Code of Conduct

Introduction to Our Code

At DEUNA, we are committed to maintaining the highest standards of ethics and
integrity in all our actions. This Code of Conduct sets forth the principles and policies that must guide the behavior of all employees, executives, and business partners/strategic allies of DEUNA.

For DEUNA, it is essential that each of us acts responsibly and with integrity.

Our Code of Conduct and corporate policies represent DEUNA’s fundamental
principles and shared values, establishing standards for teamwork, harmonious coexistence, and prosperous results for the company. This responsibility reinforces our mutual commitment to our shareholders, customers, business partners, and the communities where we operate.

Responsibility and integrity are deeply embedded in our decision-making processes.
In today’s highly competitive business environment, doing what is right has never been more important. Acting ethically is a fundamental part of our history and culture.

All DEUNERS are encouraged to read our Code carefully and consult the resources
mentioned here in case of doubt. Reading it will provide a clear and comprehensive description of the expected conduct and available resources to facilitate compliance.

There is no substitute for good judgment and common sense, so trust your instincts
and act in good faith.

Our Responsibility

Each of us is obligated to act responsibly and with integrity within the company, with
customers, third parties, and others we interact with at work by:

• Reading this Code and its associated corporate policies carefully,
  understanding, and adhering to it.
• Taking individual responsibility for their actions.
• Always acting in good faith and with common sense.
• Cooperating with internal audits and periodic controls that ensure compliance
  with this Code and its policies.
• Understanding the consequences of violating this Code and its policies.
• Reporting any violations of the law, this Code, or company policies.
• There are several options to take action. You can communicate directly with your
  supervisor, the Legal department, the ethics hotline, or the Human Resources department.

Contents

DEUNA Code of Conduct

• Policies:
  1. ABC Anti-Corruption
  2. Use of the Ethics Hotline
  3. Competition and Conflict of Interest
  4. Know Your Client (KYC)
  5. Know Your Supplier
  6. Workplace Safety
  7. Business Continuity
  8. Corporate Brand Use
  9. Error or Omission Management

Equality and Non-Discrimination

At DEUNA, we do not tolerate any form of harassment, including sexual harassment or
any behavior that is hostile, disrespectful, abusive, discriminatory, or humiliating. We ensure that diversity is visible, valued, and sustained across the organization. We create an inclusive environment that nurtures the unique backgrounds, skills, and creativity each DEUNER brings.

DEUNA provides equal treatment and employment opportunities regardless of any
protected status or other characteristic. This applies to all aspects of DEUNA’s employment decisions, including hiring, placement, development, promotion, training, scheduling, benefits, compensation, and termination of employment.

Fair Treatment and Respect

All employees must treat their colleagues, clients, and business partners with respect
and dignity. Harassment, intimidation, and abusive behavior are strictly prohibited. We do not tolerate any form of workplace violence. Intimidating or threatening words or actions are also prohibited.

Conflict of Interest

Employees must avoid situations where their personal interests may conflict with
DEUNA’s interests. Any potential conflicts of interest must be disclosed and properly managed.

What is a Conflict of Interest?

• A Conflict of Interest occurs when an employee’s personal or financial interests
  interfere or appear to interfere with their ability to fulfill their work responsibilities and act in the best interests of the company.
• Any situation where DEUNA’s interests differ from those of a client or business
  partner.
• When a colleague’s financial or personal interests compete with those of
  DEUNA, a client, or a business partner.
• When DEUNA is unable to act in the best interests of one client without
  negatively affecting another.
• Approval from the Legal department will be required in any of the above.

Let’s always be cautious:

• Quickly identifying potential conflicts of interest.
• Avoiding situations where one client may be put in conflict with another.
• Consulting the Legal department immediately in case of doubt regarding a
  potential conflict of interest.
• Obtaining proper authorization from the Legal department to proceed with any
  matter that may present a potential conflict of interest.
• Establishing mechanisms within each department for the proper identification,
  management, and resolution of any conflict of interest.
• Avoiding accepting any external work that could be detrimental to DEUNA.
  Refraining from proposing friends or companies as suppliers or contractors with whom one may have a financial interest mentioned scenarios.

Compliance and Ethical Behavior

At DEUNA, we are committed to providing an optimal environment for everyone:
colleagues, clients, and business partners. Each of us is dedicated to acting diligently to safeguard the interests of the company and our colleagues. We must all be familiar with the recommendations and specific actions we should follow as team members to prevent and, if necessary, report potential errors or omissions. This is an obligation we all undertake as part of DEUNA. The participation of each of us is essential to preserve the company’s good name and reputation, in alignment with our sound business practices and commitment to excellence in service.

What is an error or omission?

An error or omission is a verifiable failure in our professional advisory and
customer care management, which jeopardizes the company’s continuity and image. This could lead to damages, penalties, fines, or even the termination of our operations.

What to do if an error or omission is detected?

• Report any error or omission, or any situation that could lead to a claim, to your
  immediate supervisor and the Legal department.
• Pay special attention to our actions toward clients, third parties, and
  colleagues.
• Refrain from taking any actions on your own until receiving instructions from
  your immediate supervisor or the Legal department.
• Avoid creating expectations for the person affected by the error or omission.
  Adhere at all times to this Code and other applicable regulations.
• Follow up on the report and ensure compliance with the requested forms.
• Pay attention to corrective actions to prevent errors or omissions from
  recurring.
• Consult the Errors and Omissions Policy.

Effective Communication

It is important that we always act when we see something that could be considered ethically questionable. Prompt communication helps us contain risk and maintain trust with the client.

