CODE OF ETHICS AND BEHAVIOR AT BUSINESS.

November. 2021

MANDATORY

To all Collaborators:

Dear Ald3ano Collaborator:

We appreciate your interest in being part of the Ald3a team and then we allow ourselves to present our policies and processes for ethical behavior in accordance with the best business practices based on the United Nations Global Compact, which establishes that companies will make their own, support and they will put into practice the 10 fundamental values or principles in matters of Human Rights, Labor Standards, the Environment and the Fight against Corruption to the current regulations. Principles that find their foundation in the Universal Declaration of Human Rights, the Declaration on Fundamental Principles and Rights at Work, the International Labor Organization, the Rio Declaration on Environment and Development, and the United Nations Convention United Against Corruption.

CODE OF ETHICS AND BEHAVIOR IN BUSINESS

Without further ado for the moment, we remain at your service for any additional clarification you may require in this regard and we confirm our appreciation for your cooperation.

Sincerely

steering committee

Punta Santa Fe Torre-1 1st Floor Office 109

Prolong. Paseo de la Reforma # 1015 S100 P1

Santa Fe, 01376 CDMX, Mexico

Alvaro Obregon

1 SCOPE

Since its inception, Ald3a has been committed to operating with work values based on respect for the person and their integral development, professionalism, commitment, inclusion, teamwork and meritocracy. Likewise, Ald3a operates under the principles of trust and loyalty that over time we have generated in our employees, collaborators, suppliers, shareholders, investors, clients and other members of our community. It is an integral part of our vision to make Ald3a one of the best companies in Mexico and in the world, always distinguishing ourselves by our focus on human development, sustainability, security, transparency and high standards in corporate governance.

We must all accept the responsibility that we have in being part of Ald3a and act in a manner consistent with our core work values and protect the reputation of our company. In this sense, it is essential that all of us at Ald3a work in coordination, as a team and putting the interest of the company before any motivation of a personal nature or of our own professional aspiration. Consequently, individualistic behaviors or those that tend to affect others in search of personal benefit are not acceptable. On a daily basis, we must focus our work on achieving the objectives set for the company within the framework of the responsibilities granted, as well as the lines of authorization and controls set by our organization chart and internal policies.

It is the obligation of everyone at Ald3a to grant excellence in quality and service to our clients, suppliers and collaborators so that the prestige of our brand continues to grow. In our daily relationships we must act with respect, honesty, responsibility, transparency, consistency, truthfulness, personal and professional integrity and inclusion. To continue operating under these premises, we have created this Code of Ethics, which we hope will be a guide for all of us.

Adherence to the Ald3a principles set forth herein will foster a work environment with high professional and human standards. Therefore, we consider that this Code of Ethics will reaffirm our commitment to adopt these values and to conduct ourselves day by day in order to ensure that we and our company fulfill our objectives and commitments in a responsible way, in harmony with our own wishes and wishes. those of our community.

This Code of Ethics is not intended to replace our good judgment, nor is it intended to intimidate or judge; however, it tries to focus our attention on the behaviors associated with each of Ald3a's guiding values, thus allowing us to effectively conduct both our business and our professional relationship. Compliance with this Code of Ethics is expected to provide an example of the foundations that must be built to achieve our objectives as members of Ald3a.

Area of application

The scope of this Code covers all the people who make up Ald3a Int3ligente:

To the members of the Administrative Body
- Shareholders
- Directors
- Counselors
To all staff
Providers

2.INTRODUCTION

This Code of Ethics describes the values and principles of behavior that we must observe and carry out when carrying out our work, identifies and recognizes the correct behaviors and sets out how we must act in conflict situations. Likewise, this Code of Ethics seeks to serve as a guide to make the best decisions in our work, in full adherence to the principles that govern the development of this company. By virtue of the above, it is essential to understand the content of this document.

Our daily actions and behavior reflect who we are as individuals and representatives of Ald3a, for this reason and to correctly reflect how we want to be seen by our collaborators, suppliers, shareholders, investors, clients and other people with whom we relate or coincide in the performance of our daily work, we must adhere to the values and ethical lines of conduct established in this Code. However, this Code of Ethics is not intended to be exhaustive, nor to include all situations in which an ethical conflict could arise. Situations not foreseen in this document must be resolved in accordance with sound administrative criteria and good judgment. Any questions or comments that may arise in relation to this Code of Ethics should be consulted with the immediate Manager, the Human Capital area (rh@ald3a.com), administration, ultimately, with the address of Ald3a.

3.OBJECTIVES

The Ald3a Code of Ethics aims to:

Reflect the corporate values and the basic principles that should guide the actions of all the collaborators that make up Ald3a. The Code of Ethics and Conduct aims to develop the models and guidelines for professional, ethical and socially responsible behavior that should guide all the people who make up this team in the exercise of their activity.

Establish the principles to which the behavior of individuals who collaborate for or interact with Ald3a must be subject.
Make known to Ald3a employees, collaborators, suppliers and directors, among others, the behavioral obligations that govern relations with Ald3a.
Indicate the procedures to be followed and the people to contact in conflict situations.
All rules, policies and processes of behavior are applicable to third parties that collaborate with Ald3a and must adhere to these guidelines without restriction.

