I. OBJECTIVE

The purpose of this Code of Ethics and Conduct (Code) is to ensure that all workers have knowledge of the principles of personal integrity that they are required to exercise in conducting the company's business and their private and financial affairs.

These principles must guide and orient the professional behavior of employees of all companies of the Kairós Group (KAIRÓS DIGITAL ANALYTICS AND BIG DATA SOLUTIONS S.L., KAIROS DIGITAL SOLUTIONS GROUP, S.L., KAIROS DIGITAL SOLUTIONS MÉXICO, S.A DE C.V., KAIRÓS PERÚ DIGITAL SOLUTIONS SOCIEDAD ANÓNIMA CERRADA (hereinafter referred to as Kairós Group, the Company, Company), expecting that the referred personnel act following the highest standards of personal and professional integrity in all their activities, complying with all applicable laws and regulations; and that they reject and dissuade others from performing acts of bad faith. This Code reflects the commitment of the entire Group to act in accordance with values that guarantee responsible behavior in all the companies' relationships, both with their own workers, clients, suppliers, shareholders and with society in general.

In this way, its inclusion with the United Nations Global Compact, the 2030 Agenda and Sustainable Development Goals (SDGs) is promoted, as well as its future inclusion in Framework Agreements in the field of environment.

The purpose of this Code of Ethics is to formalize KAIRÓS's commitment to Human Rights recognized in national and international legislation, as well as to define the principles that the Company will apply for human rights due diligence, in accordance with the Guiding Principles on business and human rights, the OECD Guidelines for multinational enterprises, the principles on which the United Nations Global Compact is based, the Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy, the conventions of the International Labour Organization (including convention 169), the Sustainable Development Goals (SDGs) approved by the United Nations (UN), included in this Code of Ethics, as well as the documents and texts that may replace or complement those previously referred to.

We recommend complying with the Code of Conduct and KAIRÓS's policies and procedures, since those who violate these rules will be subject to disciplinary actions that may even lead to termination of the employment relationship.

II. GENERALITIES

KAIRÓS GROUP workers will have access to all policies implemented within the Company, and which must be duly complied with and observed by the worker and all interested parties.

KAIRÓS GROUP, through this procedure, implements a channel that allows confidential communication of those actions or conducts that may be considered to violate the principles established in the code of ethics. The Legal Department, in charge of receiving them, may act, together with the Human Resources Department, on its own initiative or at the request of any properly identified employee or interest group.

Any employee of KAIRÓS GROUP or person from an interest group may report suspected non-compliance that they detect of the code of ethics or in its employees. This procedure guarantees that the identity of the person communicating an anomalous action is preserved. In case of doubt or consultation about any particular point(s), this/these must be clarified by their immediate superior or by the Legal department of KAIRÓS GROUP: legal@kairosds.com. Communications containing complaints of non-compliance or queries regarding the interpretation or application of the code of ethics may be sent to the Legal Department through email legal@kairosds.com, or to the attention of the Legal Department of KAIRÓS GROUP at the following address:

C/Caleruega, nº102, C.P 28033, Madrid (Madrid).

The Legal Department assumes the commitment to resolve any matter submitted to its competence. To carry it out, it can be done through the complaints channel, located on the Kairós corporate website:

Kairós Group Complaints Channel

Measures in case of non-compliance

Trusting that all employees of KAIRÓS GROUP will follow the rules of conduct contained in the code, in the event that any type of non-compliance is detected, the HR Area together with the advice of the Legal department, will study each case to adopt appropriate disciplinary measures that may range from a warning, sanction, job relocation to dismissal.

For this, what is stipulated in Law 2/2023, of February 20, which regulates the protection of people who, in any work or professional context, report regulatory violations and anti-corruption through the internal complaint channel, effectively, confidentially, with guarantee of independence and impartiality, a process that will be developed in a communications management policy, will be taken into account.

In all cases, the principle of proportionality will be taken into account, taking into account the damages produced to KAIRÓS GROUP.

