PBX: 57 (1) 3904480

CONFIDENTIALITY

POLICY

This is the Confidentiality Policy of ESCANDÓN ABOGADOS. The company is identified with Colombian Taxpayer ID NIT 900.909.688-4, which governs all its commercial relations and working conditions. FIRST – DEFINITIONS. For the purposes of this policy, the parties are subject to the following definitions: • Confidential Information: Means any information, whether or not identified as such, related to the parties’ businesses and their internal structure and organization. This information includes, but is not limited to, the following documents: technical manuals, financial statements, accounting records, business strategies, business models, investment and development plans and projects, formulas, customer lists, product and service plans, methodologies, price information, analysis and projections and industrial models, product supports, software code, resumes of employees, objectives, terms and conditions of contractual documents. • Disclosing Party: Any party providing or facilitating access to confidential information to the other party. • Receiving Party: Any party receiving or accessing the other party’s confidential information SECOND. PURPOSE. The parties are obliged, on a reciprocal basis, to maintain all the confidential information provided in pre-contractual, contractual or postcontractual agreements between them in complete confidentiality, and the parties also agree to use it exclusively for the purposes for which it is supplied. THIRD. Obligations of the information Receiving Party: 1. Except in accordance with the provisions of Clause Four (Exceptions to the confidentiality obligation) of this policy, maintain the confidentiality of any type of information that is provided by the Disclosing party or to which the Receiving party has access or knowledge of. 2. Take all the precautions and measures necessary to ensure the confidentiality of information of this nature, which, in no case, will be lesser measures than those taken to maintain the confidentiality of their own businesses and affairs. 3. Use the information provided by the Disclosing party or of which it has knowledge, only in the manner and for the purposes established in this agreement. 4. . Refrain from delivering or making for itself or for third parties, copies, arrangements, reproductions, adaptations or any other kind of mutilation, deformation or modification of confidential information. 5. Do not disclose to third parties or any other person or entity the confidential information without the prior express, written consent of the Disclosing party. 6. Ensure that the communication systems and the technological infrastructure in which it will store and/or process the data received from the Disclosing party, possess the necessary security elements to safeguard the information, such as Firewalls, authentication and encryption systems. When using information exchange media such as e-mail and Internet, they will apply the same measures to ensure that information is not seen or modified by persons not involved in the process. 7. Not to reproduce the confidential information delivered, unless it is necessary to fulfill the purpose for which it has been supplied and it will only be disclosed to those employees, workers or advisers, who need such knowledge. In the latter event, said employees, collaborators or advisers must be advised of the confidential nature of the information and on the terms of this agreement. The Receiving party will be responsible for compliance with the provisions herein and, in any case, will indemnify the Disclosing party for any damages that the disclosure of the confidential information causes. 8. Guarantee the destruction or return of the information, at the time when the contract ends or when the Disclosing party so requires and communicates it to the Receiving party by any means. FOURTH, EXCEPTIONS TO THE CONFIDENTIALITY OBLIGATION. The receiving party is not obliged to preserve the confidentiality of the information, when it is required by order of competent authority in the exercise of public functions, when it has passed into the public domain, and when it comes to its knowledge through reports supplied by third parties not obliged to maintain confidentiality. In the case of an order of authority, prior to the disclosure of the information, the disclosing party must be informed in due time of said order. FIFTH. OWNERSHIP. The delivery of Confidential Information does not give the Receiving party any authorization, permission or license whatsoever to use the trademarks, patents, copyrights or any other intellectual or industrial property rights or any other economic exploitation whatsoever. Neither this Agreement nor the delivery or receipt of Confidential Information constitute or imply any promise or intention to make a purchase or sale of products or services, or promise to enter into any contract of any kind by either party or commitment with respect to the present, or future, commercialization of any product or service. SIXTH. VALIDITY. This policy is effective as of its publication, and specifically from when any agreement negotiation begins, or any contract is entered into or any supply of information occurs, obliging the participants to maintain the confidentiality of the confidential information to which they have access to for the duration of the contracts, plus the duration of the contract that is entered into as a result of the negotiation and for an additional period of two (2) years, counted from the date of its termination whatever the cause. Once all legal relationships between the parties have been terminated, being understood as covering pre-contractual agreements or the agreement to which they are addressed, they undertake to destroy or restore the confidential information they have received, within thirty (30) calendar days following said termination. Each of the parties will send a written notification to the other, informing the return and/or destruction of the information. In any case, each party may choose what information supplied by it must be returned. SEVENTH. NOTIFICATIONS. For all purposes relating to the execution of the present policy, Escandón Abogados S.A.S., receives notices at Calle 87 No. 10 – 93 office 702 in the city of Bogotá, phone 3108099797, email mjescandon@escandonabogados.com