Goal

Ald3a is committed to strict compliance with the regulations for the prevention and fight against corruption, developing the principles included in the Code of Ethics and Conduct; and extending its compliance not only to all employees of our company but also to our business partners.

As a defender of the United Nations Global Compact, Ald3a is committed to complying with the 10 Principles established by said Pact, including working against corruption in all its forms, including extortion and bribery (Principle No. 10).

As a manifestation of compliance with these principles, the Administrative Body approves this Policy, which must be understood as an essential tool to prevent both Ald3a and the rest of the people who fall within the scope of this Policy from incurring Conduct that may be contrary, not only to regulatory provisions but also, where appropriate, to the aforementioned basic principles of action. For this reason, this Policy regulates the actions, indicating those that are prohibited, whether they are carried out directly or indirectly or through people.

Basic principles of behavior

Respect for the law: All the people who work at Ald3a will maintain strict respect for the current legal regulations in the performance of their professional activities.
Ethical integrity: Personal integrity and professional ethics are very valuable assets for Ald3a and therefore all people must carry out their activity with objectivity and professionalism.
Respect for human rights: The actions of Ald3a and the people that compose it will keep scrupulous respect for Human Rights and Public Freedoms included in the Universal Declaration of Human Rights.

Relationship with and between people

Work environment and respect for people: Ald3a strives to create work environments where trust and respect for people's dignity, cordiality and the effort of teamwork prevail. Ald3a expressly prohibits any abuse of authority, as well as any other conduct that could create an intimidating and hostile work environment. Each of the members of Ald3a will contribute to maintaining a pleasant, rewarding and safe work environment that encourages people to give their best. Consequently, all employees have an obligation and responsibility to treat their colleagues, superiors and subordinates with respect and must contribute to maintaining harassment-free work environments.
Labor Rights: Ald3a is committed to the defense, respect and protection of basic labor rights, and of human rights and public freedoms recognized in the Universal Declaration of Human Rights, as well as the Ten Principles contained in the United Nations Global Compact. . To this end, Ald3a does not directly or indirectly employ child labor or people who perform forced labor.

Equal opportunities and non-discrimination: Ald3a guarantees equal opportunities and is committed to using the means to help all staff in their professional and personal development. Likewise, it does not allow any type of discrimination based on gender, race, sexual orientation, religious beliefs, public opinions, nationality, social origin, disability or any other circumstance that could be a source of discrimination.

Reconciliation of work and personal life: Ald3a considers that the integral development of its employees is positive both for them and for the company, therefore it encourages measures aimed at achieving a balance between the family / personal and professional responsibilities of its employees.

Occupational risk prevention: Ald3a understands the occupational health and safety of its personnel as a fundamental condition to achieve a comfortable and safe work environment, with the permanent improvement of working conditions being a priority objective. For this reason, all personnel must know and rigorously comply with the health and safety regulations established in the company and all employees have the right and duty to communicate any situation in which the safety and health of the company is being endangered. Workers.

Confidentiality: In general, all persons subject to this code must keep professional secrecy regarding any non-public data or information they know due to the development of their professional activity.

Relations with Third Parties

Company brand and image: Ald3a considers that its brand, image and corporate reputation are among its most important assets, so all its employees must ensure that their behavior does not damage the image and reputation in any way.
Quality of service, customer service and fair competition: Ald3a is constantly concerned with improving its offer and the quality of its products and services, as well as establishing relationships of trust and mutual respect with customers. Out of respect for customers, ALD3A expresses its commitment to compete in the market in an active but fair manner, respecting the free market and antitrust rules established for this purpose.
Relationship with suppliers: All the processes for the selection of supplier companies will be developed in terms of impartiality and objectivity. Relationships with suppliers that violate the law or the basic principles contained in this ethical code may not be established.
Conflicts of interest: Ald3a considers loyalty as an essential principle, which, on the other hand, is compatible with the possibility that employees can carry out other business or professional activities, provided they are legal and do not conflict with their responsibilities as employees. by Ald3a.
Environmental Protection: Ald3a is a company strongly committed to protecting and respecting the environment and for their part, all staff must protect and respect the environment and minimize negative environmental impacts, work with maximum energy efficiency and respect the preservation of biodiversity.
Anti-corruption and bribery: Ald3a is against unethical practices aimed at improperly influencing people's actions and willingness to obtain advantages. Consequently, no employee should admit or practice bribes, or offer benefits for the benefit of third parties who are at the service of any organization (public or private) to obtain advantages or conduct business, whatever their nature, reporting through the established channels how many uses of corruption come to your attention, as established in the Company's Anti-Corruption Policy.

Compliance with the code of ethics and conduct

The principles and criteria for action contained in this Code of Ethics and Conduct are mandatory. To guarantee the application of the Code, as well as the supervision and control of its compliance, an Ethics Committee will be set up, as a management body, consultation and answering of doubts about content, which will be managed by the Human Resources manager of Ald3a.

