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CODE OF ETHICS OF CONDUCT

CODE OF ETHICS OF CONDUCT

Honesty and Integrity:

Honesty and integrity; with oneself, with others, at all times and in all places.

Dear friends:

Honesty and integrity in our actions define us as members of Lesseps. For this reason, at all times, in all places and with all people, we must always bear in mind the ethical and moral values ​​that precede our professional and personal behavior.

In this spirit, Lesseps has approved its Code of Ethics of Conduct, which I am pleased to present to you.

The people who make up the company are subject to the ethical code, from external collaborators to the president, through directors, administrators, managers, employees and advisers. Everyone, without exception, must apply it; and also encourage everyone else to apply it equally.

Those of us who are part of Lesseps are proud to be able to work here and we carry out a respectful, loyal and fair treatment with all people, always fulfilling our commitments and denouncing any action that has been committed, that is being committed or that is going away to commit, when this may be contrary to the law, internal regulations or our Code of Ethics of Conduct.

On the other hand, Lesseps will only maintain commercial and business relationships with those companies and individuals that are aligned with the principles and values ​​of our Code of Ethics of Conduct.

Sincerely,

Christian Mesía
CEO de Lesseps

What is the Code of Ethics of Conduct

The Lesseps Code of Ethics of Conduct (hereinafter also referred to as the “Code”) is a fundamental rule of an internal nature, although with a universal vocation, which has the primary purpose of establishing the ethical principles and basic guidelines of conduct that must preside over the behavior and actions, both internally and externally, of all members of Lesseps, regardless of their functions and responsibilities, their position in the organization chart and any other personal, social or work circumstance.

Who must comply with the Code

The Code is applicable to the CEO, administrators, executive directors, non-executive directors, directors of the different committees, executive directors, representatives, proxies, advisers, consultants, permanent and temporary labor personnel, subcontracted personnel, auditors, as well as, in In general, to any person or entity with whom the company maintains a contractual or pre-contractual business, labor or administrative relationship (hereinafter, without distinction, the “Subject Persons”, in the plural, or “Subject Person”, in the singular).

The Subject Persons have the duty to know, comply with and apply the Code of Ethics of Conduct and, consequently, must respect the values, principles and norms contained in the Code, both in their internal professional relationships with Lesseps and the rest of the Person. Subject, as in external relations with clients, suppliers, competing companies, public administrations, the State and society in general.

Our actions must be carried out in compliance with national and international laws and regulations.

3.1 Compliance with all applicable regulations

The Subject Persons have the duty to comply with, respect and apply the laws, resolutions, directives, statutes, regulations, orders, ordinances, recommendations and internal rules of Lesseps.

3.2. Obligation to facilitate investigations

The Subject Persons must support, facilitate and cooperate with any investigation that may be carried out by public administrations, regulatory bodies, the administration of justice ‒ judges, magistrates, prosecutors and / or judicial experts‒ or by Lesseps herself, her Regulatory Compliance Officer and any person or entity designated for that purpose.

We must always respect the People, the Environment, the Culture and Customs of the Countries where Lesseps is present.

4.1 Respect for People

Lesseps considers a fundamental value respect for the dignity of every human person for the mere fact of being human and, particularly, respect for the dignity of all the people who make up Lesseps, its clients, suppliers, shareholders and, in general, respect to the dignity of any person who has had, has or may have any relationship with Lesseps.

1. Lesseps demands that special care be taken in complying with the regulations on the protection of Fundamental Rights and Public Freedoms, invoking the Universal Declaration of Human Rights, signed by the United Nations in 1948, the International Convention on Civil and Political Rights of 1966, to the International Convention on Economic, Social and Cultural Rights of 1966, as well as the Convention for the Protection of Human Rights and Fundamental Freedoms of 1950.

Lesseps also accepts and particularly respects the Tripartite Declaration of Principles of Multinational Enterprises and Social Policy of the O.I.T., as well as the principle of union representation of its employees.

2. Lesseps prohibits harassment, abuse and discriminatory treatment on the grounds of race, color, nationality, religion, political opinion, affiliation, age, sexual orientation, status ‒including pregnancy‒, social and family status, disability, handicap and other situations protected by law, both with respect to employees, managers and members of the administrative bodies, as well as with respect to shareholders, clients, potential clients, suppliers and any other person who has a relationship with Lesseps.

Harassment, discrimination and personal retaliation towards any person who reports an act or conduct contrary to the law and / or this Code is also especially prohibited.

3. Lesseps promotes equal opportunities for employees of different sex and nationality. At the same time, it grants equal opportunities to suppliers for obtaining a percentage in the volume of purchases under the same conditions as the rest.

4.2 Respect for the Culture and Customs of the Countries

Lesseps starts from diversity as something clearly positive and understands that the cultural and customs differences that exist in the different countries of the world where it is present must always be worthy of deep respect from those who are part of the company.

Being honest and transparent we generate Trust, a fundamental value for Lesseps

Honesty and transparency are two fundamental values ​​that structure our behavior as members of Lesseps and, by complying with them, we generate greater trust among our clients and acquire a greater reputation.

5.1 Defense of competition

Lesseps respects and encourages free, fair and honest competition, understanding that with this we promote discipline in the performance of our companies and we force ourselves to reallocate our resources to achieve greater productive efficiency that benefits our clients and society in your set.

5.2 Conflicts of interest

The Subject Persons have the obligation to act solely and exclusively for the benefit of Lesseps, seeking only the interest of Lesseps, and are expressly prohibited from personally benefiting from possible opportunities that arise within the framework of professional activity or through the use of assets or information from Lesseps, as well as benefit third parties with them.

A conflict of interest situation will be considered to exist when, in the performance of their duties for Lesseps, a conflict arises between the personal interests of Lesseps members, their family members or third parties with whom they are directly or indirectly linked and Lesseps interests. These situations should always be avoided, whether they are real or just potential.

Notwithstanding the foregoing, in the event that a conflict of interest situation arises, the person affected by the conflict must refrain from intervening and / or participating in the negotiation or operation in question. In this way, the Persons Subject to this Code will refrain from intervening and / or participating in transactions of any kind in which there is an interest of their own or of any related person or entity.

5.3 Protection of Lesseps assets

All Persons Subject to this Code have the duty to diligently care for Lesseps’ property and assets, which may only be used, with the exception of laptops, tablets and / or telephones within the scope of Lesseps and for the exclusive benefit of Lesseps. . Thefts, robberies, negligent carelessness, malicious acts and undue spending cause an imbalance in the allocation and distribution of Lesseps resources and cause a decrease in profits and therefore the mentioned acts will be prosecuted by Lesseps.

5.4 Relations with the Public Administration

In the daily exercise of its activities, Lesseps maintains a direct and indirect relationship with local, regional, autonomous, national and international public bodies.

The Subject Persons must be sincere and rigorous with the agreements and contracts signed with the public administration.

5.4.1. Bribes and kickbacks

Monetary payments and other favors that are made in favor of third parties with the aim of acquiring an immoral benefit are constitutive of a crime, and may even be criminally convicted for this reason both the company and the person or persons who perform, are going to perform or support such payments.

Consequently, it is strictly forbidden to offer, deliver, request, receive or accept money or favors of any kind that produce an advantage over other competitors. The delivery of gifts, handouts and the performance of free benefits in favor of public officials and employees by reason of the position they hold in the Administration is also prohibited.