CODE OF ETHICS

1. GENERAL OBJECTIVE AND PARTICULARITIES

1.1 General Objective

The purpose of this Code of Ethics (hereinafter, the “Code”) is to establish the rules of conduct and interaction applicable to Employees, both among themselves and with Third Parties. These relationships are fundamental to LETERAGO DEL ECUADOR S.A.; therefore, they must be carried out in full compliance with the provisions of this Code.

1.2 General Provisions

The application of this Code shall under no circumstances lead to a violation of the Applicable Regulations. Should such a circumstance arise, the Code must be adjusted in accordance with the provisions set forth in those legal regulations.

This Code shall take precedence over any internal rules, policies, and company regulations that may contradict it, except in cases where such internal regulations establish stricter conduct requirements than those contained in this Code or where the content of such internal rules, policies, and codes of conduct has been authorized with prior validation from General Management.

This Code does not alter the employment relationships between the company and its Employees, nor does it constitute an employment contract or a promise of employment for any specified period of time.

This Code is structured around the values and culture promoted by LETERAGO DEL ECUADOR S.A., which are known to all Employees.

The company operates based on the principles and guidelines of the Applicable Regulations, including:
i) The Universal Declaration of Human Rights of the United Nations and its protocols,
ii) The International Conventions approved by said international organization and the International Labour Organization (ILO) on social rights, as well as the principles of the United Nations Global Compact on Business Leadership,
iii) The Constitution of the Republic of Ecuador,
iv) The Labor Code,
v) Constitutional and Labor Mandates,
vi) Compliance with laws and relations with official institutions.

This Code of Ethics must be disseminated to all company personnel, as well as to new hires and stakeholders.

It demands the highest standards of honesty and ethical conduct, including appropriate and ethical procedures for handling real or potential conflicts of interest between professional and personal relationships of Employees.

LETERAGO DEL ECUADOR S.A. shall provide public administration bodies with information regarding the company, which must always be complete, fair, accurate, timely, and understandable. Additionally, the company undergoes national and international audits and certification processes, for which it commits to delivering the required information to auditing and certifying entities in a timely manner.

Additionally, this Code:

Requires compliance with Applicable Regulations.
Addresses the misuse of company assets and business opportunities.
Establishes the procedure for accepting gifts or invitations to any type of event by third parties, which must be duly authorized to avoid compromising the company’s reputation and business ethics.
Requires Employees to treat all information accessed through their connection with LETERAGO DEL ECUADOR S.A. with the highest level of confidentiality.
Requires Employees to immediately report any violation of this Code they become aware of, as well as any illegal conduct they detect.

The honesty, integrity, and sound judgment of Employees are fundamental to the organization’s reputation and success. Likewise, our company focuses on implementing techniques to provide the best possible solutions to Clients and the community.

2. SCOPE AND OBLIGATIONS

2.1 Scope of Application

This Code applies to all Employees and Third Parties concerning all activities of the company.

2.2 Obligations

All Employees are required to:

Be familiar with, adhere to, and apply the behavioral guidelines established in the company’s Anti-Corruption Program, as well as the provisions outlined in this Code and the policies and procedures developed and implemented within the company.
Seek guidance in case of any doubts regarding the scope of any provision of this Code in a specific situation.
Report to the company any situation or action contrary to the Applicable Regulations and/or the values and guidelines established in this Code.

For all Third Parties, their obligation is to:

Be familiar with, adhere to, and apply the behavioral guidelines established in this Code.

Report to the organization any situation or action contrary to the Applicable Regulations and/or the values and guidelines established in this Code.

3. DEVELOPMENT

3.1 General Philosophy, Principles, and Values

3.1.1 LETERAGO DEL ECUADOR S.A.

LETERAGO DEL ECUADOR S.A. is a leading company dedicated to the distribution and commercialization of pharmaceutical and related products. It is committed to providing high-quality service, meeting the requirements of our customers and stakeholders, supported by a quality management system. Additionally, the company adheres to Good Distribution, Transportation, and Storage Practices in line with national and international quality standards.

