Our company is it compromised to operate and to work under the applicable laws, rules and regulations. Our efforts are directed to perform considering the standards of ethics of businesses. The code of ethics fulfils the function to create and to remember the borders of our organizational culture, so that all the employees, directors, managers and workers, are the vehicles of the culture and organizational ethics; which will create an atmosphere of confidence and personal and organizational development.

It is obligation of all the employees, directors, managers and workers, to know and to promote the culture, ethical and honest conduct, based on the laws, rules and regulations. In addition to this the communication channels must be ascending and descendent so that the information flows easily and in that form quickly take care of the restlessness and preoccupations of all the employees related to the events that happen within the organization.

As result we must have an organization with compromised, collaborating, confident and integrated people.

Conformity with the Laws, Rules and Regulations

It is required to accept the laws, rules and regulations that lead to an integral conduct of business and the company; this includes avoiding completely any disloyal or illegal competition practices, which includes without limitation, money laundering, bribe, unsuitable payments. Any suspicion of unsuitable acts or
violations should be investigated, and in a further case, punished according to the applicable law by competent authorities.

Conflict of Interests

Within the company the real and personal interest must be obtained by means of the joint effort for the success of the company as a whole. The individual benefit of the directors, managers and employees in no case must be obtained in a hidden way by doing investments, accepting positions, to participate in some transaction or business that are not of the knowledge of everyone in a specified and disclosed way. Any act that is suspected to be of this nature must be informed by the employees to its superior ones and the directors must discuss it in the board (ordinary or extraordinary).

A conflict of interests happens when the personal interests of an employee, director or manager interferes with the company interests. This conflict can take place in different forms in the company and it is important that the employees communicate any conflict in which they find themselves before acting, in order to be able to consider the best way to act, considering the interests of the company and the ethical standards of businesses.

Confidential Information

The confidential information related to the operation of the company and information that can be of knowledge of the employees, must remain confidential and it is required that the employees do not disclose such information in any case, only in the case that the disclosure is requested by courts or by the competent and authorized authorities to make this type of investigations (within these authorities are the stock exchange regarding the information that they may require). Within the confidential information is the non-public information that can get to harm to the company and his interests, information that is of the interest and use of the competition or that can get to be harmful for the company, its clients, partners or suppliers.

Within this confidential information, information related to the price of the market and other information that can influence in the decision of investment of third parties and public investment is included. The confidential information can not be taken in advantage for self interests and benefits.

It is responsibility of the management level to make the official notices that are opportune and that are required by the law, rules or regulations, in a complete, right, transparent and opportunely way. This includes all documents and reports
that are due to do. The employees are also in the obligation to provide to the managers all the information necessary to be able to prepare official notices, also they are in the responsibility to inform and to report any event or information that affects these official notices or when it is the case, informing when these official notices contain untruthful or incorrect information.

Exactitude in the Accounting Records

The accounting records of the company are made basically to make the reports that maintain informed the governmental authorities, shareholders, creditors and organizations that require this information. It is obligation of all the employees to make sure that the information of the transactions and operations of the company is exact, excellent and it does not contain any false entrances. The accounting reports must be to conformity of the law and the Colombian authorities.

The company must be compromised to report the financial statements according to the reality so that the public information that is emitted is clear and consistent.

Assets of the Company

All the employees and directors of the company must give the best use to the assets that the company offers them, to maintain the effectiveness and the good culture of work and respect. Any damage or bad use of the assets has a direct impact in the productivity of the company. These assets must be only used with the legal intention of the business.

Corporative opportunities and Righteous Negotiation

The directors, managers and employees should not take for their own benefit the opportunities that may appear thanks to the use of the properties of the company, seek self benefit from the information to which they have access to, or from the position that they occupy, or from the people with which they are commercially related thanks to the company. The directors, managers and employees must alert the company when a corporative opportunity appears.

The representatives, directors and negotiators of the company must make businesses under the ethical and businessmen standards, act in good faith and with real interest to benefit the company and its objectives. They must know how to choose the commercial relations that are beneficial for the company and make sure that all the transactions in which they are part of, and that compromise the company, are legal. The reference and information that a representative of the company gives to third parties must be exact, not deceptive nor false. They are compromised as representatives not to execute any type of disloyal competition.

The ideal of the company is to develop in the most righteousness and honest way, and under these standards serve in the best way possible and be continuously improving and surpassing themselves.

Compliance of the Code of Ethics

It is obligation of any employee, director or manager, to ask for assistance to superiors or informed personnel at the moment that they have a doubt of any of the content of the code of ethics. To be misinformed is not excuse to violate the code of ethics. It is obligation of any employee, director or manager, to inform suspicions or information into concrete facts where any member of the organization has violated the code of ethics. The violations of the code will be discussed in the board of directors where the suitable disciplinary action will be taken based on the law, rules and regulations. Registries of the events occurred in relation to violations of the code of ethics will be recorded.

This code of ethics has the intention of regulating, standardizing and making public the principles and model of conduct in the company. As result we must obtain an excellent organizational culture, with an atmosphere of confidence and solidarity that allows us to grow as a company and that our employees grow as people, ethical and correct professionals.