INDEX

1. Introduction
2. General Ethical Principles of Conduct BCIE Central Bank of Business Innovation
3. Guidelines for Conduct
4. Relations with third parties. Commitments to our stakeholders
5. Ethical Channel
6. Regulatory Acceptance and Compliance
7. Validity

1. INTRODUCTION

1.1. OBJECTIVE and SCOPE

The Code of Ethics of BCIE Banco Central de Innovación de Empresarial (hereinafter BCIE) includes the principles of business culture and ethics that the organization must follow. Its objective is to raise awareness and sensitize BCIE staff, as well as stakeholders related to our activities.

This code is the basis of the Management System implemented in the organization, promoting its dissemination, monitoring, and control, with the aim of avoiding irregularities or non-compliance with our ethical principles, internal standards, as well as other legal and contractual requirements that affect the development of our activities.

Based on this code and through the management system, we define and maintain all necessary responsibilities, procedures, and management tools.

1.2. MISSION, VISION AND VALUES

Aware that national and international trade between companies constitutes an invaluable resource, our mission is to transform business development, in all its facets, into a vehicle for growth and sustainability for humanity.

The vision at BCIE is to ensure that our clients are more profitable and sustainable, guaranteeing universal access to the resources necessary for their business, economic, and social development, adding value to each new idea, venture, or business management task.

BCIE's purpose is to innovate in the efficient use of business applications and developments for more profitable and sustainable social growth for society as a whole. Therefore, we are firmly committed to aligning ourselves with the Sustainable Development Goals (SDGs), contributing to the social, environmental, and economic progress of our stakeholders.

BCIE Values ​​and Principles:

Human factor

We believe in people as the organization's primary asset and driving force. Consequently, we seek safe and healthy environments, offering opportunities to develop their personal and professional potential.

Customer orientation

We are prepared to adapt to demanding and dynamic markets, offering security, reliability, and innovative solutions that strengthen the quality, efficiency, and excellence of our products and services.

Collaborators and Strategic Partners

Our goal is to move forward together, building lasting relationships based on integrity, transparency, and mutual benefit. Therefore, we invite our Collaborators and Strategic Partners to adhere to the provisions of this Code of Ethics, thereby promoting good practices.

Society

At BCIE we are committed to the development of society, paying attention to the personal, social and environmental needs of the communities where we operate.

2. GENERAL ETHICAL PRINCIPLES OF CONDUCT BCIE

At BCIE , we aim to generate trust among our stakeholders. Therefore, we act responsibly and transparently, fostering integral relationships based on the trust, enthusiasm, and coherence that characterize us to achieve common goals, approaching projects with creativity and innovation; skills necessary to face challenges with agility and effectiveness. BCIE 's Management is ultimately responsible for promoting the values ​​contained in this Code, ensuring its compliance and proper functioning.

They constitute essential principles in the actions of BCIE:

2.1. INTEGRITY

Good practice and honesty have always been part of our culture. Acting with integrity in every decision and relationship, in compliance with current legislation, is one of our most valuable assets.

2.2. TRANSPARENCY AND PARTICIPATION

Acting with transparency means providing the necessary information that both our team and collaborators should receive, taking into account the quality of the information, which in all cases must be clear, complete, and accessible.

Aware that transparency is also a means of improvement, at BCIE we share our culture and commitment to the quality of our products and processes with our clients and collaborators.

2.3. TEAMWORK

Every person in the organization is part of the project that BCIE represents. Therefore, we encourage cooperation and teamwork, creating spaces for mutual learning.

Following this approach, we provide resources to enhance skills that enable personal and professional growth, promoting the integration and contribution of diverse points of view, thereby giving rise to new ideas.

2.4. EFFICIENCY AND INNOVATION

The I+D+i investments made by our collaborators and strategic partners constitute one of the pillars of BCIE's strategy. We support innovation and research to develop new technologies that allow for more efficient processes, products and services, better adapted to market needs.

3. GUIDELINES OF CONDUCT

In accordance with our principles and values, we are committed to following behaviors that reinforce the BCIE culture, behaviors based on:

– Respect for People, Society and the Environment.

– Compliance with applicable regulations.

– Fulfillment of our responsibilities and commitments.

3.1. Commitment to society and Human Rights

Every person involved in the activity of BCIE must respect the principles of:

– The Universal Declaration of Human Rights

– The Charter of Fundamental Rights of the European Union

– Other applicable rules depending on where we carry out the activity

At BCIE we will ensure that our staff and collaborators respect these principles, paying special attention to the following:

– Respect for human dignity

– Non-discrimination

– The abolition of forced labor

– The abolition of child labor

3.2. Respect for People

At BCIE, we act respecting the freedoms and rights of both individuals and groups, rejecting physical, psychological, or moral harassment and abuse of authority, including behaviors that may affect people's rights.

To prevent these behaviors, we educate our staff and partners on the importance of maintaining a relationship based on respect and cordiality, fostering peaceful, healthy, and safe work and cooperation environments. Our commitment to people and their development encompasses all of BCIE's activities, which is why we facilitate a work-life balance.

3.3. Personal development and equal opportunities

At BCIE, we promote equal opportunities without discrimination among individuals within the organization. We are committed to developing employees with equal opportunities, applying selection and promotion criteria based on the performance of professional duties, merit, and capabilities defined for each position, as well as our commitment to the principles of our Code of Ethics and Equality Plan.

