Ethics Code

Our company

CHARIKLO INVESTMENT, SRL (hereinafter “CHARIKLO”, “the Company” or “the Company”) is a company dedicated to the design of comprehensive logistics and financial solutions to make the business plans of our clients and partners a reality. We are dedicated to importing the necessary inputs with the aim of converting them into products for national and international marketing.

Our Mission and Vision

Mission

To be a comprehensive platform of business solutions through strategic alliances at a global level, providing a solid logistical and financial structure to satisfy the needs of our partners and clients.

Vision

To be a reference in international trade, permanently expanding our portfolio of projects to support the development of business opportunities integrated by our vast experience in logistics.

Our Strategy

Chariklo is a comprehensive digital platform for business solutions through global strategic alliances, providing a solid logistical and financial structure that provides opportunities and satisfies its partners and clients. Being the ideal ally to carry out the execution of innovative ideas with vast experience.

Values and principles

Cooperation: we make sure to work in collaboration and permanent communication with our clients and partners to enhance collective growth.
Innovation: we seek to offer creative alternatives to ensure competitiveness and permanent growth.
Transparency: We manage our operations with complete honesty to strengthen the trust of our clients and partners.
Commitment to excellence: we assume quality as part of our culture to exceed the expectations of our clients.

Why do we have a Code of Ethics?

The Code of Ethics defines the behavior that we must have and receive between collaborators and representatives of Chariklo as well as third parties linked to our Company. In addition, the Code of Ethics indicates the standard of conduct of each of us with the Company, with clients and with society in general.

Although we know that it is impossible to anticipate all the situations that may arise in our daily work, this Code of Ethics serves as a guide to make the best ethical decisions in our work and to know who to turn to in case of doubts.

What is expected of me?

It is very important for us that our shareholders, suppliers, distributors, business partners or anyone linked to the Company knows, assumes and endorses the principles and values contained in this Code and puts them into practice in their daily activities.

This Code sets out your responsibility as an employee or partner of Chariklo to comply with applicable laws, act with integrity and honesty in all matters, and be accountable for our actions.

The success and way of transcending our Company depends largely on compliance with the guidelines indicated here.

You are an important member of this business community and your support is essential to achieve the objectives we have set for ourselves.

You must understand the Code and comply with it. Therefore, we ask you for the following:

Read the Code carefully. Understand its scope and what is expected of you.
Comply with the principles of this Code in your work and in all your activities. Make them yours, they are the basis of our philosophy and business culture.
Always conduct yourself ethically and be proud of your conduct and actions. You are responsible for compliance with all the principles and conduct indicated here.
Always reflect on your actions and if in doubt ask for advice.
Remember that management levels have a greater commitment, so they are responsible for acting by example and conducting themselves with ethical leadership in deed and appearance.
If you know, detect or suspect that any employee, supplier, contractor or third party related to the Company is behaving in an illegal, unethical manner or in violation of the principles established in this Code, we ask that you submit a report to info@ chariklo.net

Remember that it is everyone’s obligation to protect our Company and Subsidiaries from behavior that is illegal or unethical and that may put us at risk.

In this sense, by not reporting activities contrary to the Laws or this Code in a timely manner, we can contribute to the generation of financial or criminal damage to the Company, and you may even involuntarily become an accomplice by covering up illegal or unethical activities.

Remember that by filing a complaint you generate a virtuous circle of protection, because by protecting yourself, in a correct and institutional manner, you protect the Company and by protecting the Company, you protect yourself.

If you consider it necessary, you can file anonymous complaints. We assure you that at Chariklo and its Subsidiaries we have adopted all reasonable and justified measures to protect the confidentiality of the complaint and the complainant. We guarantee you at all times that no type of retaliation will be taken against you for reporting.

For more information about filing complaints, we suggest that you read the section: Our Duty to File Complaints, at the end of this document or to the email address info@chariklo.net .

Thank you very much for your cooperation and for making these basic principles of professionalism and responsibility your own. We are sure that this Code will help us all grow both personally and professionally.

Why must we comply with this Code?

