INTEGRITY PROGRAM

A Commitment That Strengthens Our Legacy

Sondotécnica’s Integrity Program reflects senior leadership’s commitment to ethics, transparency, compliance with the law, and respect for human rights. The Program is built on structured policies designed to prevent, detect, and address misconduct.

CODE OF ETHICS AND CONDUCT

• Establishes principles of integrity, respect, and transparency;

• Prohibits unlawful practices, including corruption, harassment, and discrimination;

• Reinforces information security and data protection;

• Establishes standards governing relationships with clients, suppliers, and government officials.

COMPLIANCE AND ANTI-CORRUPTION POLICY

• Ensures compliance with applicable laws and regulations;

• Structures the Compliance Program with a focus on prevention and monitoring;

• Establishes mechanisms for reporting misconduct and irregularities;

• Requires due diligence in hiring, contracting, and business partnerships;

• Prohibits bribery and political favoritism.

REPORTING AND TRANSPARENCY CHANNEL

• Available to employees, third parties, and business partners;

• Ensures anonymity, confidentiality, and protection against retaliation;

• Overseen by the Ethics Committee.

DISCIPLINARY ACTIONS AND CONSEQUENCES POLICY

• Establishes measures applicable to violations of the Code of Ethics and internal policies;

• Applies the principles of promptness, proportionality, and non-discrimination;

• Possible measures include warnings, suspension, and termination;

• Also applies to business partners;

• Responsibility is shared among the Ethics Committee, Human Resources, and Legal.

RESPONSIBILITIES

Senior Leadership: Promote an ethical culture and support the Integrity Program.

Ethics Committee: Review cases, provide guidance, and oversee the Program.

Compliance and Legal: Monitor risks and ensure compliance.

Employees: Comply with applicable policies and standards, report misconduct, and participate in training.

CONCLUSION

Sondotécnica’s Integrity Program reinforces trust, ethics, and transparency as core pillars of the way we conduct business, while promoting a safe, responsible, and sustainable workplace.