OBJECTIVE	To communicate the ethical standards of BPM Consulting SAS that regulate the expected framework of conduct for our employees, management committee, and partners in workplace interactions and behaviors, as well as in relationships with competitors, suppliers, clients, and citizens, in accordance with corporate values. This Code applies as a corporate policy.
SCOPE	Applies to the entire organization and all stakeholders.
ASSOCIATED DOCUMENTS	Supplier Code of Ethics Anti-Corruption, Anti-Bribery, and Anti-Fraud Policy Data Processing Policy Diversity, Inclusion, and Equity Policy Workplace Harassment Prevention Policy Occupational Health and Safety Policy Internal Work Regulations Information Security Policy Work Disconnection Policy Marketing and Sales Management Policy Business Transparency and Ethics Program (PTEE) Manual

ROLE & RESPONSIBILITY
ROLE (POSITION)	RESPONSIBILITY
General Manager Deputy General Manager Area Managers Leaders with personnel in charge	Promote participation, proper conduct in accordance with corporate values, and compliance with the Business Code of Ethics in all work environments and interactions with third parties.
Entire Organization Suppliers Business Partners	Apply the guidelines established in the Business Code of Ethics.

TERMS AND DEFINITIONS

Ethics: Standards and values that regulate the conduct of BPM Consulting employees, suppliers, and business partners.

Corporate Values: They represent the convictions and interests that the organization defines as genuine and considers fundamental in its daily activities.

ETHICS IN THE WORKPLACE

For BPM Consulting, ethics in the workplace means:

Valuing Diversity, Equity, and Inclusion

We are convinced that embracing a diverse and inclusive world allows for better coexistence, as well as participation in the workplace by any person who has the skills and competencies required to perform a role, regardless of sexual orientation, gender identity, ethnic background, age, disability, place of origin, social class, or any other distinguishing characteristic. We do not accept discrimination under any circumstances.

Dignified, Fair, and Respectful Treatment

Our interactions are based on respectful dialogue, using language appropriate to the context and conversation. We do not agree with abuse of authority, and although leadership roles exist, those who hold them must give instructions objectively, respectfully, and assertively. We do not accept workplace harassment under any circumstances.

We comply with labor legislation as established by the Colombian Labor Code and other laws regulating employment relationships. We offer salaries and working hours according to our clients’ guidelines, which at no time may undermine the standards established by the national government.

Honesty

Honesty is the value that supports our anti-corruption, anti-bribery, and anti-fraud policy, which is mandatory in all its content. Everyone who is part of BPM Consulting must act consistently with truth, transparency, and honesty, fulfilling assigned responsibilities, verbal and written agreements, and the trust placed in each person as part of the BPM family.

Likewise, as guardians of the organization, we must promote honesty, proper work, and work done correctly. We must be faithful representatives of our corporate values in any work or professional environment in which we operate.

Conflict of Interest

Personal interests must not interfere with objective and impartial decision-making regarding work at BPM Consulting. We must avoid conflicts of interest; therefore, the organization establishes the following within this Code:

• Business decisions must follow objective and impartial processes, without any benefit (money or in-kind) for any third party.
• Participation in decisions involving the hiring or supervision of friends or family members is not allowed.
• Economic transactions, loans, or personal credit arrangements with clients or suppliers are prohibited.

Safe Work Environment

We seek the well-being of our employees and therefore make every effort to provide a workplace where healthy behavior, collaboration, and harmony prevail. Accordingly, we remind our employees of their obligations regarding:

• Not consuming drugs or alcohol during working hours
• Not promoting or participating in violent behavior; not carrying and/or using weapons; avoiding physical or material damage
• Working with professionalism

A safe workplace also requires everyone’s participation in Occupational Health and Safety provisions. Therefore, it is necessary to:

• Comply with all laws, policies, and regulations established by the company regarding safety, health, and environmental care
• Properly use the means provided for the final disposal of solid, electrical, and electronic waste, as well as energy and water conservation
• Promote compliance with our occupational health and safety policies among suppliers with whom we interact daily

Assets and Information
All employees have access in different ways to BPM Consulting’s tangible and intangible assets, including facilities, equipment, technology, information systems, and intellectual property. In line with our duty of care, we are responsible for and required to protect assets and information from damage, theft, unauthorized access, or misuse.

