ANTI-CORRUPTION POLICY

Introduction

CIO NET S.A. DE C.V. Since its founding, it has always distinguished itself by carrying out all its operations, businesses and conduct in an ethical manner. It is for this reason that we have established a policy regarding acts of corruption, and it is clear: No type of offer will be tolerated, payment, authorization, request, or acceptance of bribes.

It is important to read and understand this policy in order to comply with and respect the spirit and content of the principles and procedures described in this document, when acting on behalf of CIO NET S.A. DE C.V. In all jurisdictions.

Any questions about the application of this policy or any suspicion of current or future non-compliance with anti-corruption laws must be submitted or communicated directly or anonymously to email.

lineaetica@cionetsolutions.com

General anti-corruption policy

At CIO NET S.A. DE C.V. We do not accept any act of bribery; therefore, we do not receive or grant monetary or in-kind exchanges to obtain personal or business benefits contrary to the law.

Bribing, receiving money, gifts, or handouts to obtain the aforementioned benefits affect the results and reputation of the company, as well as that of our collaborators and business partners.

These actions are illegal and may constitute various sanctions, including criminal ones.

CIO NET S.A. DE C.V.´s staff is obliged to treat people generally the same, so you will not grant privileges or preferences to organizations or individuals, nor will you allow undue influences, interests, or prejudices to affect your commitment to make decisions or perform your duties effectively.

• Buying and Hiring

No collaborator of CIO NET S.A. DE C.V. may request or accept any financial or other advantage, as an incentive or reward for its performance in relation to purchasing or contracting decisions.

• Fraud
  

It is strictly prohibited to deceive any person with the intention of obtaining a financial benefit and thereby harming them, whether acting on behalf of CIO NET S.A. DE C.V.  Or on your own behalf.

• Heist
  

Collaborators must respect the property and property rights of CIO NET S.A. DE C.V., as well as those of his colleagues and third parties related to the company. 

• Gifts
  

Gifts to evade the application of the law are strictly prohibited and anyone who uses this means will be subject to administrative sanctions or, where appropriate, the termination of the employment and/or commercial relationship, as well as the corresponding legal or criminal actions.

• Economic Extortion

The collaborators of CIO NET S.A. DE C.V. They will reject any direct or indirect request for extortion.

However, in any case, of presence or even presumption of extortion, collaborators must immediately channel it to the Ethics Complaint Line.

• Incorrect use of company resources
  

Conduct through which employees appropriate, misuse or divert resources owned by the company will not be tolerated.

The use of assets owned by CIO NET S.A. DE C.V. is prohibited for purposes other than those for which they were acquired, the foregoing for their own benefit or that of a third party.

• Gifts 
  

It is prohibited to give or receive any object of value to induce a person or executive to use their position and provide an advantage in their business relationship with CIO NET S.A. DE C.V.

No employee will accept, directly or indirectly, any type of object, gift, money, or invitation that is intended to influence actions or decision-making related to the company's business or that could lead the third party to be thought of as a supplier that could benefit or gain an advantage in some way.

The gifts received by the collaborators of CIO NET S.A. DE C.V. For reasons of the end-of-year festivities, they may be accepted as long as they are communicated to the General Management before receiving them.

• Accounting and operational records
  

It is strictly prohibited to falsify, alter, or manipulate documents, information, or reports for internal or external use, in a personal or company capacity.

All commercial transactions must be documented in writing and properly accounted for to ensure their traceability.

• Relations with third parties

Those responsible for hiring third parties must inform them of the Code of Ethics and Conduct and this Policy, and in the case of third parties acting on behalf of CIO NET S.A. DE C.V. They must adhere to its compliance.

Any conduct by third parties that contravenes the guidelines established in this Policy and/or the Code of Ethics and Conduct may result in the application of sanctions, which may range from the termination of the relationship to reporting to the corresponding authorities.

• Conflict of interests

Collaborators must not take advantage of the business opportunities that of CIO NET S.A. DE C.V. offers and intends to obtain personal income from third parties.

No supplier must have a relationship, family relationship or friendship with the company personnel empowered to decide on the selection and contracting of goods and services, except those authorized and documented by the General Management.

• Working Environment
  

CIO NET S.A. DE C.V. fosters and is part of a community where the climate of mutual respect, trust, and affection, solidly based on the moral integrity of its collaborators, is a fundamental pillar for personal relationships and where its directors, managers, assistant managers and immediate bosses must serve as guidance and example of others. 

• Accountability

At CIO NET S.A. DE C.V.  The Ethics and Conduct Committee is the body in charge of presenting the report to the Management, which details the conduct carried out against this Policy that may affect the reputation of the company and its collaborators, as well as determining the actions to be taken.

• Audits

In compliance with this Policy, CIO NET S.A. DE C.V.  will carry out the review through periodic audits to verify compliance with current provisions, policies, and procedures.

It is the responsibility of directors, managers, immediate bosses, or those who hire third parties to enforce the policy and lead by example.

• Penalties for non-compliance

All will be subject to sanctions and/or disciplinary measures ranging from a verbal and/or written warning to termination of the employment relationship for any violation of this Policy or the Code of Ethics and Conduct.

CIO NET S.A. DE C.V. will apply disciplinary measures fairly and in proportion to the offense presented in accordance with the provisions of the Internal Labor Regulations.

In the case of contractors or suppliers contractually linked to CIO NET S.A. DE C.V. who engage in conduct that violates this Policy and/or the Code of Ethics and Conduct, will be subject to the termination of the commercial contract and the corresponding legal actions will be applied.