requirement to access the products it offers and sells.
• When the natural or legal person does not provide sufficient information to carry out an adequate assessment of its situation and risk analysis, the Compliance Officer will issue a concept on the non-continuity of the relationship. In the case of counterparties with a current relationship, each case must be analyzed individually, in order to analyze the risks and the Compliance Officer must issue a concept on whether the business relationship is terminated or continued, leaving a record of the reasons for the decision.
• No business or any other type of relationship should be established with natural or legal persons when there are elements that lead to well-founded doubts about the legality of the operations or the legality of the resources and/or their destination.
• All employees are obliged to ensure the best interests of the Companies and compliance with this Policy.
• All transactions must be carried out through the information systems available to the Companies, so that they are duly recorded with the support of the initial and continuous due diligence of each counterparty.
• The Company must collaborate with the authorities in providing the information requested in the development of investigation processes of Money Laundering, Financing of Terrorism and the Proliferation of Weapons of Mass Destruction.
• The information managed by the Company is of an absolutely confidential nature. Therefore, employees must handle it confidentially, honestly and with integrity. Consequently, you may not use that information for your own benefit or that of third parties, inside or outside the Company.
• No employee may disclose aspects of the operations reported as suspicious or attempted to the designated reporting entity in each country, Only the Compliance Officer will know and report the information to the entity without prejudice to the reports that must be submitted to the Company's Senior Management.
• It is the obligation of all the Company's employees to know and rigorously apply the criteria and standards incorporated in the policy and other mechanisms that regulate the Self-Control and Comprehensive Risk Management System for Money Laundering, Financing of Terrorism and the Proliferation of Weapons of Mass Destruction; Know and attend to the warning signs contemplated in it.
• In the event of knowledge of a crime that in the course of their duties is perceived by persons linked to the Company, they must comply with the obligation to report such acts, through the reporting channel established in the Code of Ethics.
• It is the obligation of the collaborators to inform the Compliance Officer, who in turn informs the Board of Directors and the designated reporting entity, of any relevant information on the management of resources whose amount or characteristics are not related to the economic activity of their customers and suppliers or that due to their number, the amounts transacted or the particular characteristics of the same,  may reasonably lead to the suspicion that they are using the Company to manage, take advantage of or invest money or resources derived from criminal activities or intended for their financing.
• It is the obligation of each employee to attend the training that is given on the subject, regardless of the level or position. It is also an obligation to allow the attendance of collaborators in the area.
• It is mandatory to put ethical principles before the achievement of commercial goals, considering that it is essential to generate a culture aimed at applying the standards established for the prevention and detection of money laundering, financing of terrorism and the proliferation of weapons of mass destruction.
• The Company should pay greater attention when entering into contracts or conducting negotiations with persons or entities in countries that do not apply the recommendations of the Financial Action Task Force (FATF) and others considered to be at high risk in accordance with the provisions of the Financial Action Task Force (FATF).
• For the Company, the knowledge of its Stakeholders is the most important control since it minimizes the risk that the company will be used for the management of resources from criminal activities, or destined for their financing.
• The Board of Directors, the Legal Representative, the Compliance Officer, Collaborators, Internal Audit, Fiscal Auditor and other Stakeholders of the Company must be responsible for the obligations and responsibilities that are applicable to them in relation to the application of the Self-Control and Comprehensive Risk Management System LA/FT/FPADM.

• It is the responsibility of the Company's Senior Management and Vice-Presidents to accompany the mandatory compliance with this policy by all Employees and processes involved in interaction with external Stakeholders.