3.4. Proper use of company assets

Company assets are understood to be the set of goods, rights and other resources owned by BCIE.

At BCIE, we provide employees with the resources and information they need to perform their duties. Employees must use the information responsibly and appropriately for strictly professional purposes. Unauthorized personal or private use is prohibited.

The safekeeping and proper preservation of BCIE's assets is the responsibility of each and every member of the organization.

3.5. Conflict of interest and loyalty to the company

We understand a conflict of interest as those circumstances where personal interests interfere with the fulfillment of professional responsibilities within the organization.

At BCIE we ensure that employees and collaborators do not have conflicts of interest, fostering relationships based on trust, loyalty, and mutual respect.

BCIE employees and collaborators may participate in other financial and business activities, provided they comply with legal requirements, do not constitute unfair competition, or interfere with their professional obligations within the organization. At BCIE, we maintain systems to manage any incidents that may occur in this regard or to anticipate them if we foresee them occurring.

3.6. Corruption and bribery.

At BCIE we establish as a strategic principle the fight against these bad practices, which seek to obtain benefits both personally and for the organization.

To achieve this goal, we establish the following guidelines:

– No employee or collaborator of the organization will use their position to offer third parties, directly or indirectly, payments in cash, in kind, or other unauthorized benefits, for the purpose of obtaining favorable treatment.

They will also not accept or request unjustified advantages for the purpose of obtaining purchases/sales of products or services.

– Similarly, no employee or collaborator may offer any benefit to public authorities or officials in order to obtain contracts, business deals, or other competitive advantages. Likewise, they may not take advantage of their personal relationship to obtain favors for themselves or third parties.

If it is detected and verified that any employee or collaborators and strategic partners incur in this practice, they would be immediately TERMINATED and REMOVED from BCIE and the case would be placed in the hands of the legal department or authorities if the circumstances so require.

3.7. Money laundering and terrorist financing

At BCIE we are committed to complying with the Anti-Money Laundering and Terrorist Financing Prevention Act, rejecting any conduct that could be related to its non-compliance.

Consequently, we will not establish any type of relationship with those who violate international regulations in this regard, as well as those specific to the country where we operate. To ensure compliance with this section, we have established policies and procedures to detect, prevent, and report these malpractices within the organization and its operations.

4. RELATIONS WITH THIRD PARTIES.

Commitments to our stakeholders.

At BCIE, we operate in an environment of transparency, seriousness, and professionalism, promoting relationships with third parties based on commitment and loyalty.

All members of BCIE will always act with integrity in our relationships with shareholders, clients, suppliers, collaborators, partners and other stakeholders, as this is an essential requirement for establishing lasting relationships.

4.1. Competition and Intellectual Property

Fair competition is the principle that governs BCIE's activity, complying with legislation on competition, market regulation, and consumer protection.

In particular, at BCIE we will not carry out actions that constitute abuses of a dominant position and we will avoid agreements with competitors, suppliers or clients that seek to hinder, restrict or distort free competition in the market.

BCIE employees must respect industrial property, know-how and, in general, the work carried out or created, whether by BCIE's activity or by third parties, always making responsible use of these assets.

At BCIE we comply with national and international standards regarding advertising that, in general, regulate its correct use, which must be lawful and truthful.

4.2. Commitment to Quality and the Environment

At BCIE, we are aware of the value of our environment and its resources; therefore, we have always been committed to Quality and the Environment for sustainable and responsible development.

4.3. Confidentiality and data protection.

At BCIE we guarantee the privacy and protection of personal data and other confidential information in our possession. To this end, we have security measures and procedures in place to protect information against unauthorized access, manipulation, or destruction, whether intentional or accidental, in order to safeguard the rights of our stakeholders.

BCIE employees may not reveal confidential information unless expressly authorized or legally required.

5. ETHICAL CHANNEL

Our ethical values ​​are complemented by providing an Ethics Channel where you can freely report any conduct that contravenes this Code or applicable regulations.

5.1. What is it and how does it work?

The Ethics Channel is an information system for reporting any act or conduct contrary to the values ​​and principles established in this Code of Ethics or in the legal system, with communications processed confidentially and impartially.

Stakeholders in BCIE's activities have the duty to:

Report any situation or conduct that violates the principles of this Code, or inquire about behavior suspected of violating this Code or applicable law, or report attempts to conceal such violations. All communications may be made via email.  

6. ACCEPTANCE AND REGULATORY COMPLIANCE

At BCIE, we promote professional environments that respect people's rights and comply with current legislation. Therefore, this Code of Ethics is binding on all BCIE employees.

The Management of BCIE prohibits any employee, due to their position or role, from requesting any employee or interested party to violate the rules and principles of this Code. Likewise, no employee may justify improper conduct based on a superior order or ignorance of this Code.

Any collaborating company, strategic partner, natural or legal person, who wants or wishes to hire the services of BCIE Banco Central de Innovación Empresarial, or provide their services to BCIE Banco Central de Innovación Empresarial externally or internally, must give their written consent to accept this code of conduct, committing to accept all the rules of conduct in this document.

The acceptance of this code of conduct and its signature does not represent or imply an employment or contractual relationship with any of the parties. BCIE Banco Central de Innovación Empresarial reserves the right of acceptance by persons or companies interested in collaborating with BCIE internally or externally.

Reviewed and approved:

Miami, Florida, 6/15/2024

                                                                            Jose Luis Reyes

                                                  President of the Central Bank of Business Innovation (BCI)