The HR manager will be competent to receive information and complaints related to violations of the Code, guaranteeing the confidentiality of all persons who use the procedure established for the communication of complaints, which will be the email address rh@ald3a.com. Complaints that are processed will be dealt with by the Code of Ethics and Conduct Committee through an exhaustive analysis of possible breaches of the Code and respect for the persons allegedly involved in them.

The decisions of the Ethics Committee are binding on the company and on all affected employees. Failure to comply with any of the performance criteria contained in this Code of Ethics and Conduct will be sanctioned in accordance with the current disciplinary regime, without prejudice to any other responsibilities that the offender may have incurred.

VALUES

About us?

We are a company that integrates use cases, with a focus on customer experience solving the business challenges of our customers.

Ald3a provides a wide range of IT solutions to the most successful local and international companies. Driven by a group of trained collaborators with extensive professional experience, committed in various fields of specialization, Ald3a keeps up to date on emerging and evolving technologies, while achieving the successful delivery of cutting-edge solutions related to ICT, to meet the requirements and satisfaction of our customers.

We are focused on point of contact technologies with a service delivery team with over 25 years in enterprise computing infrastructure. We have a work team with different profiles and roles of professionals, from support engineers and infrastructure operation in critical environments; communications and even business process experts. All oriented to deliver high quality services, this characteristic being a fundamental part of our value proposition.

Ald3a is a company aimed at supporting organizations to solve business problems related to the customer experience at any point of contact and that it is satisfactory, generating loyalty and future visits. As well as its exploitation, management and monetization; This supported by Partners with the leading technologies in the market.

To serve our ever-growing customer base, we have pioneering spirit and industry vision to develop new services and solutions for the IoT era.

Vision

We want to be an ally in customer experience looking for the end customer to find a unique and repeatable event in each contact. Generating a differentiator of value for our clients and their business. Through being a transformation agent in point of contact technologies. Providing world-class, industry-leading advice, products and services to meet the business challenges of today and the convergence of tomorrow.

Mission

Generate value in the IT and business areas for our clients based on the knowledge and experience of our consultants, as well as the solutions of our Business Partners.

Our values

Integrity

Above all, we act with integrity. We maintain at all times our professionalism, objectivity and excellence in the quality of the service that we offer, always attached to commercial ethics with world quality. We always honor our promise to meet the expectations of our customers, shareholders and employees.

Teamwork

We provide the best of our capabilities by creating high performance professional teams oriented to success, the achievement of goals and the objectives of our clients. Each and every one of us who are part of the Ald3a team are committed to giving the best of ourselves, within a framework of responsibility, inclusion and human development.

Innovation

We focus on the user experience to improve our offer and communication with our customers, partners and collaborators play a key role in our innovation cycle. We seek an approach oriented to business creativity, always looking for new solutions that are at the forefront of technological convergence and trends that add value to our clients' business objectives.

Perseverance

We are tenacious because we seek to achieve the achievements of our clients and our own. Looking for productive, profitable and innovative projects through solutions that add value to business objectives. We are constant in the pursuit of everything we started, until we find the best way to execute it.

4. RELATIONSHIP WITH CUSTOMERS AND BUSINESS PROCESSES

The purpose of Ald3a is to be the best option for its clients. That is why it treats them with professionalism and integrity, while providing them with quality services and products, in a timely manner, in the place and under the agreed conditions.

The company and those of us who are part of it also seek to act in an innovative and proactive way, so that we exceed our clients' expectations, anticipate their needs, and thereby ensure a long-lasting, mutually beneficial relationship.

Customer Service

When choosing its clients and / or markets, with the exception of legal restrictions, Ald3a does not establish discriminatory differences of any kind, but rather selects its markets based on business criteria. Illegal discrimination is a violation of our Code and the laws of free competition, for this reason such acts will not be tolerated. If you witness or suspect any illegal discrimination against a customer or market, report the situation immediately to rh@ald3a.com or to your Manager.

Relationship with Clients

We strive to promote the practice of the standards in our Code. For this reason, we promote among our clients compliance with the stipulations of this Code of Ethics and Conduct and we recommend that they carry out their activities within the framework of current laws. For this reason, if we identify that a client is involved in illegal or unethical acts, it could result in the termination of the relationship.

Commitments and Promises

One of the values within the company is to provide a treatment to clients in which, on the one hand, integrity and professionalism are distinguished and, on the other, arrogance is excluded. To create and maintain this trust and credibility between Ald3a and its clients, our principle is to establish as a commitment only what we can fully comply with. However, if due to unforeseen circumstances it is not possible to carry out the contracted commitment, it is the obligation of the person involved to inform their immediate boss and the client.

Promotion and Sales Arguments

We seek that the promotions and sales arguments that we use in Ald3a are free of false information in relation to the availability, delivery date or quality of our products, as well as the terms of sale, including payment. We must offer our products and services honestly and accurately.

Employing deceptive or dishonest practices is a violation of our Code of Ethics and our values, and will not be tolerated.

