UVM COMPLIANCE POLICY AGAINST THE CORRUPTION AND TRANSNATIONAL BRIBERY

USA VIRTUAL MARKET SAS COMPLIANCE POLICY AGAINST THE CORRUPTION AND TRANSNATIONAL BRIBERY

By virtue of this document USA VIRTUAL MARKET S.A.S. assumes the clear and decisive commitment of its administrators, employees and associates to manage, prevent and miKgate the Risk of CorrupKon and TransnaKonal Bribery.

This policy is adopted to carry out its business and operaKons in a manner ethical, transparent and honest; and be able to idenKfy, detect, prevent and miKgate the Risks of CorrupKon or Risks of TransnaKonal Bribery.

USA VIRTUAL MARKET S.A.S. undertakes to design, structure, implement, execute and verify acKons aimed at the effecKve prevenKon and miKgaKon of any corrupt pracKce, in accordance with the following:

  1. a)  Evaluate the risks of corrupKon and transnaKonal bribery, with a matrix of risk, which idenKfies and evaluates its own risk factors such as, for example, the economic sector, third parKes, contractors, intermediaries, advisors, consultants and type of contract.
  2. b)  Establish adequate and sufficient Due Diligence procedures linking suppliers, administrators, employees and associates, to detect the warning signs idenKfied regarding CorrupKon and Bribery TransnaKonal. Based on this, USA VIRTUAL MARKET S.A.S. may decide not to hire or not to conKnue with a contractual relaKonship whenever such warning signals are set.
  3. c)  USA VIRTUAL MARKET S.A.S. appoints a chief compliance officer responsible for verifying the implementaKon of acKons aimed at prevenKon and effecKve miKgaKon of any corrupt pracKces.
  4. d)  USA VIRTUAL MARKET S.A.S. has communicaKon channels that They guarantee confidenKality such as [email protected] or through the link hXps://gsp.com.co/linea-eKca/
  5. e)  USA VIRTUAL MARKET S.A.S. encourages the making of complaints and, Likewise, it adopts measures to avoid retaliaKon against employees or third parKes who carry them out.
  6. f)  USA VIRTUAL MARKET S.A.S. will annually disseminate this policy and will carry out training for its employees, associates, administrators, contractors and other interested parKes, on prevenKon, self-control and management of the Risk of corrupKon and transnaKonal bribery.
  7. g)  USA VIRTUAL MARKET S.A.S. will order acKons against the Administrators and Associates who have management and administraKon funcKons in the event of non-compliance of the Transparency and Business Ethics Program.