Anti-Corruption and Anti-Bribery Commitment Policy

At the Organization, we have zero tolerance for corruption and for any unethical conduct; for this reason, we prioritize compliance with the highest ethical, anti-corruption, and anti-bribery standards as an essential part of our Compliance Culture, grounded in the principles of integrity, accountability, and sustainable management.

This Policy is developed through the Organization's Compliance Program, which is aligned with local and international regulations on the matter (the FCPA of the USA), the Code of Ethics and Transparency of the Cámara Farmacéutica de la ANDI in Colombia, and our Corporate Code of Ethics, and is coordinated with the Internal Control System, allowing for effective management of ethical, corruption, and bribery risks across the Organization's businesses and processes.
All employees and stakeholders of the Organization commit to:

Keeping ethics as a "non-negotiable" in everything we do, assuming an individual commitment to always do the right thing, complying with the rules, policies, procedures, and controls that affect our process, and being a multiplier of Compliance with those with whom we interact.

Keeping our decisions free from any undue influence, ensuring that the Group's decisions and actions, through its employees, are not influenced by gifts, courtesies, or personal benefits; for this reason, it is not permitted to offer or accept gifts and courtesies whose intent, value, or frequency could compromise our independence in decision-making.
Rejecting facilitation payments, understood as improper payments made to expedite procedures or processes before authorities or other entities.

Complying with internal rules and procedures in all our processes and businesses, and in no way facilitating non-compliance with regulations or the obtaining of illegitimate benefits for ourselves or third parties.

Promoting transparent, responsible relationships with our stakeholders, such that in our dealings with the various stakeholders, we respect their independence and manage evidence that supports compliance with processes and the transparency of the agreement or negotiation.

Complying with due diligence on third parties prior to engaging any type of third party, we ensure compliance with due diligence and negotiation policies and procedures, among others, guaranteeing compliance with mandatory regulations, leading practices, and voluntary certifications that strengthen our processes and build trust with our stakeholders.

Protecting our Intellectual Property is essential to giving value to these efforts. The proper management of patents, trademarks, trade secrets, and copyrights allows us to safeguard our intangible assets and ensure that they are registered, protected, and aligned with the highest ethical standards.

Not disclosing confidential or material non-public information and treating with absolute confidentiality all information to which we have access, which may only be used for the purpose for which it was shared.

Acting with special diligence in our relationships with government entities and public officials, ensuring that all interaction is transparent, legal, and legitimate. In all dealings with Public Sector Actors, we ensure that such interactions take place based on ethical and integrity criteria within the framework of the Organization's Compliance Program.

Complying with internal procedures for the granting of donations, sponsorships, and contributions, such that, in advance, we comply with the internal procedures that manage legal and reputational risks, and we ensure, among other things, that these do not become an incentive for the recommendation, prescription, purchase, supply, sale, or administration of the products manufactured and/or marketed by the Organization.

Respecting and complying with electoral processes; in political exercises, we support democracy and transparency in electoral processes. However, the Group's Companies do not support political activities, political parties, or movements, nor do they make direct or indirect contributions to political campaigns or parties aimed at obtaining improper advantages and/or exerting influence that favors the prescription or purchase of medicines.

Identifying, declaring, and managing any conflict of interest in a timely manner, recognizing that well-managed conflicts of interest strengthen transparency, while hidden ones destroy it; accordingly, in all cases, we report in a timely manner any actual or potential conflicts of interest, whether our own or those of other employees, suppliers, contractors, customers, or interested parties.

Recording and reporting all financial and commercial transactions truthfully, completely, and in a timely manner, avoiding falsification, concealment, or manipulation of information, thereby ensuring that all our transactions and accounting records faithfully reflect the nature of the operation and comply with the Organization's accounting standards, controls, and procedures.

Actively contributing to the Company's culture of compliance and integrity, participating in training sessions, promoting good practices, and acting as an example to colleagues and third parties.

Responsibly reporting any non-compliance or unusual situation, whether our own or that of third parties, through the Ethics Line www.resguarda.com/sofgenpharma, a channel available 24 hours a day, 7 days a week, to make any inquiry or complaint related to ethical matters, it also being a violation to refrain from reporting them.