Confidential information, proper handling of personal data, and intellectual property are also highly valuable assets for the organization. Therefore, compliance with Information Security policies, confidentiality agreements signed at the beginning of our employment relationship, and the Internal Work Regulations is essential.

These actions help protect BPM Consulting’s reputation and preserve everyone’s good name.

Communication and Social Media
The organization provides communication resources for the development of its operations, the promotion of its services, and brand strengthening. Only individuals authorized by the organization may use social media to speak on behalf of BPM Consulting and publish corporate content.

In this regard, employees are required to:

• Use information systems and communication resources professionally and only within the work environment
• Ensure that emails and the information contained in them represent the company appropriately and are used objectively, impartially, and for work purposes only
• Conduct work-related communication only through the channels defined by the organization
• Avoid using any other communication methods that contradict regulated provisions
• Ensure that conversations with colleagues or external personnel are not related to corruption, bribery, or fraud

Regarding social media use, although the organization cannot control each employee’s comments, employees are encouraged to ensure that personal opinions are clearly identified as such and do not represent BPM Consulting in any way.

Record Retention
Records are part of the evidence of the development and fulfillment of our activities; they are valuable because they represent the company’s history and allow us to maintain traceability of executed processes. As employees, we must:

• Maintain records of our work in accordance with corporate guidelines
• Preserve records according to the instructions received
• Not manipulate the information systems to which we have access
• Make proper use of assigned access credentials and maintain the confidentiality of usernames and passwords

Financial Records

Senior Management, regulatory entities, clients, and the community in general rely on our financial information to conduct business and make decisions that impact the company. In this regard, those responsible for financial management must:

• Ensure that financial, accounting, and tax records accurately and reasonably reflect the company’s operations
• Maintain appropriate controls in the management of transactions and accounting records
• Not reimburse expenses for personal benefit
• Not carry out fictitious transactions or false accounting entries
• Not participate in or approve records that are not properly supported
• Approve payments only for their intended and agreed purposes through contracts, purchase orders, and/or agreements supported by documentation

Intellectual Property

BPM Consulting respects the property rights of third parties and likewise expects others to respect its own rights. In this regard, we commit to:

• Using client information only for its intended purposes, in accordance with the authorizations granted for the use and access of information
• Acquiring legal software and information systems
• Requesting and obtaining permission before using third-party trademarks or logos

ETHICS WITH COMPETITORS AND SUPPLIERS

Negotiations and Agreements

Negotiation processes are carried out transparently and fairly with our competitors and suppliers. We do not use unethical or corrupt practices to achieve expected results. In this regard, we are responsible for:

• Competing based on the merits and results achieved as a company
• Providing accurate, real, and truthful information
• Not making false or misleading statements
• Using legal and ethical methods to gather information
• Not offering benefits, rewards, or carrying out any action that violates anti-corruption, anti-bribery, and anti-fraud policies

Regarding agreements, we honor commitments established through signed contracts. Therefore, we ensure that these agreements are supported by our operational, financial, and resource capabilities.

In our relationships with competitors and suppliers, we value free competition and therefore do not accept explicit or implicit agreements related to:

• Prices or sales terms
• Limitations or restrictions
• Exchange of prices, costs, or other competitive information
• Discussing with competitors prices, costs, or BPM Consulting information, whether current or future, nor participating in the boycott of any competitor or supplier

ETHICS WITH CLIENTS

Quality of Services

Companies that choose BPM Consulting trust that our work will be carried out according to agreed terms and will meet expectations that may have been communicated to the organization. Therefore, as employees, we must:

• Know and apply policies, procedures, and, in general, all information related to BPM Consulting service processes, as defined through the Integrated
• Management System
• Ensure that all our deliverables meet organizational standards and comply with client requirements
• Comply with all operational and technical guidelines defined for each project
  Include and maintain project operation records in the information systems enabled for this purpose
• Maintain smooth communication with colleagues, leaders, and supervisors to ensure operations develop as expected

Government Clients

At BPM Consulting, we provide services to government entities; we value long-term relationships, as well as the trust that arises from our correct actions and constant effort. Our guidelines for interacting with government clients mean that:

• We must comply with the rules of each government (national or foreign, when applicable)
• Maintain the highest level of integrity in our interactions with government employees
• Ensure that commercial, bidding, and negotiation processes are carried out by
• General Management and/or whomever they designate to represent or accompany them
• Guarantee honesty in the exchange of information
• Comply with guidelines regarding regulations, controls, rules, and, in general, contractual obligations
• Clearly define client interactions and document them in the Project Quality Plan
• Report and denounce through the appropriate channels any actions that may go against truth and ethical conduct

Citizen Service

The services we provide to our clients may involve interaction with citizens. For this reason, our actions must reflect the principles promoted by the Colombian State regarding equality, morality, efficiency, impartiality, and responsibility.
Regardless of whether our clients are public or private companies, our conduct as BPM Consulting employees toward the end user must be characterized by:

• Equality: Providing equal treatment to all citizens
• Morality: Acting with integrity, loyalty, and honesty
• Transparency: Providing clear, timely, and accurate information
• Impartiality: Respecting everyone’s rights without discrimination or emotional bias
• Responsibility: Being accountable for every action and assuming the consequences of every act
• Efficiency: Not delaying responses to citizens, avoiding unnecessary delays or inaction
• Due Process: Carrying out processes in accordance with applicable regulations

REPORTING

BPM Consulting, in its interest in determining improvement actions where necessary, provides its PQRSF channel through its website’s https://bpmconsulting.com.co/ PQRSF module (specifying “Business Ethics” in the subject section), so that employees, individuals, legal entities, and citizens may report irregular practices or transactions carried out by any of our employees or those acting on behalf of BPM Consulting that violate the Business Code of Ethics.

Complaints involving employees are handled confidentially and follow the due process established in the Internal Work Regulations through the Human Talent Management Department.

Complaints submitted directly by clients to the Operations Management Department will be transferred to the Human Talent Management Department and, when applicable, reported to the Control, Improvement, and Innovation Management Department.

Each case will be handled individually, and depending on the seriousness of the matter, intervention by Deputy Management and/or General Management will be requested.

In all cases, records will be maintained through the PQRSF information system to ensure monitoring, control, and traceability of submitted requests and claims.

Cases received through channels other than the official PQRSF website channel must be reported to the Control, Improvement, and Innovation Management Department so they can be included in the corresponding information system and followed up accordingly.

Response times are regulated by Colombian legislation, specifically Law 1755 of 2015 or any regulations established by the Colombian State regarding petitions, complaints, claims, and reports.

VALIDITY
The policies established by BPM Consulting SAS regarding the Business Code of Ethics may be modified at any time. Any modification will be made with authorization from Deputy Management and/or General Management and will become effective upon publication through internal corporate channels and on the company’s website, so that interested parties are aware of its content and any changes made.

COMPLIANCE

BPM Consulting’s Senior Management reaffirms its commitment to acting under ethical principles in all areas. Violations of the Code of Ethics or any related corporate policies may result in disciplinary sanctions regulated by the Internal Work Regulations for serious misconduct, which explicitly include:

• First offense: suspension from work for up to five (5) days without pay
• Second offense: suspension from work from six (6) days up to two (2) months without pay

Notwithstanding the provisions of this chapter on Serious Misconduct in the Internal Work Regulations, following disciplinary proceedings and respecting due process for the employee, the employment contract may be terminated for just cause, with notification to the Colombian State Control and Supervisory Entities.

TRACEABILITY
VERSION	APPROVAL DATE	CHANGE CONTROL
1	19-01-2021	Document creation
2	07-06-2023	Communication channel updated; policy format updated (the regulatory matrix was removed)
3	07-12-2023	Complete document review. Standardization of the organization’s name. Formatting adjustments in the document content. Change in document classification (it became a Public document)
4	23-01-2024	Complete update of the document content. Change in the process issuing the document. Initially, it was created from the Control, Improvement and Innovation process; however, due to its nature, relevance, and content, it is a policy managed under the “Strategic Management” process. This change required adjusting the policy coding (from CMI-PO-4 to DRE-LN-3)
5	02-09-2024	Inclusion in the Associated Documents chapter of the Business Transparency and Ethics Program Manual (PTEE)