ARTICLE 1. INTRODUCTION

The fundamental values in carrying out work at active I.T primarily include honesty, loyalty, camaraderie, service, commitment, and teamwork.

Implicit in these values are, of course, respect and responsibility. This Code establishes general principles intended to guide the activities developed by active I.T SPA, hereafter referred to as active I.T, the Company, the Business, or the Organization, as well as by each of the individuals who work within them.

It serves as a guiding and facilitating instrument in our actions, providing a reference framework linked to both the Values promoted by the Company and its Vision and Mission.

As stated in this Code, it will be applicable to directors, employees, contractors, and relevant suppliers of active I.T. Due to the nature of the service they provide or the amounts involved in delivering their services, a clause will be included in their respective contracts, making this document applicable to them as well, and leaving it available for everyone on the Confluence platform.

All of the above, taken together, will be considered Collaborators for the purposes of this Code, which brings together a set of standards that must be applied at work, giving a distinctive mark and style to the manner of relationships and conducting business for the Company.

Business dealings and relationships with third parties will always be conducted based on compliance with laws and ethical standards. This Code will be used for guidance and applied in every circumstance, providing the best foundation for building an organization that is increasingly respectful of the rights of each worker, who, aware of their duties, will be effective and bring harmony and satisfaction to the Organization.

active I.T's vision is: "To be a company recognized for its customized solutions, market consolidation, continuous evolution, and leadership in the development of strategies and technological solutions for the improvement of business capabilities," with the mission "To provide our clients with comprehensive IT Consulting services, tailored to the client's needs with comprehensive and effective quality, and incorporating new technological tools."

The values of a company are the most important pillars of any organization. They truly define it, because the values of an organization are the values of its members, and especially those of its directors. The values that active I.T possesses are:

• Customer Focus: Being responsive to the diverse needs of our clients, understanding them and providing tailored solutions, while remaining flexible and adaptable in various environments.
• Ethics and Honesty: Integrity as the fundamental basis for all decisions, being transparent and honest in our daily actions.
• Teamwork: Collaboration, trust, and communication among internal and external team members, working together as a single, coordinated, and effective unit.
• Mutual Respect
• Mentoring: A company that supports the professional development of its employees.

ARTICLE 2. GENERAL STANDARDS OF CONDUCT AND RESPONSIBILITY

Every member of the Company is individually responsible for their actions. Employees shall comply with legislation, regulations issued by legitimate and competent regulatory authorities, procedure manuals, the Crime Prevention Model for Bribery, Money Laundering and Terrorist Financing, rules, instructions, written standards, verbal instructions given by their supervisor (when applicable), and other internal provisions of the Company (hereinafter the "Policies"), which must be known by all members.

The letter and spirit of the legislation, regulations, and rules will be applied in good faith. When an Employee faces a situation that is not clearly regulated or described, they shall consult with their supervisor.

In all circumstances, proper conduct, responsibility, and adherence to the Company's morals, customs, and culture will be applied. It will never be acceptable to act incorrectly, arguing that it constitutes a common practice among other members of the Company or its competitors, or that this is how the goals and objectives determined by the Company will be achieved.

In any commercial or other operation involving risks, these will be assumed first by the person performing it, and always taken within the framework indicated by their powers. This responsibility is not avoided by the fact that it is carried out with people linked to the Company, or by recommendation of one of them.

Actions will always be taken respecting risk prevention standards, without endangering the physical integrity of Employees, nor that of clients or the Company's assets and facilities.

In every operation, whether it involves contracts, acquisitions, services, relationships with suppliers, public affairs, or others that involve the use of the Company's resources, actions will be taken with honesty, truthfulness, transparency, and efficiency, always favoring the benefit of the Company above any other preference.

The Company should not conduct business or maintain commercial relationships with individuals or companies that deviate from ethical standards or participate in illicit business. In case of doubt, this should be consulted with the Manager of your area.

For all intents and purposes, active I.T.'s Internal Regulations for Order, Hygiene, and Safety and the Code of Ethics are complementary.

