This Code of Ethics standardizes the company’s principles, values and expected behavior for all parties involved in the operations of VIAMATICA S.A. Through the day-to-day practices of employees, business partners, clients and suppliers, it serves as a guide for internal coexistence and for relationships with society.

OUR VALUES

• Respect: Treat colleagues and clients with courtesy and consideration, acknowledging a diversity of ideas and approaches.
• Resilience: Demonstrate the ability to confront and overcome challenges and setbacks, adapt quickly to change, and learn from adverse experiences.
• Passion: Continuously seek new learning opportunities and challenges to develop our skills in a dynamic environment.
• Transparency: Share relevant information openly and honestly both within the team and with clients.
• Consistency: Work steadily to overcome challenges and meet deadlines.
• Integrity: Act honestly in communications, respect intellectual property, and ensure the security and privacy of data.
• Teamwork: Value each person’s work and transform individual contributions into collective results.
• Responsibility: Complete assigned tasks within established timeframes and strive at all times to exceed client expectations.

REPORTING INCIDENTS

Every employee is responsible for reporting violations of this Code by raising concerns through one of the reporting mechanisms established in this document or by contacting the Human Resources department.

The email [email protected] is available during business days. Reports may be submitted securely and with confidence; they will be recorded and handled according to the established procedures. If it is proven that a violation of internal or external policies, regulations, or local laws has occurred, appropriate actions will be taken. Your anonymity will be protected at all times.

VIAMATICA S.A. 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.

Conditions for effective implementation of the code of ethics and conduct

1. Corporate culture and ethics
   • Leadership must give priority to ethical principles.
   • Ensure written compliance with applicable labor laws and regulations.

1. Development and content of the Code of Ethics
   • Content: Reconcile principles with specific rules.
   • Encourage partners to follow and practice this Code in all their activities, regardless of any potential conflicts of interest.

1. Publication and dissemination
   • Ensure availability and ease of internal and external communication.
   • Produce statistics and reports on incidents or complaints semiannually.

1. Monitoring system and sanctions
   • Handle complaints and follow-ups both internally and externally.
   • Do not postpone resolution of any ethical issue under any circumstances.

1. Penalties for non-compliance
   • Breaches of this Code may result in actions up to and including referral of the offender to the appropriate legal and administrative authorities.
   • All reported incidents will be thoroughly investigated.

CONFIDENTIALITY

In the performance of their duties, employees are regularly exposed to procedures, processes, clients, methods, systems, plans, projects and other industry-related matters that require strict confidentiality. Employees must not use or transfer to third parties any information or documents related to their job functions.

Employees sign a confidentiality agreement and, for any reason they leave the company, are obliged not to disclose at any time or in any manner the information or documents to which they had access while employed by the organization.

INTERNAL GUIDELINES – OBLIGATIONS

• EMPLOYEES

All personnel of VIAMATICA S.A. must adhere to this Code of Ethics and Conduct. Additionally, it is expected that anyone involved in activities related to the organization—suppliers, consultants or subcontractors, among others—will be fully familiar with the Code and act in accordance with its provisions.

VIAMATICA S.A. will ensure correct application of the Code and will monitor that contracted individuals and institutions maintain high ethical standards, ensuring that their reputation and conduct align with the required values and standards.

It is each employee’s responsibility to read and understand this document; if any point is unclear, they must request the necessary information to clarify their doubts.

WHAT IS EXPECTED OF EMPLOYEES

1. Foster mutual respect and comply with laws, regulations and established policies, as well as internal rules and this Code of Ethics and Conduct.
2. Support and act to build a community of ethical values, aware of the responsibility to contribute to the well-being of individuals and society.
3. Maintain loyalty, transparency and integrity in labor and commercial relationships, both within and outside the organization.
4. Act with honesty, transparency and integrity in all work interactions.
5. Maintain a high level of professionalism, refrain from cyber offenses that violate intellectual property rights or client data privacy, and always preserve professional confidentiality.
6. Do not attempt to deceive clients with unfounded technical claims about IT systems for personal gain or to cover up one’s own mistakes.
7. Clearly communicate to the client the scope of the project and the requirements necessary for its execution.
8. Fully document all systems developed for a company, providing the details necessary to understand the operation of any procedure or program.
9. Recognize that healthy competition among colleagues—based on intellectual challenge—can enrich ideas and contribute to personal and professional growth, but cooperation must never impair the company’s operations.
10. Help improve the effectiveness of existing relationships by communicating ideas and concerns quickly and responsibly, clearly and honestly, and by offering constructive input, suggestions and feedback.
11. Avoid making unfounded judgments about others and show respect for colleagues’ opinions, no matter how different they may be.
12. Approach supervisors whenever in doubt or when observing potentially inappropriate behavior.
13. Consumption of alcoholic beverages, drugs or other hazardous substances during working hours, or presenting for work under their influence, is prohibited.
14. Properly use and protect the company’s tangible and intangible assets, including information, products, licenses, services, logos, equipment, computers, mobile phones, etc.
15. Understand and become familiar with the information security standards and systems established in each area, and take necessary measures to protect confidentiality, integrity and availability.
16. Communication systems and media provided by the company and used by employees to perform their duties are property of VIAMATICA S.A. and must be used solely for business purposes.
17. Uphold, promote and act as active defenders of the principles established in this Code of Ethics and Conduct.