Equity and Justice in the Relationship with Suppliers

Ald3a's principle is within a framework of confidentiality and respect - it seeks to grant suppliers the same opportunities to hire them, without generating false expectations and always keeping congruence and consistency in the supply process.

The evaluation of the offers for the selection of suppliers is based on the criteria established by our company

Relationship with Suppliers

It is Ald3a's commitment to strive to promote the practice of the standards of our Code. For this reason, it encourages its suppliers and associates to comply with the stipulations of this Code of Ethics and Conduct and recommends that they carry out their activities within the framework of current laws. Ald3a will investigate, on a case-by-case basis, reports submitted for possible illegal or unethical activities, and if true, it could result in the termination of the relationship.

We must always manage our supplier relationships with honesty, respect and integrity, offering equal opportunities to all parties, including equal opportunities to bid and win contracts. Our purchasing process must be consistent, respectful and confidential.

Our criteria for the selection of suppliers are:

Have 3 offers from different providers
Evaluate quality, delivery time and scope of offers
Evaluate the price they offer us and their payment conditions
Always seek reciprocity with our partners and suppliers
Always privilege suppliers who have been loyal and have supported us in the development of our company even when their offer is not the most competitive in a reasonable margin and the business allows it.
Adherence to sustainable and sustainable business practices.

Vendor onboarding must follow established guidelines and relevant documentation must be provided and approved before we can enter into a business relationship. Payment terms and other contractual obligations must adhere to Ald3a policies.

Respect for the Terms of Contracts, Licenses, Laws and Regulations.

One of the principles that move us at Ald3a is respect for the agreements and commitments established in our contracts. We also respect intellectual and industrial property rights and therefore the staff cannot establish commercial relationships with contractors or suppliers that do not demonstrate that they are duly authorized for the use or commercialization of products and services subject to the payment of royalties or intellectual property rights or industrial to third parties, as well as the authenticity and legality of the same.

Relationship with Clients and Suppliers

We must treat all our customers and suppliers fairly, adequately, and in compliance with all applicable antitrust laws; and we must not take undue advantage of our market position with any of our products or in the geographic areas where we operate. There must be a legitimate business reason for selling the same product at different prices to customers with similar locations, such as a difference in cost or participation in a tender.

Relations with the Government

We work respectfully and with integrity with all government agencies and officials.

We must comply with all antitrust laws and regulations.

Normative compliance

We operate internationally and are subject to many laws and regulations. We also often come into contact with government representatives in the development of our activities.

At all times we must deal honestly and cooperatively with government representatives and treat them with respect.

When a government representative requests information or documents that are in the possession of Ald3a, such requests must be coordinated with the Commercial Directorate and the administration area.

Managers must ensure that they are familiar with the laws and regulations governing the business unit for which they are responsible and that they are prepared to handle the regulatory risks they may face.

Relationship with Competitors

Competitive actions must always be justified by important business considerations. No deal should be made with our competitors that illegally restricts free trade. Examples of these types of illegal practices include price agreements, group boycotts, and supply manipulation. In practically all countries, these types of agreements have serious legal consequences, including jail time and very high fines.

We must consult the Commercial Directorate before preparing or signing agreements and contracts or taking actions that could violate laws or regulations on trade and competition.

Although some contacts with competitors are unavoidable and may be perfectly legitimate, it is important that if you have any doubts, you consult the Commercial Management before making such contacts.

For example, when a competitor is at the same time a customer or supplier, it is appropriate to maintain a business relationship as one would with any other customer or supplier. The conversations should be limited to matters about the transaction in progress, and it should be ensured that the person who attends the customer is not also responsible for competing with him.

The safest way to avoid illegal agreements with competitors is to avoid attending meetings and not maintaining other types of communication with them, unless it is clearly demonstrated that this type of contact has a purpose allowed by law

General Prohibition on Corruption

All forms of bribery are illegal and unethical. We will investigate any allegations of corruption and take disciplinary action and, where appropriate, legal consequences against those involved.

According to international anti-corruption laws, we must not promise, offer, compromise, pay, lend, give or in any way transfer things of value to a government or private agent or official, in those cases in which the contribution is illegal. This includes from contributions in cash, to indirect contributions, such as authorizing the official to use the resources or facilities of the company. Legal contributions require the proper authorization of the director of the area and must be recorded in accounting and within a framework of ethics and responsibility without any conditioning on future transactions.

Expenses for Gifts, Travel and Entertainment

Gifts, entertainment expenses or other courtesies for the benefit of any representative of any client are only permitted when there is a reasonable and legitimate business justification. In all cases, said courtesies must be of a lesser nominal value or legal, said courtesies require prior approval from the Commercial Directorate.

Travel expenses of any representative of any client paid by Ald3a, must have a reasonable and legitimate justification of business, such as a visit to the location where the project will be developed. In all cases, said travel expenses must be legal and have the approval of the Commercial Directorate.

All gifts, travel and entertainment expenses must be registered in strict accordance with the provisions of the laws and procedures established by Ald3a.

