✔️Anti-Corruption Policy

Measures and strategies aimed at preventing, detecting, and punishing corruption in both the public and private sectors.

PURPOSE

SW® focuses on meeting the needs of our customers while upholding professional and ethical values to maximize the quality of our operations. To fulfill this commitment and our responsibility to act with integrity at all times, we have established an 'Anti-Corruption Policy' designed to set control measures that prevent any form of fraud, bribery, or corruption, in compliance with the national laws and the countries where we operate.

Among the key elements of SW®'s strategy to prevent fraud, bribery, and corruption is our Code of Ethics, which establishes mandatory conduct rules for all our collaborators to follow. We are committed to ensuring that these standards are upheld and appropriate sanctions are applied in case of non-compliance. In this way, SW® aims to foster a culture of honesty and transparency in all its operations.

STATEMENT

SW® advocates for the importance of establishing general parameters of conduct that all collaborators must adhere to, in order to mitigate risks associated with fraud, bribery, and corruption.

Our policy aims to provide guidelines for identifying, measuring, controlling, investigating, and rectifying situations related to fraud, bribery, and corruption, promoting a culture of compliance and safeguarding the company's reputation, in line with the values outlined in our Code of Ethics.

Therefore, our 'Anti-Corruption Policy' explicitly prohibits bribery in all its forms. We understand bribery as anything of value offered, promised, paid, authorized, or delivered to a third party with the intention of unlawfully influencing a business decision or gaining an undue advantage in our operations. By emphasizing this prohibition, CCSCEX® seeks to ensure that all operations are conducted with integrity, transparency, and in accordance with applicable laws and regulations.

PRINCIPLES OF CONDUCT

With the primary objective of preventing corruption in all its forms in the countries where it operates, SW® consistently strives to implement best practices to combat these activities.

To this end:

• SW® promotes and fosters within the company an institutional culture that is anti-fraud, anti-bribery, and anti-corruption.

• Neither SW® nor its collaborators influence the will or objectivity of individuals external to the company in order to gain benefits through unethical or unlawful practices.

• SW® and its collaborators do not offer, promise, or provide, directly or indirectly, any tangible or intangible item of value to any individual or legal entity with the intention of gaining advantages for the company.

• SW® and its collaborators do not make payments to lower-ranking public officials with the intention of expediting or facilitating the performance of their responsibilities.

• SW® and its collaborators do not finance or provide support, directly or indirectly, to any political party, its representatives, or candidates.

• SW®'s donations are not used to cover improper payments.

• SW® and its collaborators do not improperly request or receive, directly or indirectly, commissions, payments, or benefits from third parties in connection with the company's investment, financing, or expenditure operations.

• SW® pays special attention to cases where there are indications of lack of integrity of individuals or companies with whom business is conducted, ensuring that the company establishes business relationships only with qualified individuals and companies with a suitable reputation.

• SW® accurately and appropriately reflects all actions, operations, and transactions of the company in its books and records.

  SW® encourages the training of its collaborators in the field of corruption prevention and combat.

• If collaborators have knowledge, doubts, or suspicions regarding any form of corruption, they must immediately report it to the Compliance Officer or their hierarchical superior.

• SW® will not tolerate any form of retaliation against those who, in good faith, report incidents that may constitute a breach of this policy.

In the event that a collaborator breaches any of these provisions, SW® reserves the right to take appropriate disciplinary measures, which may include contract termination, in addition to other potential legal consequences.

Likewise, the company reserves the right to take whatever actions it deems appropriate against suppliers, allies, and associates who violate these provisions. SW® takes its commitment to integrity and business ethics seriously and will act vigorously and effectively against any conduct that jeopardizes its reputation and its commitment to compliance with the laws and regulations applicable in the countries where it operates.

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