ARTICLE 3. HANDLING AND USE OF INFORMATION

Confidential information is that which is given to a Colleague by reason of the trust placed in them in their capacity as such, and which, therefore, should not be disclosed to other persons or exposed to use by third parties.

Anyone who has access to confidential information in the performance of their duties, especially information relating to clients, suppliers, shareholders, or other workers, such as salaries, bonuses or benefits, as well as their personal information, or on commercial decisions, must maintain absolute discretion in its use.

It may only be disclosed to other persons who, by reason of their institutional functions, need to know it. Any doubt about this matter will be a reason for consultation with the Manager of the respective area. In particular, strategic information, reserved information, and relevant or essential information constitute confidential information, according to what is defined in the document SG-SP-IN Classification of Company Information and in the Manual for Handling Information of Interest to the Market, privileged information.

3.1 Strategic Information

The Company requires strict confidentiality regarding strategic information, that is, information that provides it with competitive advantages, or information that is not yet appropriate to disclose to the market. Such information is confidential, and no Employee is permitted to disclose it to third parties under any circumstances.

The same rule applies to products, services, procedures, and any other matter that an Employee becomes aware of as a result of or in connection with their work or relationship with the Company, the knowledge of which by third parties outside the Company could harm its competitiveness or diminish its assets.

Employees will promptly inform their area Manager of any situation that may harm the trust, reputation, or credibility of the Company. Special care will be taken with discretion regarding information contained in physical and electronic files, and in documents under their responsibility due to the performance of each function, and they will be carefully concerned about their proper custody.

Misuse of information is not only unethical but also creates legal liabilities for the Organization and for those who engage in it, and may even constitute a crime.

3.2 Privileged Information

Privileged information is that which refers to the Company, its businesses, subsidiaries or related companies, or the securities issued by it, not disclosed to the market, and the knowledge of which may influence the quotation of the issued securities.

Information regarding acquisition or disposal operations to be carried out by active I.T. in the stock market, real estate market, or any other market, before they are disclosed to the market, is also considered privileged information.

Strict confidentiality must be maintained regarding privileged information that becomes known by virtue of the position held within the Company. It is forbidden to obtain advantages, profits, or avoid personal losses through its use, whether directly or indirectly, or for one's own benefit or that of others.

Company Employees have the right to make private investments, but they may not take advantage of privileged information in doing so. Additionally, Employees who are aware of privileged information that will be made available to the market through the publication of quarterly financial information must respect the Blackout Periods for carrying out transactions or operations involving securities affected by such information, in accordance with the provisions of General Rule No. 30 and Circular No. 1,501 of the Superintendency of Securities and Insurance.

It is also unlawful to use such information as the basis for investment advice to other people.

Should any member of active I.T. become aware of a violation of the handling of privileged information, they must promptly report it to the Manager of the respective area.

ARTICLE 4. RELATIONSHIP WITH SUPPLIERS, CONTRACTORS, CLIENTS, AND/OR THIRD PARTIES LINKED TO THE COMPANY

Relationships with suppliers, contractors, clients, and/or third parties linked to the Company will be governed by the policies, manuals, and procedures of active I.T SPA, consistent with the provisions of this Code, and ensuring a service of the highest quality.

In order to guarantee transparency, integrity, and professionalism in all matters, if any Employee has personal, familial, or friendship relationships with suppliers, contractors, clients, and/or third parties linked to the Company, they must refrain from making any decisions and must inform the Manager of the respective area, who will take measures to ensure the independence and neutrality of these decisions.

Discounts to suppliers, contractors, clients, and/or third parties linked to the Company may not be granted, nor may the terms of trade be changed, without the relevant authorization, duly adhering to the Company's policy. Commissions, gratuities, other royalties, or favors from them may also not be accepted.

We will always ensure the independence of judgment in the Company's business decisions. active I.T Employees are prohibited from offering or giving gifts to third parties linked to the Company, as well as from accepting or directly receiving them from the same, when such gifts could reasonably be perceived as incentives, when such actions represent a violation of active I.T's laws, regulations, or policies, or when they could embarrass or affect the good image and reputation of the Company.