3.1.2 Company Values

Innovation and Creativity: Promoting an environment that allows for analyzing issues from different perspectives and achieving improvements in all areas of work.
Respect and Humility: The conceptual foundation of life that governs our personal relationships both inside and outside the company.
Professionalism: Taking responsibility for our actions with conviction, commitment, and accountability to achieve high performance and excellence.
Customer Orientation: Maintaining a genuine attitude of accessibility and a service-oriented approach toward those we serve.
Teamwork: The driving force behind decision-making, engaging all involved parties and facilitating synergy by sharing knowledge.
Flexibility: The ability to adapt to a dynamic environment, prioritizing the constant perception of the needs of those who benefit from our activities.

3.2 Conduct with Customers

3.2.1 Advertising and Marketing

The organization’s advertising must be clear, simple, honest, and transparent, in compliance with applicable regulations.

3.2.2 Responsibility

Employees must not engage in or contribute to any illegal activities under any circumstances.
b. Employees must not use Discounts and/or Promotions as practices through which, by abusing power, functions, or resources, they gain or seek to gain a benefit or influence future customer decisions.

3.3 Conduct with Employees

3.3.1 Respect and Fair Treatment of Employees

LETERAGO DEL ECUADOR S.A.’s commitment is reflected in the following principles:
a. Diversity and Inclusion: Respect for the rights and privacy of each employee and a commitment to zero tolerance for discrimination or harassment in the workplace.
b. Pay and Opportunity Equity: Ensuring fair wages and eliminating any unjust disparities based on gender, race, or other personal characteristics.
c. Training and Awareness: Implementing training and awareness programs for all employees to raise awareness about the importance of equality, diversity, and inclusion.
d. Gender Mainstreaming: Promoting the systematic and cross-cutting integration of the gender perspective in all policies, programs, projects, and activities of the organization.
e. Participation and Leadership: Encouraging the participation and leadership of all employees at all levels of the company, including decision-making positions.
f. Monitoring: Promoting the use of monitoring and evaluation methods to ensure respect for gender equality in our internal processes.
g. Gender and Equality Approach: Prioritizing companies that demonstrate good practices in gender and equality matters in procurement processes.
h. Labor Exploitation, Child Labor, or Violation of Fundamental Rights: Categorically rejecting all forms of labor exploitation, child labor, or violations of fundamental rights.

3.3.2 Employee Health and Safety

The company provides a safe and healthy work environment for its employees, complying with Applicable Regulations and LETERAGO DEL ECUADOR S.A.’s policies regarding occupational health, hygiene, and safety.

3.4 Professional Rigor

The concept of professionalism in the organization is closely linked to the service-oriented nature of its activities and the employees’ sense of belonging to the company and its vision. All actions performed within the company’s operations must be guided by professional responsibility and governed by the principles established in this Code.

3.5 Fair and Equitable Business Practices

Each employee must commit to observing fair and equitable practices with Customers, Third Parties, and fellow Employees.

3.6 Management Styles

3.6.1 Responsibility and Teamwork

Employees must make decisions within their scope of responsibility, respecting applicable regulations, procedures, and the organization’s values. Additionally, employees must exercise their responsibilities in line with the company’s management style while fostering a positive work environment that enables the smooth development of activities under the organization’s established conditions.

3.6.2 Objectivity in Employee Selection, Hiring, and Promotion

The company’s employee selection and promotion process is based solely on professional qualifications and the candidates’ ability to perform the job. We implement local policies that promote inclusion and diversity, ensuring that objectivity is the only determining factor in our decisions, without allowing external influences that could compromise the fairness of the process.

3.6.3 Use of IT Tools and Email

The email and IT tools provided by the company to employees are work instruments that must be used exclusively for tasks assigned by the company.

3.7 Conduct Within and Toward LETERAGO DEL ECUADOR S.A.

3.7.1 Competition Law Compliance

The company complies with all Applicable Regulations concerning competition law and unfair competition. Specifically, LETERAGO DEL ECUADOR S.A. and its Employees must adhere to the following practices:

No exchange of information with interest groups regarding pricing, production, customer selection, or any other type of competitive or technical information.
No agreements may be made concerning such matters (e.g., price-fixing, market allocation, bid manipulation) with interest groups.
The organization commits to avoiding participation in trade associations or meetings with interest groups that involve exchanging sensitive information or signing agreements that could undermine free competition, such as price-fixing, market allocation, or bid manipulation.

