1. The Company’s Code of Ethics and Conduct has been formulated in order to inform the Company’s Staff of our code of ethics and lead them to act by it, and to allow other interested parties to understand the Company’s values. Everything stated within this document will be taken as the basis for compliance.
2. The Code is applicable to the Company’s directors and managers (including President, Vice-President, General Manager or equivalent position, Financial Department Chief, Accounting Department Chief and other management officers or authorized signatures), as well as all other employees of the Company.

Any people referred to in the preceding paragraphs of this document are hereinafter referred to as “Company Staff”.

1. The Company Staff shall at all times observe the Code and any other applicable regulations.
2. The Company Staff shall avoid any conflict of interest between their personal interests and those of the Company, including, but not limited to, situations where they cannot handle their public affairs objectively and effectively, or when Company Staff and/or their spouses, parents, children, or relatives up to the second degree of kinship, would gain any unjustified benefit because of the position of the aforementioned Company Staff within the Company.

In addition, whenever the Company offers financial loans, provides guarantees, makes significant asset deals, or trades goods or services with companies affiliated to the parties referred above, the Company Staff shall act according to the pertinent Company operating procedure: it is a mandatory requirement to inform the Company of any potential conflict of interest.

1. Should an opportunity arise to increase the Company’s profit, the Company Staff is encouraged to seize it, always within reason and respecting any relevant legal framework.

No Company Staff should have the opportunity to make or gain any personal profit by taking advantage of the Company’s property or information, or because of their positions at the Company. Moreover, staff members shall not engage in competition with the Company, unless it is consented by the Company or by the law.

1. The Company Staff shall keep private any information, affairs or client data which is considered confidential, unless such information is required to be disclosed by means of a legal warrant. It will also keep private any previously undisclosed information that might impair the Company or any of its clients if it was used or divulged by any competitor.
2. The Company Staff shall treat other employees, clients, and competitors in a fair way, and shall not try to control, conceal or abuse information obtained through execution of business in order to gain any unjustified benefit, by making false statements under any circumstance, or other unfair transactions.
3. The Company Staff must protect and use the assets of the Company properly, ensuring that such assets can be used legally and effectively on public affairs. Any larceny, negligence, or waste will directly affect the profitability of the Company.
4. The Company shall raise awareness about moral behaviour, and the Company Staff shall comply with all applicable regulations and Company policies and regulations.
5. Should any Company staff suspect or have proof that the actions taken by another member of Company staff has contravened the rules and regulations of the Code, they must report it to their Remuneration Committee, managers, internal audit chiefs, or other competent officers in writing or verbally, providing enough information or proof to enable the Company to act accordingly.

The Company will treat the report and the identity of the person who submitted it as confidential, and will handle them in a responsible manner.

1. Should any Company staff member violate the Code of Ethics and Conduct, the Company will respond according to any applicable rules and regulations.

The Company has established an appeal procedure that the violator of the Code of Ethics and Conduct can adhere to, should they wish to defend themselves against the proposed sanctions.

1. The board will review any Code exemption requests filed by Company staff, any changes to the Code will be published according to the applicable rules and regulations.
2. The Company shall disclose the details of the Code on the official website and in Market Observation Post System (MOPS). This also applies to any of its amendments.
3. The Code shall be put into practice following approval by the Board of Directors. This also applies to any of its amendments.