However, gifts may be accepted or given in accordance with the common practices of the Collaborator's position. In any case, only the Company's Managers and Assistant Managers are authorized to make an invitation or give a corporate gift. Offering, giving, or receiving gifts from public officials is prohibited.

In the event of situations outside of those just mentioned, the Collaborator is obligated to explain this code of conduct to the donor and decline the gift. If returning the gift is not possible, the item received will be given to the Company's Finance and Administration Manager, who will determine the disposition of these goods. A written report, along with the item, will be provided, detailing all relevant facts associated with the offer and its acceptance, the donor's identity, and the approximate value of what was received. Under no circumstances may gifts of money, regardless of value, be accepted.

No Collaborator may insinuate, solicit, or request gifts or personal benefits as a condition for establishing business relationships with the Company.

In relationships with suppliers, contractors, clients, and/or third parties linked to the Company, employees must keep in mind that the awarding of contracts and commitments to suppliers of goods and services will be with complete impartiality, without favoritism of any kind, and will always prioritize the commercial and financial interests of active I.T.

Links will be established with suppliers and contractors that are trusted by the Company, demonstrating fairness, balance, and a long-term perspective, and who are willing to adhere to its quality standards and act with the same level of integrity as the Company. All supplier or contractor offers will be periodically evaluated and compared in order to continuously obtain better conditions, higher quality, and improved service.

active I.T. employees will refrain from participating in meetings, receptions, or other situations with suppliers, contractors, clients, and/or third parties linked to the Company if such invitations, due to their excessive, disproportionate, or inappropriate nature, could compromise their independence of judgment and their duty to decide freely, exclusively considering the Company's interests. If there is any doubt about the above, the Area Manager should be consulted.

All invitations of any nature made by suppliers, contractors, clients, and/or third parties linked to the Company must be reported to the respective Area Manager, in order to avoid any possible pressure that compromises the judgment of the active I.T. employee. Commercial decisions will be based on the merit of the offers received, the technical and commercial background of the suppliers, and in no case may they be influenced by favors, gifts, invitations, loans, or services of any nature made by any person or organization that does business with the Company or is a competitor of it.

In the selection of suppliers and contractors, as well as in the consolidation of commercial relationships with them, strict compliance with the law will be ensured, and special attention will be paid to detecting any situation that could constitute a crime. Suppliers, contractors, and third parties linked to the Company must commit not only to keeping their activity away from the commission of crimes, but also to designing and implementing a crime prevention model in the terms established in Law 20.393, or at least to establish the control and supervision mechanisms necessary to avoid the commission of the crimes indicated in said regulation.

ARTICLE 5. INSTITUTIONAL RELATIONS

Relations with state or international institutions will be based on open, objective, and transparent forms of communication aimed at evaluating the implications of legislative and administrative activity for active I.T., responding to requirements and acts of inspection bodies (consultations, inquiries, etc.), or, in any case, making known its position on issues relevant to the Company.

In order to guarantee maximum transparency in relations, contacts with institutional interlocutors will be carried out exclusively through representatives who have been explicitly designated for that purpose within the Company.

It is the duty of the Collaborators to cooperate with all legitimate requests made by public authorities, provided they are made in a transparent manner and through regular channels of contact. Any request for information made by the aforementioned authorities, other than those routinely made during regular examinations and reports, must first be channeled to the Manager of the respective area.

ARTICLE 6. RELATIONS BETWEEN COMPANY MEMBERS

Every employee of the Company must act in good faith in order to respect the obligations undertaken in the employment contract, or those arising from the Internal Regulations and Order, Hygiene and Safety of active I.T, this Code of Ethics, as well as the Policies implemented in the Company, and must inform the Manager of their area of any violation of the rules of conduct established by them.

Collaborators of active I.T are expected to commit to behaving without endangering or affecting the health, safety, dignity, integrity, honor, or reputation of the individuals within this Organization, and to interact harmoniously with their environment.

Furthermore, it is the responsibility of all Employees to apply this Code and encourage adherence to it among those with whom they interact.