The allowed expenses must be reasonable for the daily consumption of any person and for practical and reference purposes the following parameters must be taken:

Breakfasts $ 35 Usd.
Foods. $ 50 Usd.
Dinners $ 50 Usd.
Drinks up to 2 drinks per event.
Expenses should never be paid to companions or relatives of the invited client.
Room in case of Lodging may be standard type. And only for the nights justified for the event to which you have been invited.

Dealing with Intermediaries

We cannot do indirectly what we are not authorized to do directly. Therefore, we must not use intermediaries or third parties for them to make inappropriate payments.

Ignorance is not a sufficient excuse to violate anti-corruption laws. Before dealing with third parties or intermediaries, we must ensure that their good reputation and their willingness to comply with the provisions of our Code of Ethics. The Commercial Directorate can support you in conducting an exhaustive review and gathering the necessary documentation from the prospect to act as an intermediary.

Money laundering

We must recognize the signs of money laundering and ensure that we do not facilitate or support the process of covering up the origin of illicit funds from criminal or terrorist activities through our legitimate businesses.

Money laundering is the process of concealing the nature and origin of money or other property connected with criminal activities such as drug trafficking, terrorism, bribery, or corruption by integrating illicit money or property into the flow of trade in a way that appears legitimate or that its true source or owner cannot be identified. People involved in criminal activities try to hide the proceeds of their crimes or make them appear legitimate by “laundering” them through legitimate companies.

If you have any concerns about payments or transactions or when doing business with a party that refuses to provide details about the transaction or information about their identity, or if you suspect any involvement in money laundering activities, such concerns should be reported immediately to your manager or to the Commercial Directorate, or through rh@ald3a.com

5 CONFLICTS OF INTEREST AND BUSINESS OPPORTUNITIES

All of us who work at Ald3a have the obligation to act honestly and ethically, always seeking to protect the interests of the company. Collaborators must avoid situations that signify or could signify a conflict between personal interests and those of our company.

Personnel with Outside Interests or Independent Businesses

We are expected to dedicate our talents and best efforts to the company and to preserve for it a sense of loyalty. This means that we must not:

Participate in any business or activity that directly or indirectly competes or interferes with the company.
Take advantage of our position or position in the company to obtain personal benefits, including members of our family or third parties.
Receive income and / or benefits from suppliers, competitors or customers. Exceptions are the cases of people who hold a position on the board of directors of a company, and have been authorized by the Board of Directors, having been previously notified. The cases of people who hold positions in non-profit civil associations, such as educational institutions, are also excepted.
Company personnel can purchase our products for their own consumption, as long as it is in accordance with the established policy for this. Ald3a reserves the right to verify the final destination of the purchased product. In no way can those who work at Ald3a have businesses dedicated to the commercialization, distribution, transportation or transformation of our products or services.

Personnel as Provider

Ald3a staff is not allowed to be a supplier to our company at the same time. Hence, whoever owns a business must refrain from providing Ald3a with its products and / or services.

Staff Relatives as Clients or Suppliers

Ald3a staff must not participate or influence –directly or indirectly– in the requirements, negotiations and decision processes with clients or suppliers with whom they have a family relationship, or any other interest other than those of Ald3a, for which they can obtain benefits. personal.

Ald3a seeks to keep its operations free of conflicts arising from unfair practices by its personnel. Ald3a staff must avoid situations that give rise to conflicts of interest between personal interests and the interests of Ald3a. These situations must be notified to rh@ald3a.com or to the steering committee.

Conflicts of interest

When personal or third party interests intervene or appear to intervene in the interests of Ald3a, including those of its subsidiaries and affiliates. A conflict of interest occurs when someone who works at Ald3a seeks personal benefits or when a member of Ald3a or a member of their family receives undue benefits from the company. It is the obligation of everyone who works at Ald3a to notify their immediate boss if they have family business owners who are or intend to be suppliers or clients of our company.

Shareholders as Clients or Suppliers

The shareholders who have or intend to establish a commercial relationship with Ald3a are subject to the same procedures and conditions as the rest of our suppliers and clients.

Shareholders and / or Staff with Family Members in Ald3a

Family members of the staff and / or shareholders of our company can work for it as long as they meet the requirements for the position. They are hired by following the selection procedure established by the Human Resources Department. However, it is prohibited for a person who works in the company to directly or indirectly supervise a family member. Any internal movement or labor decision is subject to the labor practices and policies applicable to all Ald3a personnel.

Conflicts of Interest Report

Situations that involve a conflict of interest are not always obvious or easy to resolve. As Ald3a employees, we are expected to report actual and potential conflicts of interest to rh@ald3a.com In similar circumstances, Ald3a managers and directors must report and follow up on those transactions or relationships that could lead to these kinds of conflicts.

Conflict of Interest Management

In the event of facing a real or potential conflict of interest, in our personal and professional relationships or activities that we carry out in the company, we are expected to face the situation in an ethical manner and in accordance with the provisions of our Code of Ethics and Conduct.

