OBJECTIVE

FORSA S.A. is committed to adhering to the highest ethical standards and complying with all the local regulations and laws on anti-corruption and anti-bribery; consequently, its registered agents, as the Company’s Senior Management, have issued the following Policies for Compliance with the rules for the prevention of transnational bribery.

The purpose of these policies is to outline a path of compliance with the regulations to prevent risks related to transnational bribery for all partners, employees and/or contractors who carry out activities for or on behalf of FORSA S.A., thus aligning FORSA S.A. in its activities with all the applicable rules and regulations against transnational bribery and corruption. It is important to clarify that the Company has a zero tolerance policy against any conduct that can be considered bribery or can somehow be considered corrupt.

These Policies complement the Code of Ethics, Conduct and Sanctioning System adopted by the Company in May 2015.

2. SCOPE

These Policies apply to the Company’s Senior Management, Partners, Employees and/or Contractors (where contractors are understood as the suppliers that carry out any activity on behalf of the Company) sales representatives and/or customs agents, all of whom are included in the Scope thereof, who must state their knowledge and acceptance of their obligation to comply with rules related to preventing Transnational Bribery, as well as the Company’s Ethics Program and this document, which contains the Compliance Policies. Said written statement will be made as per the applicable documents to each individual, or through the commercial contract, contract of employment or document that governs their legal relationship with the Company. In addition, said individuals will make this statement in writing in accordance with form GE-FR-05 R1 CERTIFICATE OF INFORMATION AND COMMITMENT TO THE ANTI-CORRUPTION AND ANTI-BRIBERY COMPLIANCE POLICIES DOWNLOAD FORM

3. RELATIONSHIP WITH OTHER POLICIES AND CODES

This Policy is complemented by and supports the terms of the Code of Ethics, Conduct and Sanctioning System, which offers additional information on how to apply this Policy to prevent and detect bribery and corruption.

4. PRINCIPLES AND STATEMENT OF THE POLICIES

Expanding on the above, the following have been adopted:

1. a) The values and principles that provide the framework for the activities of FORSA S.A. according to the Code of Ethics, Conduct and Sanctioning System are:
   Respect, Responsibility, Service, Humility and Honesty.

Respect, Responsibility, Service, Humility and Honesty..

1. b) It is the duty of FORSA S.A., of its management and supervisory bodies, of its Compliance Officer, as well as the Company Representatives, to ensure compliance with these policies and to comply with the Anti-corruption and Anti-bribery Rules.
2. c) It is imperative to put the observance of the ethical principles before the achievement of the goals of FORSA S.A., considering that it is essential to generate a culture focused on applying and enforcing these Policies.
3. d) FORSA S.A. prohibits and sanctions any type of conduct related to bribery or corruption.
4. e) Any Company Employee, Senior Manager and/or Contractor that suspects or is aware of any conduct involving corruption or bribery must report said conduct to the Compliance Officer or report it through the Ethics Hotline. The Compliance Committee will respond to reports appropriately and suggest the actions to be taken according to the procedure set out in this Policy and the Code of Ethics, Conduct and Sanctioning System for cases of Conflicts of Interest.
5. f) If an Employee, Senior Manager and/or Contractor receives a request for bribery or suspicious payment from any person or entity, whether it is internal or external, this request must be immediately reported to the Compliance Officer or reported through the Ethics Hotline.
6. g) Any Company Employee, Senior Manager and/or Contractor who in good faith reports a violation of the Policy, or the engagement of any conduct involving corruption or bribery will be protected against any form of retaliation.
7. h) The rules laid down in this Policy regarding the mechanisms for the prevention of corruption or bribery are mandatory, so they must be followed in all actions.
8. i) FORSA S.A. will refrain from making or receiving donations that do not have a lawful purpose or those regarding which there is the suspicion that they will be used to cover up acts of corruption or bribery or to gain advantages in the business of FORSA S.A. Donations will only be made to non-profit entities.
9. j) FORSA S.A. will exercise due diligence to appropriately get to know potential suppliers or agents and, in particular, the relationship between suppliers or agents and government entities or government officials. To do so, the rules, objectives and principles regarding the relationship of supplies and agents indicated in the CPR-PR-01 Procurement procedure will apply.
10. k) FORSA S.A. will monitor any suspicious transaction or activity that may reasonably lead it to suspect that the suppliers or agents are using FORSA S.A. to transfer, handle, use or invest money or resources from criminal activities, as well as to carry out acts of corruption or bribery.
11. l) Company Employees, Senior Management and/or Contractors acting on behalf or as the representatives of FORSA S.A. are prohibited from performing acts aimed at hiding, changing, omitting or misrepresenting accounting records in order to conceal improper activities.