Sincerity should permeate relationships between individuals and departments within the Company, and with external entities and individuals. Exerting undue pressure on colleagues, whether practiced individually or as a group, will be considered a breach of ethical standards. Those who fail to respect confidentiality, spread rumors, or use veiled criticism and personal disparagement of others will also be in violation.

Unethical conduct will never be justified, nor can receiving instructions from a superior be used as an excuse for engaging in it. If faced with such an order, Employees have the obligation to report it to their Area Manager or the Crime Prevention Officer, who will inform the Administration and Finance Manager, who will ensure that measures are taken to prevent any possible retaliation.

Conducts that are particularly prohibited for violating human dignity include abuse of authority, sexual harassment, psychological harassment, derogatory or humiliating treatment, discrimination based on disabilities, nationality, race, or personal situation, as well as any action that undermines the honor or respect of others.

ARTICLE 7°. EXERCISE OF AUTHORITY

Within the Company's organization, there is a hierarchy of positions, which grants greater authority and responsibility to individuals holding higher positions. Their performance simultaneously entails the corresponding obligation to exercise such authority responsibly and ethically.

Any deviation in these matters undermines its legitimacy, making any abuse of authority as well as negligent performance reprehensible.

The exercise of authority has significant repercussions on the work environment, the quality of service provided to clients, the cooperation required among colleagues, and relationships with other entities of interest to the Organization.

A priority concern should be to exercise authority always in service of these key processes, fostering open and trusting relationships between superiors and subordinates, thus preventing and resolving frictions, conflicts, and dissatisfaction while keeping in mind the best customer service.

The powers assigned to each position are aimed at improving operational efficiency and better business management. They must, therefore, comply with the regulations that govern them and not exceed their respective scope of authority.

These include signing powers, money management, use of passwords, key handling, etc. Consequently, no one may sign documents, represent the Company, exercise authority, or exceed their powers unless expressly authorized to do so. Instructions issued by someone vested with authority will be based on good judgment, prudence, and honesty. They will always respect existing regulations and cannot contradict them.

ARTICLE 8°. MANAGEMENT OF ASSETS AND MONEY

8.1 Assets

In active I.T, ownership of assets includes all resources, information, products, and services. They must not be misused or removed from the Company's premises without explicit authorization. This also applies to the Company's intellectual property, such as client lists, files, reports, information processing systems, software programs, databases, trade secrets, and more.

active I.T owns its products and services, as well as any contributions made by its employees towards their development and implementation. This condition remains unchanged even when an employee leaves the company. Company letterheads, stamps, and all official representations must be used solely for official and work-related matters.

This prevents their use in personal communications, which should not be signed as a Company member to create the impression of official correspondence when they are not. Merchandise, supplies, equipment, machinery, and materials belonging to the Company must be maintained and used only for their intended work-related purposes.

Samples provided by suppliers that are no longer needed by the receiving departments must be delivered to the Administration and Finance Manager. Under no circumstances may these samples be considered or used as personal property by employees.

Maximum care should be taken with the Company's information systems, preventing any damage to the integrity of its programs and data. Proper protection should prevent any use for personal purposes, misuse, or manipulation attempts.

The Company's computing equipment must not contain programs or other personal-use elements that could expose it to virus contamination, other malfunctions, or allegations of unauthorized application use or lack of the necessary licenses.

It is strictly prohibited, and special care must be taken to ensure that the Company’s assets, those of its clients, or related entities are not used for any illegal activities, particularly those outlined in Law 20.393 regarding the criminal liability of legal entities.

8.2 Money Management

In the Company, extreme care must be taken in handling its funds, as well as those of clients and other related entities. Any situation that could cast doubt on personal integrity must be avoided. Established procedures must be strictly followed, and all transactions must be documented and backed up.

Any purpose other than that defined by the Company for its money, as well as that of related entities, will be considered objectionable. No justification will be accepted, and it will constitute a serious breach of obligations as Collaborators.

It is expressly prohibited, and special care must be taken to prevent Company funds, as well as those of its clients or related entities, from being used for any illegal activity, with particular emphasis on those specified in Law 20.393 regarding the criminal liability of legal entities.