Gifts, Hospitality and other Courtesies

We cannot accept or give courtesies of any kind that compromise, or appear to compromise our decision-making process in any current or future negotiation. It is forbidden to condition or seek to condition a negotiation in exchange for any gift, attention or courtesy.

Accepting Gifts, Services and Other Courtesies

Gifts, services, and other courtesies from current or future clients, vendors, consultants, or service providers are acceptable only when given for legitimate business purposes.

We are not allowed to structure or seek to structure a negotiation based on a gift, hospitality and courtesy from a client, supplier, consultant, service provider or any other third person. Additionally, it is not allowed to receive gifts, services or other courtesies from third parties, except when they are legitimate promotional materials or hospitality in line with acceptable business standards and practices. If accepted, said courtesies must have the written authorization of your immediate supervisor, and above all, they must not compromise or give the appearance of compromising your integrity or objectivity, or create an expectation of obligation towards the third person.

We must not request, negotiate or accept discounts or courtesies from suppliers, consultants or service providers for our own benefit or that of others unless such action is legal, ethical and a generally accepted business practice between Ald3a and the third party. Additionally, make sure you have the written approval of your director or manager. Nor should you request or accept donations for altruistic purposes from clients, suppliers, consultants or service providers, unless Ald3a, in collaboration with other companies, decides to support said campaigns or associations.

Giving Gifts, Services and Other Courtesies

Gifts, services and other courtesies for the benefit of current or future clients, suppliers, consultants or service providers are permitted only when they are given for legitimate business purposes. In all cases, such courtesies must be legal and require prior written approval from your immediate supervisor. Any expense must be recorded in the accounting according to the processes established by the company. You are not authorized to condition or seek to condition a negotiation based on any gift for a client, supplier, consultant or service provider.

Bribery and / or Extortion

Under no circumstances is bribery and / or extortion allowed. If any person in the company is being subjected to bribery and / or extortion in their work relationships, inside or outside the organization, they should report it immediately. Similarly, when the case of a third person from the company who is being subjected to some kind of extortion and / or bribery is known, it is our responsibility to report them to our manager or through rh@ald3a.com

6.SAFETY

Security and Preservation of Assets

It is the responsibility of the personnel working in the company to maintain an adequate environment of order and cleanliness in the facilities, which contributes to safe practices and the elimination of risky conditions at work.

The people who work at Ald3a participate proactively in the design and implementation of the security measures necessary to protect the assets in our care. Likewise, we are aware of the need to respect and enforce safety regulations, as well as to report any act that puts employees, workplaces or the communities where we operate at risk.

Confidential or Privileged Information

At Ald3a we consider that obtaining and making good use of information are competitive advantages, so its administration and management must be done in a responsible, safe, objective and legal manner.

Confidential information is understood to be any information that is received from the following sources:

internal Ald3a
that includes a confidentiality legend
that is received from clients or partners not officially published regarding the company, its subsidiaries and affiliates, and its directors, stakeholders, operations, activities, plans, investments and strategies.

The following is considered, without limitation and not limited to, confidential or privileged information:

Accounting information and financial projections
Mergers, acquisitions, associations, expansion plans and business plans.
Operations with securities and financing
Business and operational policies and practices
Judicial or administrative disputes
Organizational changes
research and development of new products
Personal information of Ald3a employees, customers or suppliers
Intellectual and industrial property, such as industrial secrets, trademarks, patents and copyrights
Lists of clients and suppliers, structures and pricing policies

In general, all the information that a client or supplier shares with us must be considered confidential and must be used for the exclusive purposes of the service that we are providing. Once the work is finished or reached, it must be returned to the original source of origin and proceed to erase and destroy all the work copies that have been generated. It is the obligation of the person who received the information, under protest to tell the truth, that he will keep all the evidence of the destruction of the same at the end of the process or service.

Security and Management of Confidential or Privileged Information

It is the responsibility of each of us to make good use of the information. Whoever has collaborators is jointly responsible for the proper use that they make of the information, so they must take the necessary measures to guarantee compliance with the provisions of the information security policy. The use or distribution of confidential or privileged information without authorization violates the provisions of this Code of Ethics and Conduct, and may even be illegal.

Use of Confidential or Privileged Information

Those of us who work at Ald3a should in no way reveal or communicate confidential or privileged information to third parties, except when required for business reasons and with authorization to disclose it; We must always have NDA's signed with third parties that for reasons of a project we are sharing information. In this case, you must always notify your immediate superior or the person responsible for the information in writing. If there are doubts about the handling of confidential or privileged information, the immediate superior, if applicable, or the person responsible for the information, should also be consulted.

When for a justified reason confidential or privileged information is disclosed or communicated to Ald3a personnel, the nature of “confidentiality” must always be warned. In the case of third parties, a Confidentiality Commitment Letter must be obtained from them.

It is forbidden to use confidential or privileged information for personal gain or profit, either directly or through another person; this may cause loss, damage or impairment of the interests of Ald3a or its suppliers.

The misuse of confidential or privileged information may have civil or criminal consequences, without prejudice to the disciplinary action established by the company in this case. Safeguarding confidential or privileged information is the obligation and commitment of shareholders, directors, administrators, commissioners, general staff, external auditors, service providers, suppliers and clients of Ald3a.