Failure to comply with this Code affects the image and reputation of Chariklo and all of us who work in our Company.

As part of a business community, we must all safeguard the image of our Company, which can be seriously affected in its reputation if we do not comply with these basic standards of ethics and conduct. This affects the perception we have towards the outside and the trust that a large number of people place in us.

Furthermore, failure to comply with the principles contemplated here could constitute violations of applicable laws and consequently be subject to administrative, civil or criminal sanctions.

Who is Responsible for Monitoring Compliance with the Code of Ethics?

management is responsible for establishing adequate and effective control, surveillance and audit policies and systems, and constantly and periodically examines compliance with this Code of Ethics, as well as the laws, regulations and policies that establish standards. integrity throughout the organization.

If you have any questions you can write to the email address info@chariklo.net

Respect for Human Rights and Non-Discrimination

At Chariklo we treat each person with respect and dignity and we are committed to Protect and Respect Human Rights in general and, in particular, observe the Guiding Principles on Business and Human Rights published by the Office of the High Commissioner of the Organization of the United Nations and, where appropriate, Remedy or repair any deviation from its compliance.

We operate in a globalized world where different cultures and customs exist. We believe that these differences enrich us and we fully respect them. Likewise, we are convinced that different forms of thoughts, beliefs or preferences allow us to have a broader perspective and be more creative in solving problems.

We promote diversity and inclusion, therefore, at Chariklo:

We treat each person with dignity and professionalism and speak out against labor exploitation.
We do not tolerate any type of discrimination and we promote a culture of healthy coexistence at work, based on respect, teamwork and solidarity.
We promote respect and inclusion in the workplace without discrimination based on disability, ethnic origin, religion, gender, marital status, pregnancy status, nationality, sexual orientation, economic capacity, age or political opinion; among others.
We do not allow any type of harassment, intimidation, ridicule, threats, pointing or other attitudes of physical or psychological violence, which violate the dignity of workers, make them uncomfortable or cause them to feel harassed in any way.
We prohibit the display by any means of images or objects of sexual content in the workplace or that promote hatred, discrimination or the promotion of stereotypes.
We promote equal opportunities between men and women and do not allow gender violence or sexual or workplace harassment.
Hiring, promotions and any other job benefits are linked to the job performance of those involved.
We speak out against child exploitation and adopt preventive measures, including verification of compliance with the minimum age requirements established in the applicable national legislation.

We consider that child exploitation is any activity of children or adolescents, whether remunerated or not, that is carried out outside the law in dangerous or unhealthy conditions, that violates their rights, or that can produce negative effects, immediate or future, for their physical, mental, psychological, or social development or affect their education.

In the event of hiring a minor, we ensure that their rights and guarantees are taken care of through and jointly with their parents, guardians or those responsible for their guardianship and custody.

We do not interfere with our employees exercising their freedom of association and collective bargaining.
We make efforts so that our value chain is aware of the principles that govern us under this Code and we commit to taking actions so that our suppliers, distributors and other business partners assume the behavioral commitments established in this Code in their relationship with their employees, including respect for Human Rights.
We promote a culture of responsible, clear and honest advertising. In this way we ensure that our clients receive the information truthfully.
We implement dissemination campaigns to raise awareness of the importance of respect for Human Rights, labor inclusion, diversity and gender equality.

These are the basic principles of our Human Rights and work environment policy. If you detect inappropriate conduct that is inconsistent with these principles, submit a report to info@chariklo.net .

Job security

Safety is one of our priorities. All employees, suppliers and contractors must respect the Company’s personal safety standards, because the safety and integrity of employees or third parties may be at risk.

In this sense, Chariklo meets the highest standards applicable to workplace safety issues. One of our objectives as a Company is to have the lowest number of work incidents.

Therefore, at Chariklo we are committed to:

Offer a safe work environment, with the training, equipment and tools necessary to maintain health and safety, as well as adopt the necessary measures to avoid or reduce occupational risks in our operation.
Promote a healthy and safe environment for our employees.