In compliance with all the above, the Senior Managers of FORSA S.A. are required to:

1. i) Implement the above Policies and the Company’s Ethics Program; and
2. ii) Take steps to disseminate the Company’s zero tolerance policy against Transnational Bribery.

Also, in order to control and monitor the Company’s Ethics Program and Policies, FORSA S.A. will carry out the following procedures:

1. i) Supervise the Compliance Officer and the External Auditor,
2. ii) Perform periodic Audits and Due Diligence,
3. iii) Administer polls on Employees and Contractors in order to verify the effectiveness of the Compliance Policies.

5. PROHIBITION OF ACTS OF CORRUPTION AND BRIBERY

 What is bribery?

Bribery is the act of giving, offering, promising, requesting or receiving anything of value in exchange for an improper benefit or advantage, or as consideration for performing or omitting an act inherent to a public or private function, regardless of whether the offer, promise or request is for oneself or for a third party, or on behalf of that person or a third party.

FORSA S.A. strictly prohibits bribery in any form, including bribes paid directly or indirectly through a third party.

The prohibition of FORSA S.A. on bribery includes “commercial bribery.” Commercial bribery usually means the delivery of something of value to an intermediary (for example, a customer’s employee) without the knowledge of the customer’s supervisor or employer, with the intent of improperly influencing the commercial conduct of the Company or to gain an improper business advantage.

• Law 1778 / 2016
  According to Law 1778 / 2016 “Whereby rules are set out regarding the liability of legal entities for acts of transnational corruption, along with other provisions regarding the fight against corruption,” the crime of transnational bribery is included in the framework of the acts of its employees, contractors, managers or partners (on their own or on behalf of any subordinated legal entity) when they provide, offer or promise a foreign public servant sums of money, any object of monetary value or other advantage or benefit in exchange for the latter to perform, omit or delay acts related to the exercise of their functions and in connection with an international transaction or business.

• Law 1474 / 2011 of Colombia
  According to Law 1778 / 2016 “Whereby rules are set out regarding the liability of legal entities for acts of transnational corruption, along with other provisions regarding the fight against corruption,” the crime of transnational bribery is included in the framework of the acts of its employees, contractors, managers or partners (on their own or on behalf of any subordinated legal entity) when they provide, offer or promise a foreign public servant sums of money, any object of monetary value or other advantage or benefit in exchange for the latter to perform, omit or delay acts related to the exercise of their functions and in connection with an international transaction or business.

The crime of private corruption occurs when a gift or any other unjustified benefit is promised, offered or granted, directly or through a third party, to executives, managers, employees or advisors of a company, partnership or foundation, for the benefit of the person or a third party, or to the detriment thereof.

In addition, the crime of improper management occurs when the de jure or de facto manager, or partner of any company, incorporated or in the process thereof, executive, employee or advisor, for their own benefit or that of a third party, by abusing the functions proper of its position, fraudulently disposing of Company assets or incurring obligations on its behalf, directly causing assessable economic damage to its partners.

Accordingly, FORSA S.A. and the Company Representatives are prohibited from providing or requesting from a third party any type of benefit for performing or failing to perform one of their duties (example: asking an individual for a reward or something of value in exchange for granting a contract with the Company, or when the individual offers the Company Representatives any type of benefit in order to perform or fail to perform one of their duties).

The Company’s Registered Agents, Senior Managers, Employees and/or Contractors who represent or act on behalf of the Company agree to fulfill their duties of loyalty and integrity, and will act so as to protect the Company’s assets at all times, generating a culture and commitment of zero tolerance to Transnational Bribery and any other corrupt practice.

• Prohibition of Facilitation Payments:
  Facilitation payments are prohibited at FORSA S.A., regardless of the amount. Facilitation payments are payments made to Government officials in order to ensure or expedite a routine government procedure or action for the benefit of an Employee or FORSA S.A.