Information Requirements by Authorities and Third Parties

When any governmental authority requires information from the company, the request can be attended as long as it is presented in writing, meets the requirements of the law, and has the authorization of the immediate superior, the management and any other party involved. It is important to comply with the requirements established by the different regulatory bodies to which the company is subject.

Confidential Information of Third Parties

Ald3a respects the intellectual and industrial property rights of other companies and requires that its employees respect these rights. This means that we will not misuse proprietary or proprietary documents or materials. Additionally, we should never disclose confidential information about companies we have previously worked for. Never copy or share confidential information without first being sure that you can do it, in case of doubt consult your manager or Director or email rh@ald3a.com

Subject to the provisions of the legislation of each country, the inventions, improvements, innovations and developments generated by those of us who work at Ald3a, in direct relation to our work and responsibilities, are the property of the company. Finally, just as we have the obligation to protect the information of the companies in which we have previously worked, we also have the obligation to protect the confidential or privileged information of Ald3a even after separating from it.

7.DIVERSITY AND INCLUSION

Our success is based on diversity and the origins from which each one comes.

Recruitment, promotions, training, compensation, and benefits should be based solely on ability, professional experience, and adherence to Ald3a values.

We must value differences and provide an inclusive work environment for all, including staff and stakeholders.

We must also comply with local laws and practices and must not make employment-related decisions or discriminate based on one of the characteristics protected by law, including:

Age
Race
Ethnic origin
Religion
Gender
Disability
Marital status
Sexual orientation

8.NON-COMPLIANCE WITH THE CODE OF ETHICS

Consequence System

Living our Values fully benefits us personally and those around us; the company encourages it and publicly recognizes exemplary cases. That is why when a person engages in conduct that is detrimental to the organization, there will be a consequence, which can range from a warning to dismissal, without prejudice to any action, obligation or sanction resulting from current law.

Remember that supervisors have the responsibility to be an example in the practice and promotion of Values; This implies giving recognition to his team, as well as applying the sanctions in a timely manner in the event that his staff have engaged in unwanted behavior.

Each of us must ensure that our colleagues live the values and principles of our Ald3a Code of Ethics and Conduct. Failure to comply with what is stipulated in it will be considered a misconduct and the person involved may be subject to disciplinary actions.

If any collaborator considers that a colleague, client or supplier is incurring in a possible violation of the Code, they can file a complaint through their supervisor or to the mail rh@ald3a.com

Procedure for filing a complaint regarding non-compliance with the Code:

Inform your manager or direct once you become aware of the breach
The complaint must be by mail including the following information:
1. Date and details of the incident
2. The involved parts.
3. The section of the Code that you believe has been violated.
4. A description of the actions taken by both parties to resolve the matter.
5. Offer supporting documents if you have them
6. The solution considered should be applied.
7. The mail should be addressed to:

Whistleblower Channel

If employees have evidence, doubts or suspicions regarding any form of corruption, they must immediately notify their hierarchical superior or the Company's Human Resources manager.

Complaints from people subject to the scope of this Policy will be processed through the channel referred to in point 3 of the Code of Ethics and Conduct and will be resolved by saving the confidentiality of the sender. Ald3a will not tolerate any retaliation against anyone who, in good faith, communicates facts that could constitute a breach of this Policy. Employees who violate these provisions will be subject to the corresponding disciplinary measures, including the termination of the contract, as well as other possible actions and / or legal sanctions.

In the event that complaints or communications of suspicious behavior are raised by customers, this must be processed by email to the address rh@ald3a.com with the identification of the person who communicates the query or complaint, detailing the circumstances of the complaint. itself and accompanying, as far as possible, the evidence or indications that support it. You must also identify the person (s) responsible for the alleged irregularity.

9. COMMUNICATION AND USE OF SOCIAL MEDIA

We wish to correctly express our passion for Ald3a and our mission, but if we are contacted by a stakeholder, investor, analyst, or member of the media, we should immediately direct such requests to business management or the CEO.

Only official Ald3a spokespersons are authorized to provide corporate information to the media, analysts and other outside parties.

We should not make statements outside of Ald3a about the performance or initiatives of the company or about any other internal matter. We must keep all confidential matters safe; Any external presentation or discussion related to our business must be previously reviewed and approved by the management committee. We must not participate in any online activity that could damage the reputation of Ald3a.

Keep in mind that you need to get approval from the steering committee to create or use Ald3a accounts on any social media site and only authorized people can do so.

In addition, we must all use social media responsibly. Some helpful guidelines for posting or contributing online include:

Keep in mind that what we say could be misinterpreted as a company statement. We must make it clear that we are speaking in a personal capacity and never on behalf of Ald3a.
We must remember that our behavior can affect the perception of Ald3a.
Keep in mind that what we write will be public. Probably forever.
We cannot engage in harassment or inappropriate behavior or commit any other violation of Our Code, our policies, or the law online.

