ETHIC CODE

Introduction

In the CLISA Group we share the commitment to the highest level of integrity in the conduct of business. Integrity and ethics have always been a significant part of the way we conduct our business. Acting with a strong sense of integrity is crucial to maintain the trust and credibility of our Clients, Associates, Collaborators, Shareholders and other stakeholders. This Code of Ethics defines the guidelines and standards of integrity and transparency to which all CLISA Group Collaborators must adapt, whatever their hierarchical level or specialty.

The Code of Ethics contains rules regarding individual responsibilities and among members of the same category as well as responsibilities for our Employees, Customers, Suppliers, Shareholders and other stakeholders. Within the framework of employment relationship maintained in each entity, all employees must perform their duties in accordance with laws, external and internal regulations and the guidelines of this Code, on a personal and non-delegable basis, with honesty, loyalty to the company and transparency in all work events. It will be considered as opposed to the principles of this Code any work behavior that assigns the Collaborator or his close associates an unauthorized personal benefit, in deterioration of the company or of any of the interest groups.

I. Object

The Code of Ethics of CLISA Group aims to establish the guidelines that should govern the behavior of its employees in their daily performance, in relation to the relationships and interactions between them, the actions related to customers, suppliers and external collaborators This Code of Ethics is based on the definition of the Mission, Vision, Values ​​and Principles of the CLISA Group, to which it complements, and constitutes an action guide to ensure adequate behavior in the professional performance of its Collaborators.

II. Area of ​​application

This Code of Ethics is addressed to all CLISA Group employees, regardless of the contractual modality that determines their employment relationship, position they occupy or the place where they perform their work. The guidelines contained in this Code affect all the companies in which the CLISA Group has an interest, in which it has management control.

III. Enforcement Bodies of the Code of Ethics

Managing Director
Director of Comptroller / Human Resources / Internal Audit Director of Finance
Director of Legal
Commercial Director
Business Director

IV. Compliance with the Code of Ethics

The application of this Code will be the personal and non-delegable responsibility of each and every one of the Collaborators, who, once informed about its implementation, can not justify their transgression due to ignorance or instructions received to the contrary from any hierarchical level. Such non-compliance may result in civil and criminal liability, and may result in disciplinary action including dismissal from work. The staff is expected to adopt a proactive attitude, avoiding passive tolerance against possible deviations and acting on their own initiative when detecting departures from the principles of this Code in any type of process. It is expected that each Collaborator will comply with the guidelines of the Code of Ethics and will collaborate with internal investigations when it is required. Hierarchical levels with personnel under their charge should not approve or tolerate infractions of the Code of Ethics, and if they are aware of them, they should inform them immediately, according to point 16 of this code. Management positions must ensure that this Code of Ethics is implemented through appropriate disciplinary measures. They can not ignore unethical behavior.

V. Validity

The Code of Ethics comes into force on the day of its publication to all Collaborators and will be valid as long as its cancellation is not approved.
It will be reviewed and updated by the Committee when there are suggestions or proposals made by the Collaborators and the commitments acquired in terms of social responsibility and good governance by the CLISA Group.

SAW. Guidelines

1.- Compliance with Laws

The Collaborators of CLISA Group must consider in all cases the compliance of the current legislation, as well as the Policies and Procedures, in the countries where they develop their activity, taking into account the spirit and purpose of the same, and observing in all their actions an ethical behavior. Likewise, they should avoid any practice that, even without violating the law, could harm their own interests and / or the reputation of the Group before the community, the government or other organizations and adversely affect their interests.

All the CLISA Group Collaborators must know the laws that affect their work, requesting in their case, the precise information through their superior or the corresponding instances.
No Collaborator of Grupo CLISA will consciously collaborate with third parties in the violation of any law, nor participate in any action that compromises respect for the principle of legality.