Anyone authorized to incur operational expenses must provide an exact and timely account of them, adhering to the policies and procedures established for this purpose. All reported expenses must be properly documented and supported by the relevant records.

The books, records, and accounts reflecting the Company's operations or transactions must be kept complete and accurate. Any omission or malicious alteration of these will be subject to severe sanctions, as will any intentional action aimed at distorting its accounting, asset management, control systems, archives, or records in general.

This includes, but is not limited to, personal expense reports, background information for applying for benefits, and records of clients and other entities related to the Company.

ARTICLE 9. COMMUNICATIONS WITH THE OUTSIDE

active I.T.'s communication in carrying out its activities (including through the media) will be characterized by respect for the right to information. Under no circumstances is the dissemination of false or misleading news or comments allowed.

All communication activities must comply with laws, regulations, and professional and ethical conduct standards. They will be conducted with clarity, transparency, and timeliness while safeguarding, among other things, price-sensitive information and trade secrets.

To ensure the integrity and consistency of information, active I.T.'s relationships with the media will be handled exclusively by the General Manager or a designated representative.

ARTICLE 10. RESPECT FOR FREE COMPETITION

The Company promotes and respects free competition. It considers this a fundamental value that governs all areas of its operations. It will always act in full compliance with all applicable laws regarding competition defense, anti-monopoly regulations, and fair trade practices.

ARTICLE 10°. COMPETITION

Competition drives efficiency and creativity, allowing for fair and equitable relationships with our clients, suppliers, and competitors. Competitive actions must be guided by the Company’s business objectives and market considerations.

No agreements with our competitors or suppliers that restrict free competition are permitted. All employees, especially those involved in marketing, sales, and purchasing activities, or those who frequently interact with competitors, must be familiar with applicable competition laws. In case of any doubt, Company personnel should consult their deputy manager or the legal department, particularly when preparing and signing agreements and contracts or taking actions that might infringe competition and trade laws or regulations.

Although contacts with competitors are inevitable and can be entirely legitimate, especially within industry organizations, it is crucial to consult the relevant management in case of any doubts about the nature of such contacts. In any case, the safest way to prevent such situations is to avoid meetings or communications that could violate competition and trade laws or regulations.

ARTICLE 11°. RELATIONSHIP WITH THE ENVIRONMENT

active I.T and each of its Employees are permanently, actively, and responsibly committed to protecting and conserving the environment.

active I.T’s policies include compliance with legal requirements, especially current environmental regulations, and the application of responsible standards in cases where no laws or regulations exist. Therefore, each Employee of active I.T must carry out their activities while minimizing their environmental impact and fully complying with applicable legislation.

ARTICLE 12°. CONFLICTS OF INTEREST

A conflict of interest arises whenever a Collaborator's personal, direct, or indirect interest affects their independent judgment in a decision or action involving the Company’s interests. These situations are resolved through adherence to high ethical standards, which is the best guarantee of maintaining an image of integrity and honesty, thereby safeguarding the Company’s interests.

As a general policy, any situation in which personal interests of Collaborators conflict or appear to conflict with the Company’s interests should be avoided. In such cases, Collaborators must always prioritize the Company’s interests. The most evident application of this principle is dedicating work hours exclusively to Company matters and not to personal affairs.

No Collaborator may act on behalf of the Company in transactions involving individuals or organizations with whom they, their blood or in-law relatives, or close friends have a connection or economic interest. For the purposes of this Code, a relative is defined as anyone related by blood, affinity, or adoption in either a direct or collateral line. Friendship is considered a relationship of affection and trust but does not fall under the legal definition of kinship. Any doubts regarding these matters should be consulted with the Area Manager, who will resolve and inform the Administration and Finance Manager of the actions taken.

Collaborators must inform their Area Manager, who will then notify the Administration and Finance Manager about any legal entities or business ventures they establish with other individuals for investment and business development purposes. This ensures compliance with laws and regulations issued by the authorities when applicable.

If an external entity, due to a Collaborator’s position in the Company, requests them to participate as a speaker, panelist, professor, or consultant for a fee, they must inform their Area Manager. The manager will decide on the appropriateness of the participation and its terms. This process also applies to university and higher education teaching activities.