In this sense, it is strictly prohibited to consume drugs or alcoholic beverages at work or to be at work under the influence of alcohol or any other substance, as well as to possess, sell or transport these during working hours or using Company property.

The carrying of any type of weapon is prohibited in the workplace, in corporate vehicles, or when representing the Company, except when authorized to our security personnel where appropriate, to protect the employees and assets of the Company.
Comply with all civil security regulations and train your employees on the measures to take in case of contingencies.

It is your responsibility to take care of yourself and your colleagues to avoid risks at work. If you detect any situation that represents a risk to our safety or that constitutes a breach of workplace safety regulations, we invite you to submit a report to info@chariklo.net .

Customer Treatment

Must our existence to our clients. To continue to have your preference and achieve our mission, it is essential to treat you with the greatest respect, attention and kindness. This implies, among other things:

Provide fair treatment in accordance with respect for Human Rights. No person entering our administrative or commercial facilities will receive any discriminatory treatment based on, among others, gender, age, social status, disability, sexual preference, religion or political affiliation.
Offer services and products that meet your needs in an effective and timely manner; and be transparent regarding the terms and conditions of contracts and services.
Provide adequate, clear, reliable and timely information regarding the products and services we offer and those that each of them has contracted.
Resolve your general, administrative and technical questions and problems with highly trained and customer service-oriented staff.
Provide the highest possible quality to our clients, according to our processes and operational standards.

This series of factors that have a significant impact on the preference of our clients are translated into a single word: Quality.

Our success depends on our ability to develop and deliver innovative, high-quality telecommunications products and services. Our clients are the judges of this, which is why we should never deceive, provide false information or condition a sale.

The rights of our clients are protected in the countries where we operate by consumer protection laws, which seek equity and legal security in the relationships between the latter and suppliers.

Failure to comply with our customer service and support standards or engaging in improper business practices may, among other things, damage our reputation, lead to intervention by authorities, and cause us harm.

Chariklo does not tolerate any deviation from our standards of conduct and care towards our clients.

If you detect any situation that represents a breach of our customer treatment standards, submit a report to info@chariklo.net .

Personal information

At Chariklo we safeguard and protect the personal information of our clients, with the same care with which we protect our own. We use this information solely and exclusively for the purposes for which we collected it.

To maintain the integrity and confidentiality of personal data, we have the most advanced systems for storing and processing data, as well as various processes, controls and technical, physical and administrative security measures.

Access to personal information is limited to those employees who have a need to know it to perform their job duties.

We are committed to protecting and maintaining integrity the personal data that both our clients and other stakeholders have entrusted to us, through compliance with the laws of the countries where we operate and internal training of the following principles:

Integrity: We preserve the integrity of the personal data we receive against alteration, loss, theft, hacking, intervention or destruction, whether accidental or fraudulent.
Availability: We have procedures to ensure that our users’ information is available to them at all times.
Confidentiality: Personal data is only used by authorized personnel with justification to do so.

We adhere to current laws on personal data privacy and telecommunications in the countries where we operate and provide service.

If you have any questions related to the handling of our clients’ personal data and/or the application of these guidelines, contact your hierarchical supervisor and, if the doubt persists about how to process personal data, to info@chariklo.net for advice and assistance.

If you detect any breach of our Privacy Policy, submit a report to info@chariklo.net .

Communications Privacy

The privacy of communications is the fundamental principle that governs our industry and Chariklo, not only by legal provision, but because it is based on the trust that the public has placed in us.

Therefore, it is strictly prohibited to interfere with our clients’ communications or transmission; listen to, manipulate, monitor conversations, interfere with the transmission of data or reveal its existence or content; except in the cases established by the applicable legislation and in accordance with the requirements established for this by the competent authorities.

Nor may any type of information contained in our clients’ communications be used for personal benefit or that of third parties.

If you detect or suspect any breach of Communications Privacy, submit a report to info@chariklo.net .

Freedom of expression

At Chariklo we provide telecommunications services through landline, mobile and data telephony. Our network and infrastructure is at the service of its clients and users, who have the right to:

Express your opinions and ideas freely.
Maintain communication freely with people, organizations or entities, without them being subject to investigation or review.
Communicate content and share this information through the use of our networks or services.

