2. Scope

This Policy is applicable to all companies, directly or indirectly controlled by Change Group. Likewise, this Policy binds and applies to the members of the Board of Directors of the Company, to senior management and, in general, regardless of their position, responsibility, occupation or geographical location, to all employees of Change Group and those companies in which Change Group has control (the "Covered Persons"). With this Policy, Change Group consolidates its commitment to principle number 10 of the United Nations Global Compact, to which the Prosegur group adhered in 2002, which obliges its subscribers not only to avoid bribery, extortion and other forms of corruption, but also to develop specific policies and programs to promote transparency. Since senior management members have the greatest management and decision-making capabilities within their area of responsibility and therefore concentrate the greatest risk, they should be the focus of the greatest control and awareness efforts.

3. Implementation
 3.1 Applicable regulations 

Change Group complies with the applicable legislation in all countries in which the Company operates and, in particular, with the laws in each jurisdiction aimed at combating corruption. Likewise, Change Group complies with the internal regulations developed at the corporate level in all countries in which the Company has a presence, including, in particular, its Code of Ethics, which expressly states its total rejection of corruption. Change Group's activities in certain countries may require the application of specific internal anticorruption regulations and additional compliance programmes that, following from and in accordance with this Policy, ensure compliance with the legislation and the particular local circumstances.

3.2 Commitments, guidelines and behaviour guidelines. 

Subject Persons are required to comply with the following commitments, guidelines and behaviour guidelines: 

1. Corruption

• Maintain due diligence in the workplace and perform their professional duties with ethics, transparency and honesty.
• Pay special attention to cases in which there are signs of a lack of integrity of the persons or entities with which business is conducted.
• Respect the commitment not to carry out economic transactions, contracts, agreements when there are well-founded and sufficient reasons to believe that there may be some type of link with improper or corrupt activities by any of the counterparties involved.

2. Bribery

• Refrain from making offers, promises, authorisations or deliveries, direct or indirect, of any kind of monetary incentive, commission, gift or compensation to any employee, director or administrator of other companies or private entities, as well as to authorities, public officials, employees or directors of companies and public bodies, with the purpose that, in breach of their responsibilities and, where appropriate, current legislation, they act or fail to act to favour a certain business or obtain an undue business advantage. These deliveries, promises, authorisations or offers are prohibited whether they are made directly or indirectly through collaborators, partners, associates, agents, intermediaries or any other third party.
• Refrain from accepting, directly or indirectly, any type of gift whose purpose is that the Subject Person, in breach of their obligations, favours, directly or indirectly, the giving person or entity in contracts for goods or services.

3. Money laundering

• Donations, whether Change Group is a donor, a donee or a recipient, may not serve as a means of introducing money from an illicit activity into the financial system.
• Change Group is prohibited from carrying out any act aimed at giving the appearance of legality to resources (financial or material) originating from or related to the commission of crimes.

4. . Fraud

• Subject Persons have the commitment and the obligation not to incur in actions that could constitute some type of fraud against the Company.
• Subject Persons have the obligation to report any fact that could be a sign of the commission of a fraud.

5. Influence pedding

• Subject Persons shall not carry out any type of activity that may constitute influence peddling.

6. Extortion

• Subject Persons shall refrain from engaging in conduct that could constitute or be related to extortion in all its possible manifestations.

7. Use of false information

• Subject Persons shall not make use of false information before any type of authority (administrative or judicial) or before any third party in order to obtain any benefit or undue advantage.

8. Facilitating payments

• Subject Persons shall in no case make payments to facilitate or expedite procedures consisting of offering, promising, authorising or delivering, directly or indirectly, monetary incentives, commissions, remuneration or things of value to officials and public servants or to employees and directors of private entities in order to expedite judicial or administrative procedures, procedures or of any other nature.

9. Policy on Gifts and Hospitality

• The general principle of prohibition of receiving, promising, accepting and offering, within the framework of professional performance, objects, services, benefits or favours, in order to obtain a benefit or advantage for oneself or for Change Group, especially those that may compromise the independence and impartiality of clients, civil servants, public officials or any other person with whom we have professional relations, applies.
• In any case, Change Group is prohibited from giving gifts, hospitality, promotions, invitations or presents to customers, civil servants, public officials and, in general, to any person with whom it has professional relations, except for those which, being sporadic, are of little value, are reasonable and in accordance with the practices, uses and customs of each country and/or locality and respond to legitimate interests.

Exempted from the above general prohibition are "permitted courtesies" with all of the following characteristics:

- They are in accordance with applicable domestic laws and regulations at the time and in each country; 
- They are of reasonable, symbolic or economically irrelevant value and;
- They are not contrary to the values and principles of ethics and transparency

• Subject Persons may only receive gifts, presents, hospitality, promotions, invitations and gifts that:

- originate from or have as their origin or purpose a professional focus. 
- have an economic value that is within the amounts authorised by Change Group's internal regulations. - are proportionate, reasonable, sporadic and in accordance with the customs and practices of the place and environment in which they occur.