3.7.2 Conflicts of Interest

A conflict of interest arises when an employee’s personal interests conflict in any way with the company’s interests. Every Employee is expected to avoid situations that could result in a substantial, actual, or potential conflict between their personal interests and their duties and responsibilities as an Employee.

If a current or potential situation arises where personal interests conflict with the company’s interests, the Employee must follow the guidelines outlined in the Conflict of Interest Manual. Employees may not have any material financial interest in a Third Party or engage in activities that undermine or could undermine the organization’s interests.

Before committing to act as a director, consultant, or advisor for a Third Party or any other legal entity, Employees must inform their immediate supervisor and follow the guidelines established in the Conflict of Interest Manual.

Personal matters must be handled impartially and fairly, and no Employee shall be given an advantage based on personal relationships in matters such as selection, evaluation, transfer, or promotion. The company selects clients and suppliers based on objective standards without favoritism due to personal relationships.

3.8 Intellectual Property Rights

All intellectual property rights developed or acquired by LETERAGO DEL ECUADOR S.A. through research, development, purchase, assignment, or other activities (including, but not limited to, patents, designs, copyrights, trademarks, know-how, data, and technical knowledge) are assets of the company.

Therefore, the intellectual property of LETERAGO DEL ECUADOR S.A. must be carefully protected by Employees and Third Parties, who must cooperate in the establishment, protection, maintenance, and defense of the company’s intellectual property rights.

3.9 Personal Data and Privacy Protection

We recognize and respect the rights of personal data holders, including the right to access, rectify, or delete their information. The company is committed to facilitating the effective and timely exercise of these rights while ensuring ongoing compliance with Applicable Regulations on personal data protection.

3.10 Accounting and Auditing

3.10.1 Accounting

Employees shall comply with the Applicable Regulations and the company’s internal policies related to accounting, ensuring that transactions are recorded in the company’s books in accordance with generally accepted principles and the Applicable Regulations (IFRS).

3.10.2 Auditing

Employees shall provide truthful, accurate, and timely information to meet the requirements of both internal and external auditors, who must comply with the Applicable Regulations.

3.11 International Trade Controls

LETERAGO DEL ECUADOR S.A. and its Employees shall comply with the Applicable Regulations regarding product imports.

3.12 Confidential Information and Information Retention

3.12.1 Confidential Information

Non-public information related to LETERAGO DEL ECUADOR S.A., its businesses, Employees, and Third Parties is confidential. The company is committed to protecting the availability, confidentiality, and integrity of the information it handles by implementing information security policies.

Company Employees must always act in accordance with the information security policy, using data and assets exclusively for authorized work-related purposes.

Employees must not share confidential information with Third Parties, including family and friends, nor with any other Employee who does not require such information for the proper performance of their duties. Employees who detect any suspicion, incident, or activity that violates the information security policy must promptly notify their direct supervisor.

This obligation to maintain strict confidentiality remains in effect for five (05) years after the Employee’s employment with the company ends.

Confidential information includes but is not limited to:

Significant and non-public financial information related to LETERAGO DEL ECUADOR S.A. or any of its subsidiaries.
Trade secrets, including commercial or technical information such as programs, methods, techniques, compilations, or information that holds value due to its non-public status.
Intellectual property, including any invention or process developed by an Employee using the company’s facilities, assets, or commercial activities. This includes results derived from work assigned by the company or related to its business activities.
Exclusive company information, such as customer lists.

3.12.2 Documentation Retention

LETERAGO DEL ECUADOR S.A. retains documentation based on the type of information and applicable laws and regulations within Ecuador. Failure to comply with these guidelines may result in disciplinary actions, including corrective measures or termination of employment, reinforcing our collective commitment to a secure and ethical information management environment.

3.13 Legality

The company understands that compliance with Applicable Regulations is not only an external requirement but also an obligation for the company and its Employees. The Applicable Regulations ensure security in operations and reduce business risks. Any action that violates the law is strictly prohibited. If there is any doubt about the legal correctness of an action, the legal department of the organization should be consulted in advance.