• COORDINATORS AND MANAGERS

Ensuring that VIAMATICA S.A. upholds high ethical standards is a fundamental management responsibility. Coordinators and managers commit to promoting an ethical culture and to enforcing the Code, which includes:

Defining, communicating and enforcing the organization’s policies, procedures and internal regulations.

1. Safeguarding employees and facilities through appropriate equipment, devices, systems and security procedures.
2. Promoting absolute respect for differences and opinions and prohibiting any form of harassment or discrimination.
3. Promoting absolute respect for differences and opinions and prohibiting any form of harassment or discrimination.
4. Recognizing employees’ good work and acknowledging it in due course.
5. Providing employees with opportunities for continuous training and development to advance their professional and personal careers.
6. When making employment decisions, consider only individual or collective merit and avoid discrimination based on age, race, religion, disability or marital status.
7. Consider implementing compensation and benefit programs to recognize employees’ achievement of goals and objectives.
8. Observe applicable human rights laws and promote the responsible use of natural resources such as water, energy and paper.
9. VIAMATICA S.A. will not maintain commercial relationships with companies or individuals who violate ethical standards, engage in illegal or degrading activities, or show contempt for applicable laws.
10. At all times strive to protect the confidentiality of company and client information.
11. Employees shall be selected and/or hired based on demonstrated skills and talents; they must meet the educational and competency requirements defined in the organization’s job profiles.
12. Make efforts to introduce and/or adopt environmentally friendly technologies that protect and preserve ecosystems and avoid the use of harmful products, processes and technologies.
13. VIAMATICA S.A. will continuously seek process certifications that benefit clients and the organization.
14. All transactions and records of business activity must be accurate, transparent and in accordance with generally accepted accounting principles.
15. Company accounts, documents, contracts and any other information must not contain incorrect or fraudulent accounting entries resulting from manipulation, distortion or falsification.
16. Recorded accounting operations must be supported by documentation that substantiates the transaction, complies with tax requirements and is accurate at the time the operation occurs.
17. Coordinators and managers must stay current in their areas of expertise in order to convey to employees the guidance that helps them better understand their responsibilities and achieve their objectives.

• PROTECCIÓN DE LOS BIENES DE LA EMPRESA

Employees of VIAMATICA S.A. must exercise special care over the assets entrusted to them in the performance of their duties and are obliged to report to their immediate supervisors any situation that could result in loss, damage, destruction or misuse of company assets.

Company assets, facilities and services must be used exclusively for legal, appropriate and authorized purposes. Theft of money, goods or services is strictly prohibited. Equipment, systems, facilities and supplies must be used only to carry out company business or for purposes authorized by management. Excessive use of telephone calls, internet access, email and social networks constitutes misuse of company assets and/or services.

• INFORMATION HANDLING

Commercial and professional information is the exclusive property of VIAMATICA S.A.; this information is a valuable asset. Protecting this asset, including its confidentiality, is fundamental to the company’s continued growth and competitiveness.

A trade secret is information related to a business activity that is generally not known or readily discoverable and for which measures have been taken to preserve confidentiality and maintain its secret character.

When an employee separates from VIAMATICA S.A., they remain obligated to protect trade secrets and other proprietary information of the organization. If in doubt about whether certain information is proprietary or a trade secret, employees must contact their immediate supervisor.

• BRIBERY OR EXTORTION

VIAMATICA S.A. prohibits offering money or any item of value to clients, suppliers, municipal or government authorities to obtain commercial advantages, secure contracts, retain business, exert undue influence for benefits and/or favors.