2.- Values

In CLISA Group, the Collaborators, live the commitment with a sense of belonging and responsibility in their actions through the values, which are an integral part of the organization, besides providing the foundation, for the development of a normativity on which decisions are made and actions with value are executed. The values ​​of the CLISA Group are the following:

a) Passion for service and customer focus.
b) Creativity and innovation
c) Quality and Productivity
d) Respect, Integral Development and staff excellence e) Honesty and Integrity

3.- Respect for People

At Grupo CLISA we recognize the dignity of people and respect their freedom and privacy.
Grupo CLISA rejects any manifestation of physical, psychological, moral or abuse of authority, as well as any other behavior that may generate an intimidating or offensive environment with the rights of the people. CLISA Group Collaborators must treat each other with respect, fostering cordial relationships and a pleasant, healthy and safe working environment.

Among the facilities, events organized and / or sponsored by the CLISA Group, colloquial and vulgar language as well as the use of adjectives disparaging epithets are not allowed.

All employees have the obligation to treat their colleagues, their superiors and their subordinates fairly and respectfully. In the same way, the relations between the Collaborators of CLISA Group and those of the companies or external collaborating entities will be based on professional respect and mutual collaboration.
Grupo CLISA considers the integral development of the person important, so it will facilitate the necessary balance between professional life and personal life.

4.- Professional Development and Equality of Opportunities

Grupo CLISA promotes the professional and personal development of all its employees, ensuring equal opportunities through its policies of action.
Does not accept any type of discrimination in the workplace or professional because of age, race, color, sex, religion, political opinion, national descent, pregnancy, sexual preference, social origin or disability. The selection and promotion of the Collaborators of CLISA Group is based on the competences and the performance of the professional functions, and on the criteria of merit and capacity defined in the requirements of the job.

All employees must participate actively in the training plans that the CLISA Group offers, benefiting in their personal and professional development, pledging to build and add value to internal and external customers, shareholders of CLISA Group and society Professional in the company.
The Collaborators who hold management or command positions must act as facilitators of the professional development of their collaborators, in such a way that their professional growth within the CLISA Group is encouraged.

5.- Safety and Health at Work

The CLISA Group promotes the adoption of occupational health and safety policies and complies with the preventive measures established in current legislation. It also seeks the application of its rules and policies on health and safety at work by the companies and suppliers with which it operates.
All the Collaborators must use the resources of the CLISA Group in a responsible, efficient and appropriate manner in the environment of their professional activity. Likewise, they must protect them and preserve them from any inappropriate use from which they could derive damages for the interests of the company.

6.- Conflicts of Interest

Grupo CLISA believes that the relationship with its employees must be based on loyalty that arises from common interests.
In this sense, it respects the participation of its Collaborators in other financial or business activities, provided they are legal and do not enter unfair competition with their responsibilities as Collaborators of Grupo CLISA. At Grupo CLISA we respect interpersonal relationships and different beliefs, so at no time do we intend to interfere with them. We also seek and encourage the participation of our collaborators in activities outside Grupo CLISA, as long as these do not interfere with their work and present or future responsibilities.

It is very important to avoid any situation that in a real or potential way results in a conflict of personal interests, towards third parties and in general for any company that is part of Grupo CLISA. It is for the foregoing that the employee must take care at all times that their behavior and personal relationships do not:

a) Interfere with your agenda, objectives, performance, judgment and professional responsibility.
b) Cause or may cause, directly or indirectly, any damage to CLISA Group.
c) Directly involve CLISA Group in situations or actions that could result in probable liability for the Group.

Now, in terms of interpersonal relationships, it is important to mention that the relatives and relatives of a collaborator do have the possibility to work in Grupo CLISA. However, our Ethics Policy establishes that no collaborator can supervise or be supervised directly or indirectly by a relative. The foregoing includes organizational structures or functions that are directly or indirectly linked and that the result may transcend in a conflict of interest or in an interference with their good judgment and objectivity in the performance of their duties. Therefore, it will also be understood that relatives, relatives and close relationships include, without limitation: spouse, children (as), stepchildren (as), father, mother, stepfather, stepmother, brothers (as), brothers-in-law, cousins, father-in-law, son-in-law, daughter-in-law and any other person with whom you are related in a close personal relationship and / or cohabitation.