III. VALUES

Put the interests of KAIRÓS GROUP above those of each particular worker

• Promote the good position and good name of the Company and defend it against unfounded criticism.
• Avoid conflicts between one's own interests and the interests of the Company or its clients and be willing to report any potentially compromising or conflicting business relationship or shareholding.
• Manage personal and financial affairs in a prudent manner and without becoming involved in financial commitments that cannot reasonably be fulfilled.
• The vocation for creative innovation and leadership, characteristic features of our culture.
• Co-responsibility in management and orderly delegation of functions, bases of our management style.
• The training and development of our workers, active policies for work-life balance and respect for the principle of equality, pillars of our KAIRÓS GROUP.
• Not assume directorships, positions or consultancies outside the Company, which may harm KAIRÓS GROUP, whether free or paid, without written approval from the Company.
• Safeguard the Company's confidential information and restrict access to all confidential or critical documentation.
• Respect for the environment and the application of preventive measures that guarantee the safety and health of our workers, framework for the development of all our activities.
• KAIRÓS GROUP assumes the commitment to act at all times in accordance with current legislation and internationally accepted ethical practices, with total respect for Human Rights and public freedoms. The activities and operations of KAIRÓS GROUP are developed in accordance with its Corporate Culture and Procedures that have been developed from the Company Policy and the United Nations Global Compact, whose objective is the adoption of universal principles in the areas of human rights, labor standards and environment.
• KAIRÓS GROUP respects freedom of association and collective bargaining. Likewise, it rejects child labor and in general, any form of exploitation; we will not tolerate forced labor or work that involves physical or psychological abuse or the exploitation of any disadvantaged group or illegal labor trafficking. Similarly, KAIRÓS GROUP commits not to employ foreign citizens or minors who lack work permits.
• People will not be discriminated against by country of origin for migrants and/or foreigners and their rights and obligations will be recognized. Any hiring made at KAIRÓS GROUP will be done in accordance with current legislation. Illegal trafficking or clandestine immigration of people will not be promoted or favored, either directly or indirectly, nor will migrants and/or foreigners be intimidated, deceived or abused.

Comply with the spirit and letter of all laws and regulations

• Not voluntarily participate in any activity that could in any way be associated or considered related to illegal or criminal activities or that could be contrary to the national interest of any country in which the Company operates.
• Not voluntarily participate in any business in which KAIRÓS GROUP might not be interested in being associated with, even if such activity is not illegal in the jurisdiction in which it is carried out and conforms to local uses and customs.
• Scrupulously reject all illegal, fraudulent, dishonest or immoral conduct, all personal affairs and business operations.
• Report to the appropriate level of internal authority all behavior that may violate the law, regulatory requirements or the Company's policy or values.

GENERAL CODE OF CONDUCT

A) Confidentiality

All employees of KAIRÓS GROUP are obliged to protect confidential or reserved information of which they are aware by reason of their position −whether technical, financial, commercial or of any other nature− and not use it outside the scope of their employment relationship, nor reveal to third parties without the Company's prior written consent, except for those requests for information that are required by judicial or administrative authority in legal terms.

Knowledge of protected information to which any employee has access, as a consequence of their relationship with suppliers and subcontractors, will have the guarantees provided for in the Data Protection Law.

Those employees who, due to their high responsibilities, have access to especially sensitive information may be required by the Company to sign specific confidentiality commitments as an annex to their main employment contract.

The company will guarantee its employees, suppliers, clients and any third parties with whom it has a relationship the faithful compliance with data protection regulations and thus confidentiality, adopting the relevant measures in its Organization so that said regulations have full effectiveness. Within these measures, it is worth mentioning:

• The information related to the business and systems of the company or about any other member of the Committee is confidential and must be treated accordingly.
• The business and private affairs of clients must be treated with strict confidentiality. They must not be revealed to any outside client, or to third parties, or even to any member of the Committee or associated company, without the client's consent.
• In some cases, due to conflicts of interest, information known by a member of the company should not be disclosed to other companies.
• The worker is responsible for the care of confidential client information, whether at home, office or in any place or establishment where they are, always ensuring the care of information, as if it were their own business or affair.
• Whoever relates to KAIRÓS GROUP, whether commercially or employment-wise, must sign a specific document on confidentiality, which will be annexed to the contract or within it, which conforms to what is described here.
• The rights arising from any type of invention or product or service development are the exclusive property of KAIRÓS GROUP, in all the main and intrinsic elements to its sale or use, conditioned to KAIRÓS GROUP's own permission and the relationship that exists between the Parties. Consequently, the violation of such extremes may be pursued judicially by KAIRÓS GROUP.