• At no time should gifts or presents given, offered or received be concealed or unduly influence the decision-making capacity, objectivity and impartiality of their senders and/or recipients, or bring undue benefits to them.
• Before any Subject Person offers or accepts a gift or present, they must request the corresponding authorisation from their superior, who will assess whether the offer or acceptance of the gift or present is compatible with the provisions of this Policy and, in the event of doubt, will refer the matter to the Compliance Officer.

10. Improper use of public resources

• When, for whatever reason, Change Group receives public resources, it must use them only for the purpose for which said public resources have been provided.
• Change Group is committed to maintaining clear, precise, consistent and transparent records to verify the use and destination of the public resources it receives.

11. Political contributions

Change Group will not make contributions or donations to candidates, parties or political campaigns. The granting by Change Group of any aid or contribution, monetary, direct, indirect or otherwise, to political parties, their representatives or candidates is prohibited.

3.3 Conflict of Interest 

Change Group understands and knows that conflicts of interest may become unavoidable when Subject Persons perform their activities. However, it considers that these can be controlled in order to mitigate their consequences. It is therefore of utmost importance that, if such conflicts may exist, they be declared and managed appropriately. 

Change Group shall keep a record of the declarations of conflicts of interest made by Subject Persons and of the supporting documentation for their correct management. 

Subject Persons:

• They undertake not to participate in any business or activity that, directly or indirectly, interferes with the interests of the Company.
• Undertake not to leverage their jobs or influence derived from their positions to obtain personal benefits or benefits for third parties.
• Shall not use the assets (facilities, work instruments, etc.) for business or personal activities.
• Shall refrain from influencing in any way the negotiations and decision-making processes with customers with whom they have a family relationship or any other direct or indirect interest.

In case of conflict of interest, Subject Persons:

• Must immediately declare any conflict of interest that may arise to their superior, the Compliance Area or, as the case may be, to Human Resources.
• When there is a conflict of interest related to the purchase of products or services from a third party with which Change Group has a commercial relationship, this must be reported to the head of the Purchasing area or the Compliance area.
• Must refrain from participating in any recruitment decision-making process of people with whom they have a close bond (family, friendship, work, etc.).
• They will refrain from requesting or receiving fees, commissions, services or other favors from any business partner, real or potential, or from competitors. If they have any doubts, queries or complaints, Subject Persons must immediately contact:
  
  - Their immediate hierarchical superior.
  - The Human Resources Department.
  - The Compliance Officer.
  - The Whistleblower Channel.

3.4 Due diligence in the relationship with third parties 

Subject Persons must choose the third parties (agents, consultants, partners, suppliers or representatives) with whom the Company enters or plans to enter into commercial relationships with due diligence, in accordance with the applicable regulations established in relation to the knowledge, identification and engaging of third parties.

3.5 Tenders

All public or private tenders in which Change Group participates must be carried out in compliance with their official terms and conditions and in accordance with the applicable laws and regulations. 

In bidding processes in which the Company participates, Subject Persons must comply with the following principles of action: 

• Subject Persons may not offer, directly or indirectly, any object of value to a public official to inappropriately influence any aspect related to the entire public procurement process in favour of Change Group. 
• Change Group will never accept, or request information related to the tender that is not of a public nature.
• Change Group will not conspire, participate in cartels, or inappropriately coordinate with other bidding participants.
• Subject Persons undertake not to enter into, in public procurement procedures, agreements, contracts, conventions, or any other type of similar collusive behaviour with one or more participants, the purpose or effect of which is to obtain an undue benefit in favour of Change Group.

3.6 Recruitment of former public officials 

Change Group may only hire former public officials - including foreigners - after the time periods established in the regulations applicable in each jurisdiction have elapsed from the date on which they left their positions. Any additional limitations under applicable legislation shall be observed and complied with.

3.7 Reporting of breaches, and sanction 

All Subject Persons have a duty to know, comply with and disseminate this Policy, as well as the obligation to report through the established channel any situations or actions of which they are aware and that violate or may violate the anti-corruption regulations. 

This reporting must be immediate and must occur through one of the channels established in the Code of Ethics. 

Change Group's Whistleblower Channel is available at all times on the website https://corp.changegroup.com. This is a channel that preserves the confidentiality required for each situation, the anonymity necessary to guarantee respect for the privacy of its users, and the absence of reprisals against anyone who reports improper conduct or participates in its investigation, unless they act in bad faith. 

Persons Covered who breach this Policy shall be subject to disciplinary measures determined by the Human Resources Department in accordance with employment contracts, applicable labor legislation and the Company's internal regulations; they may also be subject to prosecution, as appropriate, in the corresponding jurisdictions. 

Change Group shall promote the termination of any commercial relationship with customers, suppliers and other third parties who fail to comply with the provisions of this Policy and will assess the advisability of demanding the repair of the damage that, if any, it may suffer, acting in all cases with respect and in compliance with the terms of the contracts entered into.