The General Management will have the faculty to justify the continuity within CLISA Group, to those collaborators that are in any of the previously mentioned cases when their situation does not affect the interests of the Group and / or of any of its members and collaborators. The General Management will present the justification before the Corporate Committee, who will issue and postulate their opinion to be annexed to said proposal. "In their relations with customers, suppliers, contractors and competitors, the Collaborators must privilege the interests of the company over any situation that could represent a real or potential personal benefit for themselves or for close associates CLISA Group Collaborators that serve clients, should offer them an equitable and honest treatment in each transaction, providing the products and services that are of the highest quality. and opportunity at your disposal, adhering at all times to official regulation and internal regulations, false or misleading comparisons will not be made with products or services equivalent to those offered by competitors.
In the event that the Collaborators or their close relatives participate or are going to participate in government bodies of other companies that may come into collision with the interests of Grupo CLISA, they will have to inform the CLISA Group of such situation.

When a CLISA Collaborator feels influenced by its ability to fulfill its responsibilities objectively, by receiving pressures from third parties who are using their position, authority or influence in the organization, they must report it immediately to their superior or to the Committee Corporate.
Intercede must be avoided to satisfy the requirements of superiors, subordinates, co-workers, family members or friends, if they harm the companies of Grupo CLISA.
CLISA Group Collaborators that negotiate the acquisition of the goods and services that the CLISA Group companies require, must always seek the best interests for the company, through transparent processes that ensure the equitable participation of the suppliers and an impartial selection of the themselves, based on criteria of quality, profitability and service.
You must collaborate in a professional and truthful manner with the internal and external auditors of Grupo CLISA that is in the performance of its functions.
The Collaborators of the CLISA Group must inform the company by signing a signed and updated statement annually on conflict of interest situations. The Corporate Committee must have a copy of the above.

7.- Gifts and Attentions

Acceptance of gifts and entertainment is restricted.
Employees may accept courtesy gifts or courtesies, such as corporate, small or hospitality gifts, only when they are of a value no greater than the equivalent of USD 20, and an impartial observer can not interpret that they are intended to obtain undue advantages.
Collaborators who receive gifts or special treatment that are not directly related to normal courtesy relationships, must inform their superiors in order to request instructions regarding the final destination of these gifts.

Under no circumstances may gifts of money or goods easily convertible into money be accepted.
Invitations received to participate in business events, conferences, conventions, commercial presentations or technical courses must be authorized by the appropriate level of supervision. The restrictions for the reception of gifts or services include those close to the Collaborators.

8.- Commercial Incentives (donations)

Commercial incentives must conform to applicable legislation and market practices.
The granting of commissions, discounts, credits and bonuses must be resolved in accordance with current legislation and must be officially made to legally recognized organizations, with the corresponding supporting documentation. Even if it complies with the aforementioned requirements, any commercial incentive must correspond to the usual practices in the market, for authorized values ​​and through procedures duly approved and registered in accordance with internal regulations.

9.- Use and Protection of Assets

Grupo CLISA makes available to the Collaborators the necessary resources for the performance of their professional activity, and is committed to providing the means for the protection and safeguarding of them. All the Collaborators must use the resources of the company in a responsible, efficient and appropriate way in the environment of their professional activity.
According to current legislation, each Contributor is responsible for protecting the property and other tangible and intangible assets of the company against unauthorized use, breach of trust, damage or loss due to negligence or criminal intent.

10.- Security of Company Information

Grupo CLISA considers internal information and knowledge as one of its main assets for business management, so they must be the subject of special protection.
Grupo CLISA declares the veracity of the information as a basic principle in all its actions, for which the Collaborators must truthfully transmit all the information they have to communicate, both internally and externally and in no case will they knowingly provide incorrect or inaccurate information that can mislead the one who receives it. Only those persons expressly authorized may access the internal information of the company, whether it is in physical, magnetic, electronic or optical media, for the purposes and during the periods specified in the authorization.