B) Data Protection

All workers have the responsibility to ensure that the data collected is accurate, updated and remains secure. Information stored on computers must be used only for the purposes for which it was obtained. Its unauthorized disclosure is prohibited as it constitutes a serious crime and may give rise to criminal action. KAIRÓS GROUP has a security protocol on Data Protection that develops this precept and governs normatively, according to the applicable legislation in each country:

Spain: Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights, Regulation (EU) 2016/679 and Directive (EU) 2016/680.

Mexico: Federal Law on Protection of Personal Data Held by Private Parties

Peru: Law No. 29733 (Personal Data Protection Law) and Supreme Decree No. 016-2024-JUS.

KAIRÓS GROUP is ultimately responsible for the processing of data collected in the business sphere, however, it may repeat the actions it deems appropriate to safeguard its interests against whoever violates their duty of information and good custody. Data, in any case, may be transferred by Public Administration, judicial mandate or legal imperative, as well as in the exercise of the inherent functions of the position, where it

The exercise of the rights of access, rectification, deletion, opposition, not to be subject to automated individual decisions (including profiling), portability and limitation of data processing may be filed, via email to lopd@KAIRÓSDS.com indicating as reference "Data Protection", for which documentation may be requested that duly accredits the identity of the interested party.

In case of any type of violation regarding Personal Data Protection, the worker commits to inform KAIRÓS GROUP about this case, indicating what happened with total accuracy. Otherwise, and being aware of this case, the worker could incur a disciplinary sanction.

Once the worker brings to KAIRÓS GROUP's attention what happened, it will study the situation and if it believes it appropriate and considers that a violation regarding Personal Data Protection has been committed, it will communicate it to the Spanish Data Protection Agency (AEPD).

In case of Data Protection violation, the worker must send all information they know to:

GRUPO KAIRÓS

Company Premises:

CALLE CALERUEGA, 102, 28033 Madrid (Madrid)

Email address:

lopd@GRUPO 

https://kairosds.com/ 

C) Commitment to KAIRÓS GROUP Clients

Among the main qualities that KAIRÓS GROUP workers must observe, towards clients, are the following:

• Understand and analyze client needs.
• Listen to suggestions from clients and co-workers, and even from the client's personnel, specialized and/or assigned to the project.
• Be punctual in work schedule, in appointments with clients and in any other professional commitment.
• Have full knowledge of the operation and personnel that make up client-companies to avoid conflicts of interest.
• Report any situation (however distant and mild it may seem) that puts at risk the interests of any of the parties involved in the business relationship.
• Given the characteristics of the services we perform, it will be necessary for the worker to make correct use of the access credentials granted by clients for entry to their facilities. The worker will be responsible for taking care of the access credential, observing all caution to avoid its loss and, in case of loss, must pay any amount that results for its replacement. Upon completion of the work entrusted and the assignment, the worker must return the access credential to the client's offices.

D) Environment

At KAIRÓS GROUP, we understand that the protection of the environment is not only a legal obligation, but a strategic pillar of our corporate identity. Our commitment is articulated through the following action axes:

1. Regulatory Compliance and Prevention

We develop our activity under strict respect for the environment, exceeding mere observance of current legislation.

• Respect and Current Legality: We develop all our operations under strict respect for the environment. We formally commit to comply with the standards and requirements established in the applicable legal regulations, ensuring that our activity always remains within the current regulatory frameworks regarding environmental matters.
• Commitment to Sustainable Development: We understand sustainability as an axis of continuous improvement. For this, we promote an internal awareness policy aimed at all members of the organization being able to generally identify the environmental effects derived from our activity. The ultimate goal is to foster a responsibility culture that seeks, progressively, to minimize the global impact of our operations.
• Integration of Environmental Awareness: The assumption of these principles is not exclusively limited to the work environment of KAIRÓS GROUP. We aspire that respect for the environment be a transversal value that our professionals integrate and apply also in their daily life, promoting responsible habits that transcend the strictly professional sphere.

E) Occupational Health and Safety

KAIRÓS GROUP will provide and evaluate the employee in Occupational Health and Safety policy based on current legislation in each case, with risk assessment and basic implementation course, based on strict compliance with all regulations, training and preventive management of occupational risks. This implemented policy will take precedence over this Code, and this serving subsidiarily in case that one does not specify any case.

