SUPPLIER CODE OF CONDUCT

Purpose: This Supplier Code of Conduct (“Supplier Code”) establishes the principles and considerations for entities or individuals that provide goods or services (“Supplier”) to La Tercera Mirada or on its behalf. In this document, the term Supplier also includes independent contractors and subcontractors that provide goods or services to La Tercera Mirada or on its behalf.

La Tercera Mirada does not approve of illegal or unethical behavior by its Suppliers, contractors, or partners; it selects its Suppliers through a fair procurement process. This Code of Conduct details the minimum required standards and complements the terms and conditions of purchase agreements between Suppliers and La Tercera Mirada. This Code of Conduct does not exempt the Supplier from its financial responsibility, from exercising good practices, or from seeking guidance related to business conduct.

Professional requirements: La Tercera Mirada has been required to comply with different laws, regulations, and professional standards in order to maintain independence with respect to clients, which may also affect Suppliers. Where applicable, La Tercera Mirada will guide Suppliers regarding these requirements. In addition, La Tercera Mirada will conduct due diligence questionnaires for Suppliers to assess their relationship with La Tercera Mirada. If necessary, the Supplier must provide information to La Tercera Mirada to support this process.

Principles governing the Supplier Code

Ethics and Integrity: Suppliers must not participate in any illegal or unethical process, and are expected to maintain fair business practices. In addition, they must commit to providing tools that allow their employees and contractors to report incidents related to unethical behavior.

Corruption: Suppliers must not offer or accept bribes, nor influence a third party to offer or receive bribes on their behalf. It is prohibited to offer, give, request, or receive any type of bribe or kickback; to offer or provide anything of value to a third party for an improper purpose or to gain an unfair advantage; and to offer facilitation payments. Likewise, Suppliers must make reasonable efforts to prevent bribery offenses in all their forms and support efforts to combat corruption.

Gifts and entertainment: Suppliers must not offer, accept, or request gifts, entertainment, or hospitality that could be considered a disguise for a bribe, or if they could be perceived as improperly influencing decisions or impairing business objectivity.

Money laundering and sanctions: Suppliers must not engage in activities, conduct business, or enter into agreements that could involve La Tercera Mirada, directly or indirectly, in money laundering or terrorist financing activities. Suppliers must comply with applicable laws, rules, and trade control regulations related to the import, export, and transfer of goods and services.

Use of privileged information: Suppliers must not carry out operations, transactions, or speculation using non-public and confidential privileged information obtained through their relationship with La Tercera Mirada.

Conflicts of interest: Suppliers must not allow biases, conflicts of interest, or inappropriate third-party influences to override their professional judgment and responsibilities. They must also not enter into transactions that may create a conflict of interest regarding the supply of goods and/or services. Suppliers shall immediately inform La Tercera Mirada of any potential conflict of interest related to business with La Tercera Mirada.

IT security, privacy, and confidentiality: Suppliers must, at all times, take the necessary measures to properly protect, collect, and manage confidential and personal information, including physical and electronic assets obtained from La Tercera Mirada or from La Tercera Mirada’s clients. This information shall be used strictly for the purpose for which it was provided. Suppliers shall immediately inform La Tercera Mirada of any incident involving unauthorized access, disclosure, or potential loss of such information, including, but not limited to, theft, damage, destruction, attempted cyberattack, ransomware, etc.

Human and labor rights: Suppliers must maintain a workplace characterized by professionalism and respect for the dignity of each collaborator/worker and every person with whom their collaborators/workers interact. They must treat all workers with dignity and respect and must not subject them to degrading conditions. They must not tolerate discrimination. They must foster a culture and workplace where equal opportunities are promoted for all, and must not tolerate harassment, threats, or retaliation for reporting harassment.

Suppliers must not participate in or support human trafficking or slavery, and must not use forced or involuntary labor, nor require work or services from any person under threat or coercion.

Suppliers must not benefit from child labor, nor hire underage workers.

Suppliers must respect workers’ right to freedom of association and may not prevent workers from legally organizing and joining associations.

Suppliers must conduct an assessment or background check of their workers to ensure their integrity and good reputation. Candidates and workers are expected to be evaluated based on their ability to perform the work.

Suppliers must comply with all applicable standards regarding the working conditions of their collaborators, including, but not limited to, laws, regulations, and standards related to the payment of the legal minimum wage or a wage that complies with local industry standards.

Supplier diversity: Whenever possible, Suppliers shall promote diversity within companies by including women, Indigenous businesses, minorities, and LGBT businesses in their operating chains.

Health and safety: In addition to complying with minimum legal and regulatory requirements for working conditions, Suppliers must provide a safe and healthy work environment and comply with applicable health and safety laws.

Environment: Suppliers are encouraged to improve energy efficiency and reduce the consumption of natural resources, including energy — electricity and heating — water, and fuel. Suppliers are encouraged to use innovations and ecological practices that reduce negative environmental impact. Suppliers must take reasonable measures to comply with environmental laws in order to minimize greenhouse gas emissions and hazardous pollutants, where applicable. Suppliers are expected to make efforts to eliminate or reduce the levels of waste generated, both solid and liquid waste.

Responsible business practices: Suppliers must not subcontract services or activities they perform that may directly affect the delivery of goods and services to La Tercera Mirada or its clients without prior written approval from La Tercera Mirada. When Suppliers subcontract certain activities related to the services provided to La Tercera Mirada, Suppliers must supervise the subcontracted party to ensure compliance with the Suppliers’ contractual obligations and this Supplier Code.

Social media: Suppliers must not act or speak on behalf of La Tercera Mirada, present themselves as La Tercera Mirada, or express any point of view attributable to La Tercera Mirada, unless expressly authorized by La Tercera Mirada.

Legal: When there is a conflict between the terms of the Supplier Code and the Supplier’s contract with La Tercera Mirada, the contract with La Tercera Mirada shall prevail to the extent legally permitted.

Violations of the Supplier Code: Violations are taken seriously and must be reported as soon as the Supplier becomes aware of them. In the event of any violation of this Supplier Code, recommendations may be made, corrective action plans may be required, the decision may be made not to prioritize working with the Supplier, or the contract may even be terminated. Violations may be reported directly to the procurement representative, or to any other La Tercera Mirada collaborator with whom the Supplier feels comfortable discussing the matter.

Supplier Code of Conduct Version 1.0 – Effective as of July 9, 2020. La Tercera Mirada S.A.S.