1. INTRODUCTION
Simetrik INC., its affiliates, and subsidiaries (hereinafter, 'The Company'), reaffirm their commitment to law, ethics, and integrity as fundamental pillars of all its operations and decisions. This Code of Ethics serves as a guiding framework for our employees, ensuring that our actions consistently reflect the values that define us, and that ethics, transparency, and regulatory compliance always take precedence over any commercial objective.
The Code of Ethics establishes guidelines that employees shall always uphold to demonstrate ethical behavior that enables them to build legitimate and productive relationships while acting with transparency and integrity in all business interactions.
2. OUR ETHICAL VALUES
In addition to our value principles-"We seek perpetual evolution," "We take care of our brain," "We are debaters," "We are radically honest," "We build together," and "We enjoy the struggle," The Company upholds the following ethical values:
Transparency
The Company operates as an open book. Information about our strategy, challenges, progress, obstacles, and general thoughts is accessible to all. We expect everyone to share their thoughts, ideas, challenges, and feelings openly and constantly.
Trust
We believe that to build the company of our dreams, every team member must trust that their colleagues are always doing their best and working in the best interests of those they collaborate with.
Reciprocity
All relationships should be reciprocal rather than unilateral. At The Company, we believe that reciprocity fosters lasting and high-quality relationships.
Collaboration
The Company is not the work of a single individual. It is the result of talented people coming together to share their knowledge and collaborate toward a common goal. We prioritize building together, valuing collaboration over competition.
Direct and Honest Communication
We believe that in a rapidly growing and evolving company, constant and effective communication is essential. Assertive, concise, and timely communication are crucial to our success. We encourage authenticity and the open expression of opinions while always maintaining respect and honesty in our interactions.
3. SCOPE
The Code of Ethics applies to all employees of The Company who are under employment contracts and/or apprenticeship agreements.
4. RESPONSIBILITY AND COMMITMENT
The implementation of the Code of Ethics is the responsibility of all employees. Therefore, every employee must familiarize themselves with this document and adhere to it with a proper understanding and interpretation.
The Code of Ethics applies to all Company employees, while the Legal & Compliance Department is responsible for its enforcement and oversight.
5. GUIDELINES
5.1. Building Business with Ethics and Transparency: Legal and Regulatory Compliance
The Company aims to conduct business professionally and with integrity, providing innovative solutions to our customers. To achieve this, we comply with all applicable laws, regulations, and international trade, intellectual property, data protection, and information security laws
Bribery, Corruption, and Fraud
We comply with local and international anti-corruption and anti-bribery laws and never engage in corrupt activities. All forms of bribery and corruption are strictly prohibited. We must never offer, pay, promise to pay, or authorize the payment of a bribe to obtain or retain an undue business advantage or influence an official action. Likewise, we must not solicit, accept, or agree to accept anything of value if it is intended to, or appears to, secure an undue business advantage.
The Company is committed to transparency and legality, implementing controls to ensure the proper recording of books, records, and accounts to prevent fraud, corruption, and bribery. We also have reporting mechanisms for such situations.
For more information, consult our Anti-Corruption and Anti-Bribery Policy, Anti-Fraud Policy, and Business Ethics and Transparency Program.
Gifts and Hospitality
We shall never offer or accept gifts or hospitality in exchange for business. Any gifts, courtesies, or hospitality extended to customers or suppliers must serve a legitimate business purpose. In all cases, such courtesies must be legal, approved by the Legal and Compliance Department, and comply with the Gift, Courtesy, and Hospitality Policy. All related expenses must be accurately recorded in accordance with established procedures.
Company employees are not permitted to accept gifts or courtesies from customers, potential suppliers, or third parties.
For more information, consult our Gift, Courtesy, and Hospitality Policy.
Books and Internal Controls
The Company maintains financial controls and records to ensure transparency in financial reporting. Employees shall, within the scope of their responsibilities, ensure that records accurately reflect reality, that controls are effective, and that reports and documents are subject to regulatory review and oversight.
The recording, retention, and preparation of financial reports shall comply with applicable legal provisions, generally accepted accounting principles, internal control standards, and The Company's guidelines.
Conflicts of Interest
All employees of the Company are required to act with transparency, honesty, integrity, responsibility, and fairness, always safeguarding the Company's interests. Employees must prioritize the Company’s interests over personal gain. A conflict of interest arises when personal interests, activities, or relationships have the potential to influence an employee’s responsibilities and commitment to the Company.
If you believe there may be an actual, potential, or perceived conflict of interest, you must report it immediately to your People Manager and the Legal & Compliance Department.
For more information, please refer to our Conflict of Interest Policy.
Fair Competition
Fair and honest competition is fundamental to our business and relationships. The Company does not tolerate unfair practices to compete or secure business. Employees must avoid practices such as:
- Engaging in misleading or deceptive conduct toward customers.
- Participating in anti-competitive practices, including agreements that restrict competition, abuse of market dominance, or unilateral actions that limit competition.
- Any other actions that reduce competition between the Company and its competitors.