Consistent with the above, we do not restrict any content or interfere with the freedom of users to communicate or create content, except in cases where legislation so determines and in accordance with the procedures established for this purpose by the competent authorities.

If you detect any breach of our Freedom of Expression principles, file a complaint to info@chariklo.net .

Confidential information

At Chariklo we are committed to not disclosing Confidential Information.

In general, we understand by this type of information, all those that we develop, generate and operate with sensitive information, which means a competitive advantage for our Company.

Likewise, we understand Confidential Information, among others:

Financial and legal information;
Information relating to our products and services, including our current and future plans;
Market information developed internally by the Company;
Information obtained through our telecommunications networks;
General business information, including information regarding our current and future plans, programs and expectations.

If you have confidential information, it is important that you at least ensure that you adopt the following safeguard measures:

Make sure you keep it in a safe place;
Do not leave photocopies or prints of it in common areas;
Do not discuss such information with coworkers who do not need to know it;
Don’t leave your computer screen open with sensitive information;
Never discuss this information with family or friends;
Do not make calls or have conversations that refer to confidential information in public places;
Do not share it or discuss it with people (internal or external to the Company) with whom you are not sure that they have formal authorization to know it.

Revealing Confidential Information could grant improper business advantages to third parties, cause damage to our Company and put the privacy of our clients’ and business partners’ communications at risk, and may even generate personal liability for you.

Therefore, we must observe the following rules:

Access to internal information is limited to those who have a need to know it. We must refrain from discussing any Confidential Information, even with our co-workers, unless they require it to perform their duties and with prior authorization from your superior.
It is prohibited to disclose Confidential Information to third parties. In justified cases, Confidential Information may be provided to third parties with prior authorization from the person or area designated for this purpose by the Company, subject in all cases to the execution of confidentiality agreements or other protection measures, as well as those of the applicable legislation. .
In the event that any government authority requests or orders the disclosure or delivery of any information, said circumstance must be made known to our Legal Department so that it can take the necessary measures for its protection and ensure compliance with all applicable requirements.
If as a result of our work we obtain confidential information from another person, including any competitor, client, supplier or government authority, and whose recipient is not the Company, we must respect and protect said confidentiality in terms of the criteria indicated above and when this is possible. , this information must be returned to the issuer without reading the content.
Employees must refrain from holding confidential conversations of any kind in public places, as well as avoid improper disclosures through media such as the internet, social networks or mobile phones; always complying with the provisions of the applicable provisions.
It is strictly prohibited to share Confidential or privileged Information to obtain, directly or indirectly, personal gain or benefit. Be careful when sending emails, ensuring that you are transmitting information only to those authorized to receive it.
When your employment relationship with the Company ends for any reason, you must deliver to your superior all the documents and/or work tools that you were entrusted with and that contain Confidential Information.

The obligation to maintain confidentiality regarding the Company’s information subsists after the termination of the contractual relationships of its employees or contractors.

If you detect or suspect any breach related to the handling of Confidential Information, submit a report to info@chariklo.net .

Files and Records

All records, books and accounting files must be prepared with the utmost care and must be correct, complete and reliable in all respects.

Compliance with the financial, legal and administrative obligations of our Company depends on these records and therefore they cannot be misleading or confusing.

All Company files and records must be kept up to date and in a sufficiently reasonable level of detail to accurately reflect the origin and destination of all transactions and operations, including the disposition of assets.

It is our responsibility that accounting and financial files and records are accurate and complete. Maintaining information accurately reflects the good reputation and credibility of the Company and we ensure that we comply with our legal and regulatory obligations.

To do this we commit to:

Never falsify a document.
Do not distort the true nature of a transaction.
Not participate or support another person in evading taxes or breaking the law.
No account should be kept off the books to facilitate or conceal improper payments.
All employees must maintain books, documents and records to comply with applicable laws and the policies and procedures established by the Company for this purpose.