Decisions related to personnel and their matters, as well as business conduct, must be based on solid ethical principles and sound management practices, avoiding employment and leadership decisions based solely on family, personal, or friendship ties. In such situations, Collaborators must prioritize impartiality and inform their Area Manager of any connections they may have with the other party. If necessary, they should allow the manager to make the final decision.

ARTICLE 13°. PERSONAL CONDUCT

The Company calls for adherence to the principles and values explicitly stated in this Code, recognizing that they also extend to the private lives of Collaborators. The relationship between a Collaborator and the Company does not end with the workday but continues into their social life as citizens, making an absolute separation between both spheres impossible.

Given this inevitable overlap, the Company requires its Collaborators to observe these ethical principles in their family and private affairs when applicable.

A constant commitment from Collaborators to the most fundamental human values is expected, ensuring the well-being of the Company, all its members, and its reputation.

While the Company recognizes the broad freedom of its members in ideological, political, religious, and philosophical matters, it demands respect for fundamental principles, such as the dignity of all Collaborators and conducting themselves honestly and prudently in all aspects.

The adherence of each Company Collaborator to the ethical guidelines outlined here, and the consistency between these principles and their private and social conduct, will be the best guarantee for the optimal operation of the Company and the best reinforcement of its reputation in the community.

ARTICLE 14°. ALCOHOL AND DRUGS

The safety of its clients and employees is one of active I.T's main responsibilities and, therefore, a constant concern and dedication. Since the use of illicit drugs and alcohol abuse deteriorates this level of safety and, at the same time, generates undesirable personal consequences, the Company aspires to maintain a work environment free from the effects of such dependencies.

The Company rejects alcohol abuse and the use of illicit drugs by its employees. The possession, distribution, sale, and consumption of illicit drugs, as well as the possession, distribution, and consumption of alcohol, in any form or modality, are expressly prohibited on its premises. The consumption of alcohol on Company premises may only be authorized by the General Manager under special circumstances. Additionally, the distribution and sale of legal drugs on its premises and in locations where employees perform their duties are prohibited.

No one in the Company may report to work or perform their duties under the influence of alcohol, illicit drugs, or other substances that impair their ability and normal work performance.

It is the responsibility of everyone to help prevent and, if necessary, eradicate these habits. In cases of excessive consumption and/or dependencies, the Company will maintain a policy for their management and will proceed in accordance with internal regulations established for such cases.

Regarding this particular matter, the Procedure for the Control of Drug Use and Alcohol Abuse contained in active I.T’s Internal Regulations must be observed.

ARTICLE 15°. CRIMES ASSOCIATED WITH LAW 20.393

15.1 Responsibility of the legal entity for crimes of Money Laundering, Terrorism Financing, and Bribery.

The Company requires all its employees to conduct themselves with integrity and honesty, as well as to demonstrate a strict and diligent commitment to compliance with the Crime Prevention Model for Bribery, Money Laundering, and Terrorism Financing, which has been designed and implemented by the Company.

Everyone must be committed to knowing and complying with this regulation, recognizing that maintaining conduct free from any legal or ethical infringement is part of active I.T’s corporate culture.

Legitimate requests from public authorities must be responded to in a courteous, honest, and efficient manner. However, under no circumstances should employees engage in behaviors that could be legally or ethically questionable, including offering, promising, giving, or agreeing to give valuable objects, benefits, or money to public officials in Chile or abroad. Such practices are unacceptable to the Company and will be considered a serious breach of duty.

In cases where such officials are required to charge fees for their intervention, the payment must strictly adhere to the corresponding amount and never include additional payments beyond that.

If there is any doubt about whether a person is a public official, the employee should assume that they are.