The Collaborators are directly responsible for taking the necessary precautions to preserve the information of the company from risks of damage or loss, ensuring custody for the time established by laws and internal regulations. In CLISA Group all the information generated in the financial records is confidential and can only be delivered to external parties with the Vo. Bo., From the Corporate Finance Director. In CLISA Group it is forbidden to distort the records and / or the accounting information, or to falsify the operations, either to simulate the fulfillment of goals or objectives, or to obtain some personal benefit.

11.- Confidentiality of Company Information

The Collaborator must maintain confidentiality regarding all information accessed in the performance of its duties in the CLISA Group, even if it has not been classified as reserved or does not specifically refer to the CLISA Group but to its customers, competitors, suppliers, markets and public bodies related to their activities and even their CLISA Group Collaborators. It is considered a serious breach of the obligation of confidentiality to disclose or facilitate the disclosure of internal information regarding business ventures and activities. The requirement of confidentiality of the information must be maintained according to the applicable national laws, until the information is made public.

12.- Intellectual Property Rights

The property rights of all the knowledge developed in the work environment among which are, plans, computer programs, systems, methodologies, courses, reports, technical documentation and inventions, belong to the company, which retains its right to exploit the mode and at the time it deems appropriate.
The intellectual property created by each Collaborator, derived from his professional performance, is transferred and assigned to the CLISA Group by law / or his work contract with the exceptions stipulated in the current legislation.

13.- Communications Systems

The communications systems of CLISA Group, including Internet connections, must be used to carry out the CLISA Group's business or for occasional purposes authorized by Management.
The unacceptable use of Grupo CLISA's communication systems includes processing, sending, retrieving, accessing, viewing, storing, printing or otherwise disseminating materials and information that are fraudulent, harassing, threatening, illegal, racial, sexist , obscene, defamatory or otherwise incompatible with professional conduct.
The Collaborators in CLISA Group, should refrain from making comments, either in family, social and / or electronic media (email and social networks), on activities carried out within the companies belonging to the Group, which are to the detriment of this or of others, such as processes, methods, strategies, plans, investments, technical, market or any other type of data.

14.- Relations with the Community

Employees are not authorized to publicly support political parties on behalf of the company, participate in electoral campaigns or take part in religious, ethnic, political or interstate conflicts.

15.- Respect for the Environment

The Collaborators must strive to minimize the environmental impact derived from their activities and the use of the facilities, equipment and means of work put at their disposal, seeking an efficient use of them.
In their relations with contractors or external collaborating companies, CLISA Group Collaborators will transmit these principles.

16.- Complaints
The Collaborators and / or suppliers of Grupo CLISA, who consider that the staff has participated in an unethical, undue or unfulfilled conduct in the Policies and Procedures, can report the issue, in the telephone number for anonymous reports 01 800 1200 200, through the electronic mail denuncias@clisanet.com or in the page www.clisanet.com.
17.- Sanctions

Violations of this Code of Ethics will be subject to sanctions and the severity will depend on the seriousness of the faults committed. In cases of misdemeanors or serious crimes, sanctions may range from dismissal to criminal prosecution before the competent authorities.
Some examples of violations of the Code of Ethics:
a) Negligently disregard the Policies and Procedures, as well as this Code of Ethics.
b) To omit or not timely inform about violations of the Code of Ethics and / or Policies and Procedures.
c) Failure to comply with safety regulations that put the life of the Collaborators or the assets of the company at risk.
d) Report an innocent person in bad faith and in bad faith.
e) Carry out operations for personal benefit, family or third parties, to the detriment of the company.
f) Influence, manipulate or deceive anyone who performs an investigation or review within the company.
When there is doubt about the existence of a violation of this Code of Ethics, the Corporate Committee will proceed to validate and evaluate the available evidence, before the corresponding sanction is imposed on the possible offender.

18.- Compliance with the Code of Ethics

The Corporate Committee will prepare a document in the month of January of each year, where it will report the compliance or omission of this Code of Ethics to the General Management.
If this Policy and Procedure is not applied, it will be reported to the Human Resources Department, so that the necessary measures are taken.
Exceptions may only be authorized by the General Directorate.
END OF DOCUMENT