3.14 Use of LETERAGO DEL ECUADOR S.A. Resources

Employees must commit to using company resources properly and efficiently for professional activities. These resources must not be used for personal purposes. Employees must follow internal processes and policies for the use of these resources and take necessary measures to prevent their loss, theft, damage, or waste. Any company property provided to an Employee must be returned when requested, when it is no longer necessary for professional activities, or upon the Employee’s departure from the company.

3.15 Expenses

When Employees use or authorize the use of company funds, they must obtain the necessary approval following company policies and procedures. They must ensure that the expense is appropriate, reasonable, and proportional to the circumstances, relates to achieving company objectives, and is properly documented.

3.16 Social Media Presence

When an Employee publishes personal opinions or information in their name on social media or any public platform, they must not use their status as an Employee or make any reference that could attribute or imply that the published content is endorsed by LETERAGO DEL ECUADOR S.A. or any of its subsidiaries.

3.17 Community Conduct

3.17.1 Anti-Corruption and Conduct Guidelines

The organization and each of its Employees commit to complying with the Applicable Regulations on anti-corruption, including the United Nations Convention against Corruption, approved by the UN General Assembly on October 31, 2003. The objectives of this document are:

To promote and strengthen measures to prevent and combat corruption more effectively and efficiently.
To promote, facilitate, and support international cooperation and technical assistance in preventing and combating corruption, including asset recovery.
To promote integrity, accountability, and the proper management of public affairs and assets.

Neither the company nor its Employees shall give, offer, or promise a bribe (including money, goods, gifts, or any item of value), directly or indirectly, to public officials in any country where the company operates or elsewhere.

The company and its Employees shall not provide any form of payment or benefit to private sector individuals or entities to influence them or obtain or maintain any commercial advantage.

No Employee shall offer, promise, provide, request, or receive, directly or indirectly, any gift intended to influence or attempt to influence unjustifiably the decisions of Third Parties or Employees regarding the company’s activities.

3.17.2 Environment and Sustainable Development

The company is committed to minimizing the environmental impact of its operations. To this end, it complies with Applicable Regulations on environmental protection and follows its policies on sustainability in all business activities.

4. Code Compliance

4.3 Code Administration

This Code shall be administered and supervised by the General Manager and the “Delegates Committee,” composed of individuals designated by the General Management. Any questions or requests for further information regarding this Code of Ethics should be directed to them. Employees and Third Parties are expected to comply with the provisions of this Code at all times.

4.4 Code Violations

Violations of this Code may result in disciplinary actions under the Applicable Regulations, including termination of employment or commercial relationships, depending on the nature and severity of the violation. Any Employee who directs, approves, ignores, or is aware of violations of this Code and fails to report them immediately through the whistleblowing channel shall be subject to disciplinary actions, including termination of employment or commercial relationships.

4.5 Reporting Illegal Behavior

If an Employee or Third Party becomes aware of violations of this Code or the Anti-Corruption Program, or any known or suspected directive that affects the company or its Employees or contradicts the Applicable Regulations, they must report it through the online whistleblowing channel of LETERAGO DEL ECUADOR S.A. This channel is available 365 days a year and is published on the company’s website and internal networks.

4.6 Whistleblower Protection

The whistleblowing channel is an essential part of the company’s compliance system, ensuring the effective application of the Applicable Regulations and this Code’s guidelines. It also serves as a means for reporting observed or communicated violations by Employees and/or Third Parties.

Reports through this channel may include, but are not limited to, suspected illegal or professionally unethical conduct. The Delegates Committee will process whistleblower reports diligently and promptly, verifying the claims and taking appropriate resolution measures in accordance with the reporting program.

Information will be analyzed objectively, impartially, and confidentially. The identity of the whistleblower will be kept confidential, and information will only be shared with relevant company areas necessary for verification, avoiding any impact on the investigation or reputational harm to those involved. The results of verification actions will be communicated to relevant company areas for implementing mitigation or corrective measures. Additionally, appropriate notifications will be made to the whistleblower and the reported individual, as applicable.

*Interpretation: The titles of this Policy are for organizational purposes only and shall not affect or condition its content. Unless the context requires otherwise: (i) a reference to a gender includes all genders; and (ii) singular words include plural meanings and vice versa.

This Code of Ethics was approved by the General Manager on January 1, 2025.