Every effort must be made to prevent money laundering and terrorism financing crimes. Money laundering consists of concealing the illicit origin of money (which may come from criminal activities such as drug trafficking) to give it an appearance of legality. Terrorism financing refers to financial support or backing provided to any organization linked in any way to activities that could be classified as terrorist acts. In both cases, the techniques used are practically the same, and employees must be careful not to involve themselves or the Company in such behaviors.

active I.T and all its members must take on the task not only of preventing the commission of any crime by its employees, particularly those mentioned in the law, but also of maintaining the highest ethical standards of conduct in daily operations. Detecting money laundering and terrorism financing is not easy, as these activities are often carried out in ways that appear entirely legal. For this reason, employees must always remain vigilant, know their clients and suppliers, and be prepared to report any suspicious situations.

If a client handles large amounts of cash, seeks to bypass legal requirements, or if suppliers offer exceptional payment terms or exhibit unusual or unjustified behavior from a commercial standpoint, this must be reported immediately to the respective Area Manager and the Crime Prevention Officer.

Company employees must always ensure that the funds or assets they receive on behalf of the Company come from lawful and legitimate activities. Employees commit to exercising due diligence in reporting any suspicion they may have regarding the origin of such funds or assets to the Crime Prevention Officer, in accordance with active I.T’s Crime Prevention Model for Bribery, Money Laundering, and Terrorism Financing.

Likewise, Company employees must ensure that the Company's funds or assets that they manage, hold, invest, or safeguard are never used to finance illegal activities of any kind.

If any active I.T employee becomes aware of any of the aforementioned situations, they must report them as soon as possible to the Company’s Crime Prevention Officer, either directly or through the reporting channels established by the Company in accordance with its Crime Prevention Model for Bribery, Money Laundering, and Terrorism Financing.

15.2 From the Crime Prevention Officer of active I.T

The Crime Prevention Officer is the official specially designated by the Company for the design, implementation, and control of the Crime Prevention Model in accordance with Law 20.393. Their main responsibilities include: a) ensuring the effective implementation of the prevention program; b) ensuring the continuous adaptation and updating of the programs; and c) ensuring that employees are adequately trained and educated on legal obligations aimed at crime prevention.

The Crime Prevention Officer must report directly to the Company's General Manager and its Board of Directors and will have organizational and budgetary autonomy from the administration to carry out their tasks.

The Crime Prevention Officer will maintain a CONFIDENTIAL record containing all complaints received through the established channels, whether formal or informal, as well as all investigations arising from them, along with their respective background information and outcomes. They have a strict duty of confidentiality regarding all received information.

ARTICLE 16°. VIOLATIONS AND REPORTING

Any Employee who has knowledge of violations of this Code, illicit, illegal, or fraudulent conduct occurring or having occurred within the Company must immediately inform their Area Manager, the Crime Prevention Officer, or report it through the Company's Whistleblowing Channel. Those who report will be protected by the Organization, especially concerning maintaining confidentiality of identities when requested. Failure to report will be considered a violation of the principles and guidelines of this Code.

Reports made in bad faith, falsely, or irresponsibly are not acceptable and will be subject to sanctions in accordance with the Company's internal procedures and applicable legal regulations.

ARTICLE 17°. ETHICS COMMITTEE

An Ethics Committee, hereinafter referred to as the “Committee,” is established with the mission of ensuring compliance with this Code, interpreting its provisions, and clarifying their correct meaning and scope, as well as sanctioning behaviors that deviate from the guidelines set forth herein.

The Committee will be composed of the General Manager, the Human Resources Manager, the Administration and Finance Manager, and the Crime Prevention Officer.

Any Manager of active I.T may request the Committee's intervention if they are aware that one or more Employees in their area have violated this Code.

The Crime Prevention Officer may also request the Committee's intervention in cases they deem appropriate.

The Committee will request all relevant information regarding the situation and, if necessary, will hear from the involved parties. It will then decide and rule by majority vote on the measures to be taken and/or the sanctions to be applied if justified, in accordance with the Company's Internal Regulations on Order, Hygiene, and Safety.

ARTICLE 18°. APPROVAL OF THE CODE OF ETHICS

The Board of Directors, as the highest administrative body of the company, is responsible for approving this Code as well as any future modifications.

It is hereby recorded that the Board of Directors of active I.T SPA, in a session held on November 3, 2014, approved this Code of Ethics.