Everyone is expected to collaborate in good faith and provide truthful information. Providing false information at the outset or during an investigation will be considered a violation of the Code and may result in disciplinary action.

No Retaliation

We will not tolerate retaliation against anyone who has acted in good faith to report an ethical or legal concern about their supervisor or peers. Rest assured that DEUNA will always protect you if your supervisor acts against you for raising a concern.

Common Sense

Above all, we expect our DEUNERS to use their common sense when identifying a concern. If you're unsure, speak up!

Protecting What Is Ours

It is crucial to keep in mind that we are responsible for the company’s assets, such as
the brand, confidential information, facilities, equipment, systems, and more; these must always be used prudently.

DEUNA’s technological resources are monitored at all times and without prior notice,
so it is important to use them responsibly, as well as any social media platforms made available to you. Any individual responsible for making discriminatory, offensive, obscene, improper, or harmful comments about DEUNA, its employees, clients, suppliers, or others will be held accountable, and appropriate disciplinary measures will be applied.

By working at DEUNA, you are identified and associated as part of our organization.
Anything you publish regarding the company, whether text or images, must be shared through authorized company channels. Processes, information, and other materials created by employees for DEUNA are the exclusive property of DEUNA.

Be mindful of the following:

• Use DEUNA’s assets exclusively for legitimate business purposes.
• Do not use company assets for personal purposes or to support any
  negotiations or activities unrelated to DEUNA.
• Some assets, such as phones or computers, may be used for limited personal
  purposes, provided the usage is appropriate and does not interfere with work performance.
• Make appropriate use of our brand, following the guidelines set by the
  Marketing department.
• Follow the recommendations from Human Resources and Marketing regarding
  access to social media and electronic forums. If in doubt, ask!
• Do not speak to the media about company-related topics without prior
  authorization. Obtain permission before distributing information to large groups of people.
• Protect and refrain from disclosing confidential information to colleagues,
  clients, third parties, or others.

All employees must be aware of and comply with the laws and regulations affecting
their work.

Fair Competition

We do not take unfair advantage of anyone through manipulation, concealment,
abuse of privileged information, distortion of facts, omission of information, or any other form of unfair business practice.

Operating fairly and in accordance with sound market practices is not only a
requirement of the high ethical standards we adhere to but also aligns with national and international competition and anti-monopoly laws.

We must always approach our clients with complete honesty and transparency,
acting in their best interest, never promising something we cannot deliver, and certainly refraining from making disparaging remarks about our competitors’ products.

No Corruption
At DEUNA, we do the right things for the right reasons. We must ensure that we do not:

• Accept or offer bribes or improper payments.
• Agree to actions or reach any understanding with a competitor to increase,
  decrease, coordinate, or stabilize prices or terms.
• Reach an understanding with a competitor aimed at dividing territories,
  markets, or customers. Discuss sensitive market information, such as prices, territories, and customers.
• Share documentation or future plans about a client's products or services with
  competitors. Make false or misleading comments about competitors during conversations with clients or business partners.
• Participate in formal or informal discussions with competitors on any sensitive
  matters.
• Accept "hidden" payments from business partners, or recommend clients
  influenced by payments received from business partners.
• Offer clients any good or service they have indicated they do not want or need.
  Conceal information or facts on which a client might reasonably rely to make business decisions.
• Use marketing techniques that exaggerate or misrepresent the cost, scope of
  coverage, contractual conditions, or benefits of products or services. Accept or request a quote from a business partner that has been inflated or contains amounts secretly intended to be returned to the business partner.

At DEUNA, we do not make improper payments to anyone. We do not offer or give
bribes directly or indirectly, nor do we use cash, gifts, meals, travel, entertainment, or loans to influence the decisions of clients, prospective clients, third parties, or government officials.

Therefore, it is essential that:

• All expenses, gifts, business entertainment activities, and payments are
  promptly, accurately, and transparently reported and recorded.
• We maintain proper accounting records and reliably present accounting
  requirements.
• We do not accept inappropriate gifts, entertainment, or events.
• We avoid potential conflicts of interest.
• We do not hold funds, accounts, assets, or payments that are undisclosed or
  unregistered for any purpose.
• We do not circumvent or bypass the company's internal accounting controls.
• We do not promise or directly or indirectly make financial payments or gifts to
  government officials to secure or retain business.
• We do not make improper payments to third parties, competitors, or
  commercial clients.
• We consult the Legal department to obtain assistance in determining the
  status of an individual as a government official.
• If the receipt of a payment cannot be proven to have reached a specific
  government official, the mere belief that a payment has been made is sufficient to constitute a violation of our internal policies and must be reported immediately.

Confidential Information and Privacy

Depending on the service we provide to our clients, business partners, and
colleagues, we constantly receive confidential information and personal data. For this reason, we ensure that such information is processed under the highest standards of quality and confidentiality.

Confidential Information: This refers to information/documentation that is not
publicly available and that could affect the price of a security or influence an investor's decision to buy, sell, or hold a security if disclosed. This information is frequently provided to us by our clients, and we are committed to maintaining and protecting it securely.

Personal Data: This refers to any information concerning a natural person, while
sensitive personal data includes information that, if disclosed, could affect the most intimate sphere of a natural person, leading to discrimination or posing a significant risk.

Commitment

As DEUNERS, we are committed to reading, understanding, and applying this Code of
Conduct and its associated Corporate Policies, which will be reviewed and updated periodically to ensure their relevance and effectiveness. We encourage you to provide feedback and suggestions for the continuous improvement of our ethical practices.