If you detect or suspect any breach of the rules for handling files and records, submit a report to info@chariklo.net .

Effective Control of Corruption

Chariklo has a firm commitment to controlling corruption by complying with the provisions of local and international anti-corruption laws and international treaties on the matter.

Violation of the Code of Ethics, internal policies, or applicable anti-corruption legislation, regardless of the country where it occurs, may give rise to civil and criminal sanctions, ranging from fines to imprisonment and imprisonment. They are applicable both at the personal level and at the Company level.

In the public sphere, corruption is the abuse of power for personal benefit or that of the Company. When you interact with Public Servants or Government Entities and it is known as Public Corruption. In the sphere of individuals, that is, when actions or omissions are carried out aimed at obtaining some undue benefit for the Company, personnel or for a Third Party and it is known as Private Corruption.

Chariklo prohibits giving or receiving, directly or indirectly, bribes, offering or soliciting a bribe, or assisting or authorizing the payment or receipt of a bribe. Bribes can include paying to obtain an improper advantage or influence a decision (such as obtaining a lower tax rate than the law requires).

Bribes can be in the form of money, securities, real or personal property, donations, employment, gifts, access to entertainment and hospitality, travel, loans, dues payments, vacations, job offers, personal services, or anything else of value.

Gifts, Entertainment and Hospitality Expenses

Giving or receiving gifts, meals, or access to entertainment or hospitality may be acceptable as long as there is no expectation that the person who received the benefit will reciprocate with something in exchange for that attention and that meets specific lawful business purposes.

These courtesies must be previously reported and authorized by your hierarchical supervisor or by Management in the event that a public servant is involved and must be reasonable under the circumstances, not excessive or infrequent.

Gifts, access or expenses for entertainment that have the purpose of influencing decision-making or that could affect Chariklo’s business relationships should not be accepted.

Every gift must be given and received in an honest and transparent manner. It is prohibited to give or receive gifts, access to entertainment or hospitality from public servants directly or through intermediaries such as distributors, suppliers, consultants, third parties or travel agencies.

It is important to mention that gifts, meals, entertainment or other types of payments from or to public servants carry a higher risk and may be prohibited or limited under local laws. For the purposes of this Code of Ethics, employees of government companies are considered public servants.

If you have doubts about whether you should accept or give a gift, food, access to entertainment and hospitality, and specifically if this is for a public servant, you should consult with Management and write to info@chariklo.net

Likewise, if you detect or suspect any breach of Chariklo’s Gifts, Entertainment and Hospitality Policy, submit a report to info@chariklo.net .

Interaction with Public Servants

Due to the nature of our business, we are sometimes required to interact with public servants. Transactions with the government are regulated by specific laws and are not the same as business with individuals.

Do not offer anything to a public servant, either directly or indirectly, in exchange for favorable treatment.

Obtaining any type of licenses, permits or procedures before Government agencies for the functioning and operation of the Company must be processed in accordance with the provisions of Chariklo’s Anti-Corruption Policy.

The Company will refrain from participating directly or indirectly in any contest or tender in which there are signs of corruption, responding in a timely and transparent manner to the information requirements and observations of the authorities.

Chariklo also prohibits, on his behalf or on behalf of:

Enter into contracts with distributors, representatives, advisors, business partners, agents, intermediaries, clients, contractors, managers, lobbyists, consultants or suppliers that could represent a risk of bribery or corruption. In other words, we should not negotiate or make payments to third parties if there is any indication that those persons may carry out any type of bribery or act of corruption.
Make payments for gifts, access to entertainment or hospitality to public servants or their family members.
Make “facilitation payments,” which are smaller payments or fees to obtain a government service to which we are entitled, such as the issuance of a visa.
Make donations or make payments to causes or political parties, with Company resources or in the name of Chariklo. You may make donations in your personal capacity and in accordance with applicable local laws.

Chariklo also prohibits any unethical conduct such as fraud, deception, extortion, collusion, use of false information, illicit enrichment or money laundering, financing of terrorism, among others. These actions constitute crimes, regardless of whether public servants are involved.