• Commitment to provide our employees with the necessary resources so they can perform their functions safely and in a healthy environment.
• Employee commitment to observe rigorous compliance with health and safety at work standards and to make responsible use of the equipment assigned to them, ensuring their own safety and, in general, that of all people who could be affected by their activities.
• Ensure the application, both by suppliers and subcontractors with whom the Company operates, of strict compliance with all legal regulations applicable to them regarding occupational health and safety and environmental protection.

F) Worker's Commitment to KAIRÓS GROUP

• Protect the company's prestige and client relationships in any statement, speech, presentation or publicly disseminated analysis.
• Treat colleagues and the client with courtesy and tact.
• Respect the workplace assigned to their person and their colleagues, taking care of order and cleanliness.
• The worker may receive receipts of their payroll, via institutional email, assuming from this moment the obligation to print the file, sign it and deliver it to the administrative personnel that, for this purpose, the Labor department designates.
• In case of absence from the workplace, due to illness, you must notify your superior immediately and deliver the temporary certificate of temporary disability, issued by a Collegiate physician of the specialty, to the Labor department.

G) Commitment to Assigned Tasks

• Honestly express doubts about the work being developed.
• Promise only what can be fulfilled.
• Ensure that the work is focused on the needs reported by the client.
• Try to go beyond the objectives set in the assignment, without putting it at risk.
• Estimate the real times that are necessary to invest to perform the work.
• Perform their activities with the highest possible quality, care and expertise, meeting the quality requirements requested by KAIRÓS GROUP for the development of each project.

H) Presentations and Congresses

• When addressing audiences that reasonably expect one to speak as a KAIRÓS GROUP worker, one must express one's own expression, according to one's honest knowledge and understanding, in line with KAIRÓS GROUP's own opinion, always respecting each worker's freedom of expression.
• Protect KAIRÓS GROUP's prestige and client relationships in any statement, speech or publicly disseminated analysis.
• Not publicly issue judgments against our competition or against KAIRÓS GROUP.
• Not speak or publicly issue opinions on behalf of KAIRÓS GROUP, except in cases of express authorization.
• Not expose topics outside those of our organization (political, religious, etc.).

I) Sexual Harassment and Disapproved Conduct

KAIRÓS GROUP will not tolerate harassment in the workplace, in any of its forms. Workers who violate this policy and protocols will have their employment contract terminated, based on the Law and the Equality Plan of KAIRÓS GROUP and the harassment, sexual harassment and LGTBIQ+ harassment protocol plans, which govern prescriptively before the current Code, which will be general and subsidiary in nature.

Likewise, the following conduct is prohibited, in an illustrative but not limiting manner:

• Mockery, insults, caricatures or any type of aggression related to sexual topics related to sexual orientation.
• Requests for sexual favors in exchange for preferential treatment, specific actions, or as employment conditions.
• Insinuations, sexual propositions, obscene, hostile, humiliating or offensive gestures.
• Body approaches, rubbing, touching and any other conduct of a sexual nature, offensive and unwanted.
• Offensive or hostile treatment for not acceding to the described conduct.

J) Prevention of Money Laundering and Terrorism Financing, Corruption, Bribery and Influence Peddling

KAIRÓS GROUP declares itself opposed to influencing the will of people internal or external to the company to obtain some benefit through the use of non-ethical practices. Nor will it allow other people or entities to use such practices with its staff. KAIRÓS GROUP personnel may not accept or offer, either directly or indirectly, gifts, donations, remuneration, promises or compensation of any kind that are intended to improperly influence or be influenced in their commercial, professional or administrative relationships, both with public and private, national or international entities.

Likewise, the Company's workers may not, personally or through an intermediary, promise, offer, grant or request or accept from any person, whether internal or external to the company, or a public or private entity, an unjustified benefit or advantage so that they favor him/her or a third party over others, breaching their obligations in the acquisition or sale of goods or in the contracting of professional services.

Only those gifts that do not influence business decisions will be permitted, such as promotional or low-value gifts, as well as those offered on specific dates, since they cannot be considered criminal conduct since their purpose responds to the maintenance of good commercial relations, to "customer care".