10.GLOSSARY OF TERMS

For the purpose of the Code, the terms used have the following meaning:

Code Administrator: Independent person or body appointed by Ald3a to monitor compliance with the Code, as well as the resolution of complaints that may arise.
Company: It refers to any entity or company or legal person with which there are commercial exchanges.
Corruption: Offering, promising, granting, receiving, requesting or accepting an unjustified benefit, for oneself or for a third party, to unduly favor another in the acquisition or sale of goods, in the contracting of services or in commercial relations.
Customer / Consumer: Anyone who buys and / or consumes products from an independent seller and / or a Direct Selling company.
Extortion: the one that, for profit, forces another, with violence or intimidation, to carry out or omit a legal act or business to the detriment of his patrimony or that of a third party.
United Nations Global Compact: a voluntary initiative of corporate citizenship that asks companies to own, support and put into practice a set of fundamental values in terms of Human Rights, Labor Standards, the Environment and the Fight against Corruption, which are materialize in 10 principles.
Facilitation payment / Gifts / intermediation: payment of a small amount made to lower-ranking public officials, whose purpose is to speed up or facilitate the performance of their responsibilities, such as access to public services, obtaining licenses.
Order: Written or printed document that confirms the details of a consumer order, the terms and conditions of the sale of the product, its characteristics and sales receipts.
Product: Tangible or intangible consumer goods and / or services.
Prospecting: Commercial activity carried out in order to offer a product or service for sale to a person or company
Direct Sales: The commercialization of general consumer products, carried out directly to customers, at their workplace or other places outside the commercial premises, usually through the explanation or demonstration of the products by a seller.
Seller: It is a person or entity dedicated to the activity of the Direct Sale of products or services and prospecting potential customers.
Gift: in a broad sense, in this Policy, it includes the gift itself, gifts, advantages, favors, free dispositions or any other physical present or pecuniary donation.
Bribery: the one who corrupts someone with gifts to get something from him.

11.NOTE OF CONFIDENTIALITY

The information contained in all the pages of this document constitutes confidential information of Ald3a Int3ligente, S. de RL de CV hereinafter identified as Ald3a ™. And it is provided for informational and compliance purposes only. In return for receiving this document, the recipient agrees to keep such information confidential and not to reproduce or otherwise disclose it to anyone outside the company, unless authorized by Ald3a ™ in writing. There is no obligation to maintain the confidentiality of any part of such information that was known without restriction by the recipient prior to receipt of this document, as demonstrated by written business records; or of that information that is publicly known without the receiver having incurred in any fault; or that which is received by the recipient from a third party without restriction.

This document includes information regarding behavioral policies and processes that may be modified or discontinued at the sole discretion of Ald3a ™ who has made every effort to include in this document materials that are believed to be reliable and relevant for the recipient's compliance purpose.

Validity of the behavior policy

Unless otherwise agreed in writing and a new policy or process is published, it will remain in effect indefinitely.

If you have any questions or require any clarification regarding this Confidentiality Notice, please contact your human resources representative.

Copyright

All content included in this document, including text, graphics and images, is the property of Ald3a Int3ligente, S. de RL de CV or our associates, and is protected by national and international copyright laws. You may not copy, reproduce, distribute, publish, display, execute, modify, create derivative works, transmit or in any other way exploit any part of the copyrighted material without the permission of Ald3a Int3ligente, S. de RL de CV

All logos used in this document belong to their owner and are used for informational purposes only.

Resignation

This document is provided "as is". Ald3a ™ does not represent or guarantee the information, content, procedures and policies of any kind. To the extent permitted by applicable law, Ald3a ™ disclaims all warranties, express or implied, including, but not limited to, the implied warranties of merchantability or fitness for a particular purpose. Ald3a ™ will not be liable for damages of any kind arising from the use of this document, including but not limited to direct, indirect, incidental and consequential punitive damages. We reserve the right to make changes to this document and these disclaimers, terms and conditions at any time. Therefore, your consultation of this document is at your own risk.

Personal data protection:

Ald3a Int3ligente, S. de RL de CV (Ald3a) is responsible for their use and management, with a commercial office in Prolong. Paseo de la Reforma # 1015, Santa Fe, Cuajimalpa 01376 CDMX, Mexico Punta Santa Fe Torre-1 1st Floor Office 109, which is intended to hear and receive notifications. It informs you that your personal data will be collected in order to provide our products and services in Information Technology, development of consultations, recruitment and selection of collaborators, provision of services and correct identification of clients in the businesses that we develop, customer service customer service marketing campaigns as well as to integrate them into our internal records, to send information about news regarding the provision of our policies and processes, as well as for administrative and human resources purposes. The personal data that you receive from Ald3a as directed or copied in this document, must be treated in accordance with the Ald3a Comprehensive Privacy Notice made available to the owner prior to data collection; Likewise, the receipt of personal data in Ald3a is carried out with the understanding that you previously obtained the consent of the owners thereof. The processing of personal data in Ald3a is carried out in accordance with the Comprehensive Privacy Notice that is available on the website www.ald3a.com in the privacy notice section.