Finally, Chariklo prohibits any attempt to assist or conceal acts of corruption regardless of the benefit obtained for you, the Company or Third Parties.

In order to combat corruption, at Chariklo we are committed to:

Adhere to the anti-corruption laws of all countries in which we operate or that are applicable to us.
Comply with all financial reporting laws and regulations applicable to the Company.
Carry out all negotiations, purchases and financial transactions in accordance with our internal procedures and retain all records thereof for the appropriate time, to be reviewed in the event of an audit.
Ensure that payments we make or that are made on our behalf are exclusively payment for goods or services actually provided to our company.
Adopt internal controls and report, if necessary, to the corresponding authorities any cases in which an employee or third party commits an act of corruption.
Promote practices to effectively control corruption throughout the value chain, train staff on preventive measures and conduct dissemination campaigns.

If you are in a relationship with public servants and you are not sure if the way to act is correct, you can consult with Management.

If you detect or suspect any breach of our Anti-Corruption Policy, submit a report to info@chariklo.net .

Remember that it is your responsibility to report any suspicious activity, otherwise you could be complicit in the act of corruption and this may have consequences for you.

Donations

At Chariklo we are committed to improving the communities and the environment in which we work, and donations are our means of collaboration, however, they can also represent a risk for the Company, therefore, all donations, in cash as well as in kind, must be done for a legitimate purpose and for the right reasons.

You can find additional information by consulting Chariklo’s Donation Policy.

If you detect or suspect any breach of our Donation Policy, submit a report to info@chariklo.net .

Sponsorships

Sponsorships may represent a real or perceived risk of corruption and must therefore be carried out for a legitimate and reasonable purpose.

Sponsorships that Chariklo makes with institutions, associations or organizations must be aligned with the values and principles of the Company, in addition, they must guarantee that resources are not used for inappropriate or illegal purposes and must comply with the Sponsorship Policy.

If you detect or suspect any breach of our Sponsorship Policy, submit a report to info@chariklo.net

Conflicts of interest

These types of conflicts arise when the interests of an employee or a third party are inconsistent or interfere with the interests of the Company.

Conflicts of interest are a form of Corruption that consists of an action that may be unduly influenced by a personal, family or third party interest.

A conflict of Interest exists when an employee or a third party guides their decisions or acts for their own benefit, which is frequently of an economic or personal nature, contrasting with the responsibility to act for the benefit of the Company when they are representing it. A good criterion that we can use to know whether or not you have a conflict of interest is to imagine yourself explaining your actions to a friend, colleague or the press. Would you feel comfortable?

When acting on behalf of Chariklo, we must always put the interest of our Company above our personal interest. This means that we do not let our own interest, that of our family or any other relationship influence the decisions we make on behalf of our Company.

Conflicts of interest may affect our judgment, affect the reputation and image of Chariklo and expose it to possible risks, therefore we must avoid conflicts of interest, real or that may be interpreted as such, in matters related to hiring, promotion or any other dealings with the Company or our dealings with other business interests outside the Company.

Likewise, we must not accept gifts, favors or access to entertainment or hospitality that could influence our decisions or affect the Company’s business relationships.

Many employees have family members or people with a close relationship who are employees, customers or suppliers. Family, personal and/or friendship ties should not be considered in the assignment of jobs or in the selection of a supplier, this can lead to actual or potential favoritism, as well as a lack of objectivity in such assignments, therefore For this reason, assignments of this type are prohibited within the Company. It is important to remember that employment decisions should be based on qualifications, performance, skills, efficiency and experience.

The Company does not encourage the secondary employment of its employees or any other activity or action external to the business, such as the opening of a new business where they have the role of owner, advisor, consultant, officer or director of any other business of their own or from third parties.

It is prohibited for the employee, due to his or her nature, to interfere with the interests or reputation of the company or have a negative impact in terms of competition.

You may not be employed by, or otherwise provide services to, or receive payment from, any customer, supplier, or competitor of the Company.

Any conflict of interest must be declared by the person or parties involved to Management.