• Gifts may be accepted and offered when the conditions mentioned below are met:
• When gifts are of irrelevant or symbolic economic value whose economic value does not exceed 50 euros per year, 1000 Mexican pesos, or 200 Peruvian soles.
• When gifts respond only to usual commercial courtesies or are courtesy details.
• When they are invitations that do not exceed the limits considered reasonable in social uses.
• That the present is not in cash, transfers or checks.
• That the gifts are not prohibited by law or by commonly accepted commercial practices.

When any member of the staff and supplier of KAIRÓS GROUP finds themselves in the situation of accepting a gift that they should not, they will have to refuse it or return it, trying to avoid it being a serious offense to the offering entity or person. If they have doubts about what is acceptable or not, they must consult with their hierarchical superior who, in turn, will transmit it to the Legal Department. In the event that such return cannot be made, the gift will automatically become the property of the Company to subsequently allocate it to social purposes.

All gifts offered and received will be recorded for more exhaustive control. Staff must inform the Management of their corresponding Area of gifts made or received so that they can be registered. At KAIRÓS GROUP we will take special care when we evaluate a potential third party (consultancy, agents, etc.) that could interact with the Public Administration on behalf of the Company since, if an external contracted company commits bribery, KAIRÓS GROUP may be considered responsible.

KAIRÓS GROUP must always comply with anti-money laundering laws that govern in any competent jurisdiction. For this, the Company has its own policy for the prevention of money laundering and terrorism financing, which is superior in nature to this Code and will govern to its detriment, which will serve as a basis and subsidiarily in case that one does not contemplate it.

The Management and other personnel of KAIRÓS GROUP, as well as its suppliers or any subject with whom it has a relationship, must not carry out or be involved in activities that involve money laundering, that is, they must not acquire, possess, use, convert, or transmit goods, knowing that these have their origin in a criminal activity (committed by them or by a third party) or carry out any other act to hide or cover up their illicit origin, or to help the person who has participated to evade the legal consequences of their acts.

The Company establishes policies to prevent and avoid in the course of its operations, the making of irregular payments or money laundering originating from illicit or criminal activities. The aforementioned policies establish specific controls over those economic transactions, both collections and payments, of unusual nature or amount made in cash or with bearer checks, as well as all those payments made to entities with bank accounts opened in tax havens, identifying in all cases their ownership.

Similarly, both the Management and the staff of KAIRÓS GROUP must be vigilant during the fulfillment of their functions to detect and avoid money laundering, and in case they can detect any situation that may be related to such criminal conduct, they must report as soon as possible to their immediate superior or through the Complaint Channel contemplated in the policy for the prevention of money laundering and terrorism financing.

KAIRÓS GROUP staff members will review with special attention extraordinary payments not provided for in the corresponding agreements or contracts. KAIRÓS GROUP workers will remain alert to those cases in which there could be signs of lack of integrity of the people or entities with which the Company maintains relationships. Before establishing business relationships with third parties, they must verify the available information (including financial) about their potential business partners and suppliers, in order to ascertain their respectability and the legitimacy of their activities.

K) Advertising

Communication through advertising and marketing of KAIRÓS GROUP business units must be:

• Legal, decent, honest, truthful and in accordance with the principles of fair competition and good business practices.
• Prepared with a due sense of social responsibility and based on principles of honesty and good faith.
• Verifiable and free from elements that could induce an erroneous interpretation of the characteristics of the products and services that HE offers.
• Respectful of moral values, avoiding unethical circumstances that violate human integrity and dignity, or use culturally offensive symbols to a sex, race, religion, social class or political preference.

The information presented to the general public must be clear, precise and honest. We must therefore:

• Promote advertising that is consistent between the products and/or services offered. Not use advertising for unfair competition and discredit others without basis to disqualify competitors.
• Respect the right of consumers to be correctly informed about products and their contents.
• Carry out advertising adhering to the legal framework that contemplates consumer protection law and that is detailed truthfully, and that can be verifiable.
• Act with loyalty, transparency and good faith in commercial relationships with the competition.

L) Obligations to Public Administration

KAIRÓS GROUP will punctually comply with tax and social security responsibilities and obligations. In attention to this point, any fact of tax significance must be verified exhaustively and systematically in order not to defraud the State, Regional, Provincial or Local Public Treasury whether by action or omission (evading the payment of taxes, withheld amounts or that should have been withheld or advance payments, unduly obtaining refunds or enjoying tax benefits in the same way).