Examples of facilitation payments include payments to process visas and expedite customs procedures, etc.

6. GIFTS, MEALS AND ENTERTAINMENT

The purpose of gifts, hospitality or entertainment activities is to create a good, solid working or business relationship. The purpose should never be to have or gain an unfair or undue advantage from a relationship. FORSA S.A. prohibits paying even a modest amount for meals, trips, lodging or entertainment for a corrupt purpose or in order to gain an unfair advantage.

This Policy recognizes that in business, meal, hospitality and entertainment invitations, and in limited circumstances, modest or symbolic gifts, are considered a courtesy. For instance, giving or receiving any gift of a symbolic and modest value, or cards, which are usually distributed for promotional purposes or during the celebration of a holiday, such as Christmas, is allowed.

• Rules for receiving gifts or hospitality
• The following acts will never be allowed:
• Accepting or receiving gifts from third parties, customers or suppliers in cash or cash equivalent for a corrupt purpose or in order to gain an unfair advantage.
• Accepting gifts, invitations, hospitality or other valuables that may be for the purpose of having an influence or material effect on any business transaction of FORSA S.A. (real or potential), or that may otherwise give rise to a conflict of interest.
• No Employee and/or their family will accept, directly or indirectly, any money, gift or invitation whose purpose is to influence the action or decisions made regarding the Company’s business, or that may lead the third party or Supplier to think they might somehow benefit or gain an advantage.
• Accepting any type of bribe, gift or inappropriate payment from anyone, including Suppliers or customers, in exchange for the promise of doing or refraining from doing something to benefit the third party.
• Any gift exceeding the equivalent of USD 30 (thirty US dollars) in local currency, or any meal invitation or hospitality provided by a third party or Supplier must be reported to the Compliance Officer.
• Any suspicion of attempted bribery by a third party or supplier must be immediately reported to the Compliance Officer.
• Rules for giving gifts, invitations or hospitality to Government Officials and third parties:
• The gifts, expenses or hospitality must be of a modest or symbolic value, separately as well as when considered together with other gifts or hospitality offered to the same recipient.
• They cannot be provided in order to exercise undue influence on a government official, or otherwise with the aim of influencing their actions or decisions, or in order to gain a business advantage for FORSA S.A.
• The following gifts, invitations or hospitality are never allowed:
• Gifts, invitations, hospitality or other valuables offered to third parties, customers or suppliers to obtain something in exchange;
• Gifts, invitations, hospitality or other valuables aimed at individuals who are in the bidding process where FORSA S.A. is a party of the public or private tender;
• Any gift that is in cash or a cash equivalent;
• Gifts, invitations, hospitality or other valuables that are frequently given to the same person or organization;
• Gifts, invitations, hospitality or other valuables that are excessive or extravagant, inappropriate or may negatively affect the reputation of FORSA S.A.
• The gifts or hospitality must be given on behalf of the Company and not in a personal capacity.
• This Policy applies even when the Company representative does not intend to or does not request reimbursement for the corresponding expenses.

7. MERGERS AND ACQUISITIONS

In each negotiation process and investment analysis, the Company will perform due diligence on compliance with Anti-corruption Rules before making a final decision regarding the investment or the merger.

Also, if the acquisition or merger takes place, FORSA S.A. will ensure that the company acquired implements these policies and the corporate Ethics program within a reasonable term, in order to prevent Transnational Bribery, along with the internal control systems and the corporate Code of Ethics, Conduct and Sanctioning System under the existing standards at FORSA S.A.