If you detect or suspect any breach of our Conflict of Interest Policy, submit a report to info@chariklo.net .

Dealing with Our Suppliers

As noted in the previous section, your personal relationship, where applicable, with our suppliers and business partners must not create conflicts of interest, affect your objectivity or give the appearance of improper conduct, so in such cases you must refrain from make decisions that may be influenced by that relationship.

These risks arise particularly when business relationships are made on behalf of Chariklo with family, friends or third parties or when we receive or give a gift, meal or other payment from or to a supplier, especially when this is from a government company.

Any conflict of interest must be declared to Management.

We must maintain a professional relationship with our suppliers and business partners to ensure that we comply with the values and principles set forth in this Code of Ethics and make every effort to ensure that our suppliers promote and adhere to these principles.

We must select our suppliers based on the merits, costs and efficiency of their products and services; communicate to current or potential suppliers, in a clear and precise manner, the Company’s needs; and ensure that you receive adequate value for the price paid.

All interactions with our suppliers must be in accordance with established procedures, which include legal and registration obligations.

For the purposes of selecting and contracting suppliers and any third party that provides goods or services to the Company, the established guidelines must be followed .

If you detect or suspect any breach, we invite you to submit a report to info@chariklo.net .

Due Diligence for Employees and Third Parties

The Human Resources area together with Management are responsible for establishing policies, procedures and protocols to prevent the incorporation of people who may generate a risk of Corruption and affect the integrity of the Company.

Chariklo has a Due Diligence Protocol for Employees that allows evaluating, managing and monitoring the Company’s Employee candidates, as well as the Company’s Employees, in order to identify Warning Signs regarding anti-corruption.

Management is responsible for establishing policies, procedures and protocols to prevent and manage the incorporation of high – risk third parties through: (distributors, suppliers, managers, business partners, etc.) allowing:

The evaluation of the experience, soundness or financial sustainability of third parties;
Identification of final beneficiaries;
The identification of relationships and contacts between legal entities, individuals and final beneficiaries with government entities and officials;
Monitoring to identify the history of sanctions and litigation of the third party and associated individuals;
The analysis of the history of the ethical behavior of the third party, through reports in case they have incurred crimes related to Corruption, financial crimes or unethical conduct or bad corporate and ethical practices.

For the hiring of any third party that provides goods or services to the Company, the guidelines established in the Third-Party Due Diligence Protocol and Chariklo’s Purchasing Policy must be followed.

If you detect or suspect any breach, submit a report to info@chariklo.net .

Prevention of Money Laundering

At Chariklo we adhere to laws that prohibit money laundering or terrorist financing. Employees must know and comply with these provisions in order to prevent the services offered by the Company from being used to hide or simulate the origin of resources of illicit origin.

Given the vulnerable activities to which the Company is subject, employees must always remain alert to situations that may represent the incorporation of resources of illicit origin.

If you detect or suspect any non-compliance, submit a report to info@chariklo.net .

Economic Competition

At Chariklo we recognize that markets that are subject to processes of economic competition and free competition, dynamic and efficient, on the one hand generate economic development and a healthy economy in the countries in which these companies are established, and on the other hand, strengthen the internal efficiency of the economic agents that operate under this model.

Therefore, we are convinced that we must always compete based on the price and/or merit of our products and services, as well as our ability to provide them in an innovative and efficient manner. Therefore, we assume the commitment not to carry out acts or conduct of collusion with competitors, as well as to carry out or be subject to any commercial practice that illicitly restricts economic competition in the markets in which our Company participates.

Likewise, we understand that there are economic activities carried out by Chariklo or its divisions and that, by virtue of their nature, they are regulated by laws and various regulations regarding economic competition in each of the countries where we operate. Therefore, we assume the obligation to understand these legal systems and we have the firm conviction of complying with them in accordance with their legal and economic nature.

On the other hand, we are convinced of preventing the acts we carry out from reasonably appearing to be prohibited conduct, since violations of economic competition laws can have serious consequences for the Company.

In this sense, we should not discuss any issue with a competitor if this communication could be or be interpreted as affecting free competition, except in cases permitted by law and in compliance with the legal requirements established for this purpose.