Likewise, for its respect for society and public institutions, KAIRÓS GROUP commits not to defraud Social Security (evading the payment of its contributions and joint collection concepts, unduly obtaining refunds thereof, unduly enjoying deductions for any concept, etc.) The Company commits not to falsify conditions to obtain the granting of subsidies or public aid. KAIRÓS GROUP will not request or obtain subsidies or aid that were not duly justified. KAIRÓS GROUP will request all collaborating companies to comply with the same responsibilities and obligations.

M) Use of Email and Internet

It should be noted that, the following provisions applicable to the use of institutional email, will also be applicable in case the worker is assigned an internal email account, by any client, so that, email accounts assigned by clients will be protected and the same provisions described below will apply.

The company supplies its employees with Internet, Intranet, email and instant messaging tools, and even and only at the full discretion of KAIRÓS GROUP, computer (laptop) or mobile phone. Therefore, only the account assigned by KAIRÓS GROUP is considered an Institutional Email account, so no technical support will be given to the worker for any other type of email accounts; the use of these will remain under the strictest responsibility of the user.

When the worker stops using their workstation they must close the client software or email program (Gmail) they use to read their email or, if applicable, the Internet browser used, to prevent another person from having access to their account information.

The only authorized email for the generation, transmission, reception and preservation of official KAIRÓS GROUP information is the Institutional Email.

Institutional Email accounts and passwords assigned to each user are personal and non-transferable. Once the account and corresponding password are assigned, the worker may use the Institutional Email. The confidentiality and use of the account and password will be the sole and exclusive responsibility of the user or worker.

• Information sent through electronic systems supplied by KAIRÓS GROUP must contemplate the following precepts that apply equally to messages and any attached document:
• Information sent through electronic communication systems must be related to the functions and responsibilities of the area to which the worker belongs, according to their responsibilities and authorization levels.
• Care must be taken when drafting and sending messages, whether internally or externally. All correspondence, both electronic and paper, is potentially susceptible to being revealed in litigation affecting the company; therefore, all workers of the company must avoid using comments or approaches that could cause harm to the legal position or reputation of KAIRÓS GROUP.
• Workers must not create, view, download, modify, send or forward, in any form or through any means of communication.
• Any inappropriate material, including: Obscene images, pornography or explicit sex, racist images or messages or other obscene or frivolous material.
• The production and distribution of illegal, defamatory or offensive messages, among others, including information that serves to defame, embarrass, threaten, harass, offend or harm employees, service providers, clients or any other person.
• All types of material that is unethical or malicious or that may violate any contract or law, such as information protection, copyright or intellectual property rights.
• Any type of privileged information that may generate damage to the company's reputation or may put it at a commercial disadvantage.
• Messages that initiate or continue "chain" or "pyramid" correspondence.
• Information or information systems protected by copyright, in violation of these rights, with the knowledge and/or consent of the worker.
• Content-type videos, music, graphics or executables for personal, entertainment or any other purpose not consistent with the functions assigned to the worker.
• The use of encryption devices not authorized by KAIRÓS GROUP.
• Any message that is received or transmitted and that due to its structure or content is considered spam, for example: emails with jokes, chains or information unrelated to the performance of the worker's duties.
• Likewise, the use of software not authorized by KAIRÓS GROUP is prohibited.
• The worker must not open attached data files that come from an unknown or dubious origin, which could damage the worker's equipment or information.
• Workers must not represent the company or share any type of company information in Internet discussion forums, social or professional networks, newsgroups or chat rooms unless expressly justified and authorized by the company.
• All business-related email of the company and/or the worker's functions and responsibilities must only be sent through the company's email systems, so private email systems should not be used for these purposes.
• On occasions, workers will need to send personal messages through the company-owned electronic communication systems, so limited personal use is permitted, provided that such use does not contravene the terms of this policy or other Company directives and also does not interfere with their work.

Email Reading

• Workers who have an assigned email account will be responsible for the timely attention of their emails; therefore it is recommended to: keep the email client software (Gmail) online, and activate the option to notify when a new message arrives, or connect to web email as frequently as possible to read their messages.
• Workers with an assigned account must periodically and permanently delete messages they consider unnecessary in any of the folders existing in their mailbox, thereby preventing saturation of their mailbox.
• Workers are responsible for any backup of the information they use, so they will use the email client system (Gmail) and it will be the tool they use to save that information.
• Upon receiving a message considered offensive, the received message must be forwarded to KAIRÓS GROUP technical support email, in order to follow up on this act and the respective actions can be taken.
• Workers must avoid receiving email when the sender is unknown since sometimes this can be a message with junk content or with viruses.