Trade Controls
We comply with all applicable local and international trade control laws, including regulations governing exports, imports, and international transactions. If you have any questions, contact the Legal & Compliance department for guidance.
Anti-Money Laundering and Countering-Terrorism Financing
We must protect The Company and prevent criminals from using our systems to facilitate illicit activities such as money laundering, terrorism, and weapons proliferation financing.
To this end, we have established a risk management system that includes procedures, methodologies, and due diligence tools to identify, measure, control, and monitor these risks. Employees shall comply with all policies and procedures under this risk management system.
For more information, consult our Anti Money Laundering and Counter-Terrorism Financing Policy (AML/CTF).
5.2. Integrity in Our Work: Respect for Human Rights, Labor Standards, and the Environment
The Company recognizes its workforce as a strategic asset and is committed to fostering an environment that supports professional development. Employees must always uphold behaviors that reflect The Company’s established principles and values.
At The Company, recruitment, selection, and hiring are based on candidates' alignment with corporate values, competencies, and professional experience. The Company fosters work relationships that promote collaboration and teamwork to overcome challenges effectively.
Safe and Healthy Work Environment
The Company aims to promote and maintain a healthy and productive work environment that channels employees’ potential and creativity while fostering collaboration and teamwork.
Therefore, The Company:
- Complies with labor laws and regulations.
- Ensures absolute respect for differences and opinions in an environment of good practices, strictly prohibiting any form of harassment or discrimination.
- Safeguards employees and facilities (where applicable) through security equipment, devices, systems, and procedures.
- Promotes occupational health by implementing the best practices in risk prevention.
For more information, refer to our Internal Work Regulations and the Occupational Health and
Safety Policy.
Diversity, Inclusion, and Non-Discrimination
We are committed to fostering a diverse, equitable, and inclusive organizational culture that
respects and values differences within The Company.
For more information, consult our Workplace Harassment and Discrimination Prevention Policy.
5.3 Protection of the Company, Information, and Information Security
Confidential and/or Privileged Information
The acquisition and responsible use of information provide competitive advantages and require secure, objective, and legally compliant management.
Confidential and/or privileged information refers to acts, events, documents, or data related to The Company or its business network that must not be disclosed to the public or unauthorized individuals. This includes The Company’s proprietary commercial information and intangible assets.
Confidential information encompasses any unpublished data related to The Company, senior management, stakeholders, operations, customers, and suppliers. All employees shall protect confidential information about The Company, its customers, suppliers, and employees, even after leaving The Company. Additionally, employees must not use The Company’s assets or information for personal benefit or that of family, friends, or acquaintances. Privileged information refers to non-public acts, facts, or events related to The Company or its business network that could result inpersonal gain if improperly used.
All employees are responsible for handling information appropriately and complying with The Company’s information security and cybersecurity policies.
For more information, refer to our Information Security Policy.
Personal Data Protection
We are committed to safeguarding the privacy, confidentiality, and security of the information entrusted to us by our customers, suppliers, and employees. The Company collects and uses personal information solely for lawful purposes and complies with applicable data processing laws.
Employees must limit third-party information access to the strict minimum necessary and prevent unauthorized individuals from accessing such data. Employees must comply with The Company’s established guidelines and procedures regarding data use and protection. For more information, refer to our Personal Data Protection Policy
6. SIMETRIK ETHICS HOTLINE
The Company upholds the highest standards of transparency, honesty, and accountability and has established reporting channels for employees to report any suspicious behavior, misconduct, or irregularities.
Employees must report any illegal, unethical behavior or any violations of this Code, anonymously through Simetrik’s Ethics Hotline, operated by Ethics Global:
Toll-free phone line:
Colombia: +57 1 800 518 9191
Argentina: 0800 345 5478
Brazil: 0800 900 0510
Mexico: 800 043 8422
Website: https://simetrik.lineadeconfianza.com/
Ethics Global Mobile App using the code V22-7259-SIM
All reports will remain confidential, and the anonymity of the whistleblower will be preserved. Failure to report a violation of the Code of Ethics is considered a violation of the Code itself.
For more information, consult our Ethics Hotline Policy.
7. CONSEQUENCES AND CORRECTIVE ACTIONS
Violations of this Ethics Code shall subject employees to disciplinary action in accordance with applicable laws, employment contracts, and Internal Work Regulations. Legal and disciplinary measures may range from a written warning to termination of employment. Such disciplinary actions do not preclude The Company from pursuing additional legal remedies, including but not
limited to civil claims for damages, injunctive relief, or referral to appropriate authorities for criminal prosecution where applicable.
In cases not explicitly covered in this document, employees must adhere to The Company’s internal policies and uphold the highest ethical standards. Compliance with this Code is an obligation for all, reflecting our unwavering commitment to The Company’s values and objectives.
8. UPDATES AND DISCLOSURE
This Code will be reviewed and updated as necessary to consider new legal or internal regulations. Any changes will be communicated to employees.
9. EFFECTIVE DATE
This Code shall come into effect upon publication and formal approval by the Board of Directors of Simetrik INC.