Objective.

This policy establishes the guidelines, rules, parameters and responsibilities to which all Itera employees, partners and suppliers must adhere to comply with the applicable anti-corruption and anti-bribery laws.

Scope.

• All Itera employees, Directors, Leaders.

• Business / Business Partners and suppliers that have dealings with Itera.

Gifts.

• It is allowed to receive and offer business services to customers and suppliers of a maximum value of US $ 1,000, the frequency and the amount thereof must not exceed the amount defined annually.

• Never you should offer, request, give or accept money in

Travels.

• only the travel necessary for the correct performance of the functions of the client’s representative or public official is allowed.

• The payment of expenses of family members or friends, as well as the payment of vacation or recreational expenses is prohibited.

Sponsorship of Events and Contributions to Charitable Organizations or Donations.

• Contributions and sponsorships of events for charities, for marketing and promotion of our services and commercial purposes, be for under US $ 2,000, the frequency and their sum must not exceed the amount defined annually.

• Due diligence is required on the charity or other recipient to determine if they are legitimate and are not being used as a bribe.

Behavior of Our Business / Business Partners or Suppliers.

• Commit to prevent bribery in connection with the corresponding transaction, project, activity or relationship.

• Itera requires conducting due diligence with the business partner / business or supplier to assess the nature and scale of any transaction, project, corresponding activity or relationship

• Itera is able to terminate the relationship with the business partner / business or supplier in the event of bribery by, or on behalf of, or for the benefit of the business partner.

Our commitments when working with business / business partners and or suppliers.

• Itera must determine if the business partner / business or suppliers have anti-bribery controls in place that manage the relevant risk of bribery.

• You should not ask business partners or vendors to provide services without any contract .

• Payments to business partners or suppliers should not be made in cash.

Due diligence is necessary in merger and acquisition activities.

• Before closing an acquisition, conduct anti-corruption due diligence to help you identify and mitigate risks.

• Itera will incorporate the acquired company into its internal controls and policies.

Conflicts of interest.

• When there is a conflict of interest related to the service of a third party, must be declared immediately to your leader

• Itera employees must not have any kind of commitment, remunerated or not, with a business partner or a competitor of Itera , as well as with any other person or company if it affects their performance in Itera.

Information, complaints, complaints, reports and non-retaliation .

• Itera always encourages and facilitates that clients , suppliers and employees of Itera express any type of concern, concern or complaint in relation to a situation of corruption or bribery:

• suppliers and customers can do it on the Itera page ( https://www.iteraprocess.com/make-report/) or by sending an email to the Talent Director Human who has the role of compliance with the anti-bribery policy humantalent@iteraprocess.com 

• Itera employees can do it directly to a reference person in the company (such as their immediate superior, their area manager or the person in charge of TH) and / or through satisfaction surveys sent by the Director of TH, They can also do it directly on the Itera page ( https/www.iteraprocess.com/make-complaint/) or by sending an email to the Director of Human Talent who has the anti-bribery compliance function humantalent@iteraprocess.com

Consequences of not complying with the established policy.

• In the event that any Itera employee violates the Anti-Bribery Policy, it will lead to the adoption of disciplinary measures.

• Business / business partners or suppliers that violate this policy are subject to termination of all business relationships with Itera.

• Sanctions are determined based on the Matrix of sanctions established in the Disciplinary Process.