8. CONTRACTS WITH THIRD PARTIES

This Policy also applies to all the agents, suppliers, distributors and other third parties contracted by FORSA S.A. to do business on behalf of FORSA S.A. As a result, all contractors, such as agents, suppliers, distributors and other third parties acting on behalf of FORSA S.A. must state in writing their knowledge and acceptance of their obligation to comply with the rules related to preventing Transnational Bribery, as well as their knowledge and the obligation to accept the Company’s Ethics Program in all their activities, as well as this document, which contains the Compliance Policies. Said written representation will be made as per the applicable documents to each individual, or through the commercial contract or document that governs their legal relationship with the Company. In addition, said individuals will make this statement in writing in accordance with form GE-FR-05 R1 CERTIFICATE OF INFORMATION AND COMMITMENT TO THE ANTI-CORRUPTION AND ANTI-BRIBERY COMPLIANCE POLICIES Attached hereto

As a result, all the contracts in writing between FORSA S.A. and any contractor acting on its behalf must contain the relevant representations and warranties regarding anti-corruption behaviors. In addition to declaring and ensuring compliance with this Policy and the applicable anti-corruption laws and regulations, the contracts will also include the right of FORSA S.A. to terminate the contract in the event of a breach of this Policy, the corporate Ethics Program or any applicable anti-corruption or anti-bribery law or regulation.

The Compliance Office is responsible for verifying that the contracts include said representations and clauses.

9. POLITICAL CONTRIBUTIONS AND DONATIONS

All political contributions and donations made by FORSA S.A. must have a lawful purpose and be carried out following the legal procedures for their formalization.

Neither FORSA S.A. nor the Company Representatives, employees and/or senior management can make direct or indirect contributions or donations to political parties, government entities, organizations, government officials or individuals involved in politics, without the approval of the executive committee. No donations or contributions can be made in exchange for gaining advantages in the businesses of FORSA S.A. or in its business transactions.

10. ACCOUNTING RECORDS

It is the policy of FORSA S.A. to keep and maintain records and accounts to accurately and precisely reflect the transactions and disposals of the assets of FORSA S.A. Company Representatives, employees and/or senior managers cannot change, omit or misrepresent records to hide unlawful activities or those that do not properly indicate the nature of a recorded transaction.

11. REPORTING MECHANISMS

The Compliance Officer is responsible for receiving the queries, complaints and reports of possible acts that violate the Policies, the corporate Ethics Program and/or the Anti-corruption Rules.

FORSA S.A. has also provided an Ethics Hotline through which Company Representatives or Employees can safely, confidentially and anonymously – if the person so wishes – report any suspected violation of this Policy to FORSA S.A.

The Ethics Hotline will be managed and handled by an external company, which will report the reports or complaints received to the Compliance Officer and the External Auditor.

The information of the person placing the report, if provided, will be kept confidential.

The channels of communication provided by FORSA S.A. are:

Tel: (57) 2 8983930

Email: lineaetica@forsa.net.co

There will be no retaliation against Employees reporting in good faith any acts or potential violations of these Policies and/or the corporate Ethics Program. FORSA S.A. will not accept false or reckless reports or complaints. If it becomes apparent that the report is false or reckless, or has not been made in good faith, said conduct will be considered a violation of the Code of Ethics, Conduct and Sanctioning System of FORSA S.A.

12. SANCTIONS

Sanctions for violating the National Rules, the Anti-corruption and Anti-bribery Rules, and the corporate Ethics Program and Policies may result in severe sanctions for Company Representatives, employees, senior manager and/or contractors, and for FORSA S.A. itself.

Any Company Representatives, employees, senior managers and/or contractors that violate these Policies and/or the corporate Ethics Program will be subject to sanctions and disciplinary actions, including dismissal with cause pursuant to the provisions of the Internal Workplace Policy and the Substantive Labor Code, notwithstanding any other legal actions that may be taken for this reason. FORSA S.A. will apply the disciplinary actions fairly and promptly and in accordance with the violation.

Based on the decision of the Board of Directors, subject to the announcement by the Compliance Officer, FORSA S.A. will report to the competent authorities any violation of the Anti-corruption Rules that it becomes aware of during the course of its activity.

FORSA S.A. cannot assume the costs corresponding to the defense or the sanctions imposed on a Company Representative, employee, senior manager and/or contractor due to the violation of the Anti-corruption and Anti-bribery Rules.

13. DISCLOSURE

These Policies and the corporate Ethics Program will be disclosed through their inclusion in Daruma, on the FORSA S.A. website and through mass e-mails. In addition, the GE-FR-05 R1 CERTIFICATE OF INFORMATION AND COMMITMENT TO THE ANTI-CORRUPTION AND ANTI-BRIBERY COMPLIANCE POLICIES will be given to Agents and Suppliers, who must sign it.