1. PURPOSE ESCANDON ABOGADOS is a law firm that provides legal services in labor matters under the highest standards of ethics and integrity and therefore exercises zero tolerance for any illegal or corrupt practices or bribery. The objective of this policy is to comply with the national and international normative provisions on the subject, as well as to protect our reputation by developing our professional practice in an honest manner. 2. SCOPE This policy is addressed to all the employees of the company as well as the different stakeholders with whom the company has commercial relations, such as suppliers and contractors, in addition to others, who must express their knowledge of this policy as well as its acceptance by signing the form established for this purpose. 3. NORMATIVE PROVISIONS • Criminal Code Law 599 of 2000 • The Anti-Corruption Statute Law 1474 of 2011 “By means of which norms are dictated focused on strengthening the mechanisms of prevention, investigation and the penalization of acts of corruption and the effectiveness of the control of the public administration. • Law 1778 of 2016 “By means of which rules are issued on the liability of legal persons for acts of transnational corruption and other provisions in the field of anti-corruption.” • Foreign Corrupt Practices Act (FCPA): United States Federal Act on the Prevention of Corrupt Practices Abroad. • UK Bribery Act: Bribery Act of the United Kingdom which criminalizes bribery in both the public and private sectors. • Convention against Transnational Bribery of the Organization for Economic Cooperation and Development (OECD). • Disciplinary Code for Lawyers, Law 1123 of 2007. 4. DEFINITIONS Corruption; Abuse of power for personal gain. (Transparency, 2009)1 Audit; An internal or external examination of an organization’s accounts, processes functions and performance to produce an independent and credible assessment of their compliance with applicable laws, regulations and audits. (Transparency, 2009) Bribery; To give, promise, solicit or accept a consideration in money or kind in exchange for receiving an unfair advantageous condition in commercial, contractual or personal matters. Bribery is a phenomenon committed both in the private sector and in the public sector. Facilitation payments; These are unofficial small amounts of money or gifts made to secure or expedite the performance of a routine or necessary action to which the payer has legal or other entitlement, with respect to decisions that are administrative, commercial or contractual or those of public function and government. Code of conduct; Statement of principles and values that establish expectations and standards for an organization’s conduct, including the minimum levels of compliance and disciplinary action. (Transparency, 2009). 5. COMPLIANCE WITH THE POLICY As the governing body, it is incumbent upon the Board of Directors of ESCANDÓN ABOGADOS to approve this policy and to update it in accordance with the recommendations of the General Management and the ethics committee. Management has the obligation to enforce this policy by creating a preventive, ethical and responsible culture, establishing as its main guideline the commercial interests of the firm about ethical principles. 1 Transparency. (2009). Anti-corruption plain language guide. Source: http://transparencia.org.es/wp-content/upIoads/2014/Gu/%C3%ADa-de-Ienguaje-clarosobre-Iucha-contra-la-corrupción.pdf Any type of bribery or conduct that may be defined as illegal or ethically incorrect is expressly prohibited, and it is the duty of all employees of the company to immediately inform any information they may have about any illegal conduct, and therefore an attack on our reputation. 6. ACCOUNTING RECORDS The accounting books of ESCANDÓN ABOGADOS will permanently reflect the exact financial and accounting situation of the company, as well as its transactions. It is completely forbidden to alter, modify, manipulate or misrepresent the accounting entries and other records that are intended to manipulate information with which it is intended to conceal the nature of transactions such as; Bribes, payment of fees, sponsorships, donations, representation expenses, in addition to others. 7. GIFTS AND MEALS The objective of the meals and gifts or entertainment activities provided by the company for third parties is an expression of the corporate desire of the entity to: thank, create or strengthen working or commercial relationships. It is not allowed for the furtherance of meetings, luncheons other events in which an agreement or undue advantage is sought. Likewise, it is forbidden for all collaborators in their capacity as employees of the firm, to give or receive money under any title, or gifts in an amount greater than USD 50 and they must report any invitation extended them by a supplier or client. All ESCANDÓN ABOGADOS gifts are understood to be on behalf of, and in the name of, the company and never in a personal capacity. The company will have as its policy to give corporate gifts of a symbolic amount on special dates such as Christmas or items that do not exceed a value of USD50 and they will be duly recorded. Gifts of an excessive value are considered inappropriate for the company and an attack on our reputation. 8. DENUNCIATION The ethics committee is in charge of receiving denunciations, and forwarding and transferring them, when applicable, to the competent authorities on the occurrence of any act of corruption. This body will be made up of an employee from the administrative area, a board member and a lawyer of the firm who must report directly to the General Manager. No one shall be discriminated against, mistreated or pressured due to filing a complaint. The committee shall be responsible for ensuring the custody of the information, keeping it confidential and ensuring the guarantees in the management of the same. The email info@escandonabogados.com is enabled as a means of communication for the effective receipt of complaints. 9. NON-COMPLIANCE Failure to comply with this policy will be just cause for termination of the legal relationship with ESCANDÓN ABOGADOS, in addition to criminal sanctions as applicable. 10. TERM This policy is effect as of the date hereof and will be divulged to all the employees of the company and suppliers, who after reading it must prove their knowledge of it by signing the respective form. It will also be publicly known through its disclosure on the company’s website. This policy sets aside any provision that the firm has previously had on this matter. Issued in Bogotá on the 26th day of June 2017. ESCANDON ABOGADOS Labor Attorneys