We ask that you consult with our Management before exchanging information, discussing commercial issues, negotiating or contracting with a competitor.

If you detect or suspect any breach, submit a report to info@chariklo.net .

Use of Company Assets

We must take care of and make efficient use of all the tangible and intangible assets of our Company, since they are necessary inputs to carry out its activities and operations. Among others, we can mention the following:

Real estate and personal property;
Tools, supplies, vehicles, inventories, consumables, devices and telephone exchanges;
Telecommunications networks and equipment and their components;
Computer equipment and applications such as email and voice mail systems;
Internally developed software or third-party licenses;
Financial resources, investments;
Concessions and other authorizations to operate telecommunications networks;
Industrial and intellectual property rights,
Information about products and services and financial and business information.

We must reasonably use Company property in the performance of our work and not for personal gain or an unauthorized purpose.

Likewise, we must protect the Company’s resources, comply with all procedures related to the operation and security of said assets to prevent them from being damaged, lost, stolen or wasted.

Financial resources

Any person who has control over the Company’s financial resources, including cash, cash equivalents, securities, credit instruments or credit cards, is personally responsible for their safekeeping, administration and use in the operation of Chariklo.

We must also ensure that all income and expenses of the Company are properly documented, in accordance with applicable legislation.

Political Activities

Chariklo has no ideological, political or partisan affiliation, but respects the right of its employees to collaborate civically in non-profit professional associations and in citizen organizations that promote the legal and responsible exercise of political rights.

All employees enjoy the most absolute freedom to exercise their political rights without being pressured, directly or indirectly, to do so in favor of a party or a specific person.

However, in order to allow the Company to comply with the legal provisions that apply to it, the participation of our employees in political and/or electoral processes must be strictly in their personal capacity, outside of work hours and without express reference or implied to Chariklo and may not involve under any circumstances the use of financial resources or other assets of the Company.

In addition, some laws that govern us contain provisions that prohibit Chariklo and its employees from making donations, contributions or other payments, whether in cash or in kind, to political parties, employees of political parties and candidates for elected office, including from other countries. Therefore, our Company’s financial resources cannot be used to support any candidacy for political office.

If you detect or suspect any breach of the aforementioned principles, submit a report to info@chariklo.net .

Sustainability

Sustainability for Chariklo means ensuring a balance between the economic, social and environmental aspects, so that the company can continuously generate a positive impact on the communities in which it operates and its environment, thus reaffirming our commitment to being an agent of change that promotes inclusion, economic growth and well-being.

In that sense, we are oriented towards our company and its divisions being catalysts for the development and improvement of people’s quality of life, through digital connectivity, road awareness, actions to preserve and care for the environment, among others. .

Likewise, we work continuously to keep our operations aligned with the best national and international standards, the Sustainable Development Goals established by the United Nations.

Any act that may put Chariklo’s sustainability at risk must be reported to info@chariklo.net .

Our Duty to File Complaints

Each of us must report directly through the complaints portal, any conduct that violates this Code of Ethics or any applicable law, regulation, policy or internal procedure and, in general, any unethical conduct.

We must cooperate with any internal or external investigation and maintain its confidentiality. Employees who make a false or malicious report may be subject to disciplinary sanctions.

Remember that failure to report an ethical offense may have disciplinary consequences for you, as you could be covering up an unethical act or crime. Anonymous complaints may be filed if the complainant so wishes. In this case, it is recommended to leave a contact to follow up on the investigation.

Chariklo will take all reasonable and justified measures to protect whistleblowers and no retaliation will be taken against you for reporting. To the extent possible, the Company will maintain the confidentiality of complainants.

No provision of this Code of Ethics will be understood as an obstacle for people who feel affected or witness any illegal conduct to directly file complaints with the competent authorities. In such cases, it is recommended to notify our Management so that, if necessary, they can assist with the corresponding authorities.

All complaints received will be managed, attended to and investigated by Management.

For any complaint we put at your disposal the email info@chariklo.net .