This policy applies to all employees, contractors and third parties that have a relationship with GRUPO VIAMATICA, and reflects top management’s commitment to upholding integrity as a core principle of the organization.

OBLIGATIONS

• Maintain honesty and integrity as a consistent standard in all actions.
• Comply with national laws and regulations relating to integrity and anti-corruption.
• Strictly apply measures to avoid entering into or maintaining business relationships with third parties whose organizations do not adopt anti-corruption and anti-bribery principles and standards equivalent to those of GRUPO VIAMATICA.
• Ensure that any information for which they are responsible is accurate, truthful and transparent. No information or record shall be manipulated for the purpose of altering or distorting results.
• Report any violation or suspected violation of this policy or of applicable legal requirements.
• Cooperate openly and transparently with authorities in corruption investigations.

FORMS AND MANIFESTATIONS OF CORRUPTION

The following are illustrative examples of corruption and dishonest conduct, without limiting the provisions of applicable law:

• Requesting personal benefits in exchange for performing duties, except in cases expressly provided for in the Anti-Bribery Management Procedure Manual.
• Creating false, incomplete or misleading entries or records; this includes falsifying overtime hours and using company resources for personal gain.
• Providing or offering any kind of benefit in exchange for receiving a favorable position or treatment within GRUPO VIAMATICA for oneself or for a third party.
• Abusing the status of an employee to generate personal gain for oneself, for another employee, or for a third party outside GRUPO VIAMATICA, whether that gain is material or immaterial.
• Receiving or soliciting concealed commissions or kickbacks — i.e., payments that do not appear in the contract and are not properly justified.

RISK ASSESSMENT

The main steps for conducting a corruption risk assessment are summarized below:

• Identify corruption risks that have occurred or that have been reported.
• Understand the nature of those risks — where they arise, why they exist, which processes they affect (or whether they exist due to the absence of processes), when they are most likely to occur, and which factors are related to them.
• Evaluate the magnitude of the risk to determine the potential impact.
• Implement tools tailored to the company’s specific needs that enable risk mitigation to be carried out collaboratively.

REPORTING OF INCIDENTS

Each employee is responsible for reporting acts of corruption by contacting the Human Resources department office. The email gestionantisoborno@viamatica.com is available during business days. Reports may be submitted securely and with confidence; they will be recorded and managed according to the established procedures. If it is proven that a violation of internal or external policies, regulations, or local laws has occurred, appropriate measures will be taken. Anonymity will be protected at all times.

GRUPO VIAMATICA will not tolerate any form of retaliation against anyone. Employees may raise concerns about this code and will not be subject to dismissal, suspension, threats, harassment, or discrimination for providing information and/or assisting with internal or external investigations into conduct that the employee reasonably believes to constitute a violation of policies, standards or applicable laws.