Directors, managers, coordinators, leaders and employees of VIAMATICA S.A. must exercise special care when contracting consultants, agents or business partners and must take appropriate precautions to:

1. Ensure that third parties understand and accept the company’s Code of Ethics.
2. Assess the reputation and qualifications of third parties.
3. Include appropriate clauses in contracts and agreements with third parties to protect VIAMATICA S.A.’s operations and reputation.

Any suspicion of bribery or corruption, inside or outside the organization, must be reported immediately to the Compliance Department at [email protected]

• COMPLIANCE WITH THE LAW

VIAMATICA S.A. complies with all laws, regulations and standards related to the development, marketing and use of software. The company also maintains licenses and intellectual property rights in accordance with Ecuadorian law.

The company respects agreements and contractual commitments as well as intellectual and industrial property rights. For this fundamental reason, VIAMATICA S.A. will not engage in business relationships with suppliers who cannot demonstrate proper authorization to use or market products and services, or the authenticity and legality of such products and services.

EXTERNAL GUIDELINES – RELATIONSHIPS WITH STAKEHOLDERS

 

• WITH CLIENTS

Clients are considered partners; the company’s success depends on the long-term relationships maintained with them. The company is committed to delivering proven, high-quality products and/or services. The services we provide must meet required safety standards and satisfy customers’ generally more stringent expectations.

The company’s success depends on customer satisfaction. Opinions, concerns and suggestions received by the company are considered valid sources of information. Since our clients’ needs are constantly changing, we must remain attentive to their wishes and use creativity to meet evolving needs.

When a client expresses dissatisfaction, we take the opportunity to address the issue, do everything possible to resolve it, regain their satisfaction, and earn their trust so they will continue to purchase the company’s products and/or services.

This Code of Conduct reflects our responsibility to protect client information. Personnel who do not need access to such information must refrain from accessing it; those who do require access must handle it properly and avoid disclosing or sharing data without authorization.

All employees, managers and coordinators of VIAMATICA S.A. must commit to negotiating fairly with clients, competitors, suppliers and coworkers. No one may take advantage through manipulation, fraud, abuse or any improper form of treatment or negotiation.

• SUPPLIERS

Suppliers are invited to comply with and adhere to the provisions of VIAMATICA S.A.’s Code of Ethics and Conduct.

The objective of procurement operations is to ensure reliable and continuous sources of supply. Honest treatment of suppliers is essential to establish strong, long-lasting relationships.

Decisions to select suppliers are based on objective criteria such as price, quality, warranty, reliability and integrity, on-time delivery and efficient handling of claims. Offering or accepting kickbacks, bribes or similar payments of any kind is strictly prohibited.

All our suppliers have the right to fair and equal treatment without advantages or disadvantages unrelated to the quality of the work, products or services they provide. Suppliers must comply with legal and commercial conditions when interacting with VIAMATICA S.A.

VIAMATICA S.A. will not maintain commercial relationships with suppliers of goods and services who violate laws prohibiting the use of child labor. To enforce this provision, the organization will require suppliers to include a clause in their contracts committing to comply with relevant laws.

• WITH COMPETITORS

Fair competition emphasizes the importance of developing under the principle of equity in the battle for market share.

VIAMATICA S.A. has an obligation to maintain a professional attitude toward competitors in its sector or industry. There are several circumstances that could infringe on free and fair competition, which employees, managers and coordinators must avoid:

1. Refrain from reaching agreements with competitors to avoid direct competition, restrict dealings with suppliers, make misleading offers, or divide customers, markets or production programs.
2. Do not influence prices or attempt to restrict imports or exports of goods supplied by particular vendors.
3. Be careful when making statements about competitors; when necessary, such statements should be fair, complete and objective.
4. Do not use your position to request, demand, accept, obtain or receive promises of advantages from third parties to the detriment of competing companies.
5. Employees may not lead or assist any organization that competes with VIAMATICA S.A.

• COMMITMENT TO THE ENVIRONMENTT

VIAMATICA S.A. is committed to environmentally responsible behavior, compliance with environmental rules, policies and procedures, and reporting any potential environmental risks. All coordinators are responsible for defining roles and responsibilities to protect the environment, providing appropriate resources, measuring, reviewing and continuously improving environmental performance. The company participates in environmental campaigns and practices with foundations and/or entities that raise awareness about minimizing environmental impact.

Priority is given to the responsible, careful and reasonable use of natural resources: water, electricity, paper and fuel. These efforts improve the company’s efficiency and financial performance. We continue to take decisive actions to reduce our environmental impact.