Email Misuse

• The worker must not, among other things: falsify email accounts, impersonate any other person, make false statements, in any other way falsify the identity of any person, or falsify message headers.
• Appropriate any email account(s) different from the one assigned to their person.
• Use institutional email to collect or redirect messages from another Internet provider.

Similarly, the internal policies of Grupo Kairós must be followed, in relation to all Information Security, Cybersecurity and Data Protection.

N) Evaluation and Displacement of Workers

KAIRÓS GROUP allows the displacement of workers so that they provide services outside the work center assigned in the employment contract, always under express authorization from KAIRÓS GROUP Management, HR Department or Legal Department, always based on the following foundations, and which will subsequently govern in a contractual annex signed with the worker, and which will take precedence over this subsidiary Code:

• From this moment the worker authorizes KAIRÓS GROUP, so that, derived from their employment contract, it may perform an analysis or evaluation of their performance, work, aptitudes and capabilities, periodically, according to the period of time that KAIRÓS GROUP considers necessary. The results of the referred evaluation may be used for the purposes of improving the performance of KAIRÓS GROUP workers, as well as probing the needs and/or deficiencies of the company's personnel and improving the services we provide to various clients.
• The worker will be receptive at all times, in order to improve their capabilities and knowledge, accepting and receiving the training that KAIRÓS GROUP determines as necessary for the better performance of their duties.
• KAIRÓS GROUP may propose to the worker it considers suitable, their transfer to any of the company's branches either inside or outside Spain, for training or the development of their work, with the understanding that any expense or expenditure necessary for the worker's displacement abroad will be covered by KAIRÓS GROUP, provided it is at the company's request. Likewise, KAIRÓS GROUP will be responsible for supporting the worker to obtain the immigration and legal documentation that is necessary for their stay in the receiving country.
• Similarly, there is the possibility of being able to work from another place in the world, provided there is a bilateral agreement or of analogous hierarchy with that country, in addition to approval from both the capacity Head, the HR Department, as well as the client. The worker must sign an agreement with the Company, which will govern the particularities of the same displacement.
• The worker may perform their functions both at their home and within the Client company's facilities, therefore, they authorize KAIRÓS GROUP, so that, according to their capabilities and aptitudes, it designates the facilities, the work and the client for whom they will provide their services at their own home, so that, the worker is obliged to abide at all times by the rules and other internal provisions that the Client establishes or considers necessary for the performance of their functions. However, they will report any anomaly or provision they consider, attempts against the provisions contained in this Code.

Ñ) Care of Work Materials

The worker is obliged at all times to care for and safeguard all work material that is supplied and belongs to KAIRÓS GROUP, with the understanding that, they will be responsible for its care and any deterioration caused by their carelessness or inexperience. Likewise, the worker is obliged to:

• The worker must at all times care for the work material provided by KAIRÓS GROUP, preventing any person outside the company from being able to access the company's information.
• Immediately report any failure or hacking in the system whether on the computer equipment or cell phone, so that KAIRÓS GROUP adopts the corresponding measures to safeguard confidential information, as well as any industrial secret or work developed by KAIRÓS GROUP.
• In case of theft or loss, the worker must immediately report this fact to the corresponding authorities so that KAIRÓS GROUP can be legally protected against any contingency. Similarly, the worker must notify KAIRÓS GROUP, so that it is in a position to cancel access, establish electronic information protection mechanisms and other actions tending to prevent any damage to the company.
• In case of equipment and/or work materials, the worker is obliged to keep them in good condition, make good use of them, and in case of loss or damage without cause attributable to KAIRÓS GROUP, the worker must replace it.

O) Equal Opportunities, Non-Discrimination and Diversity

It constitutes a fundamental pillar and a basic principle of action at KAIRÓS GROUP the guarantee of providing the same opportunities to all people, both in the phases of access to the labor world and in development and professional promotion within the company. This commitment translates into constant vigilance to ensure, at all times, the total absence of discrimination situations.

We understand equality as an inalienable right, regardless of sex, sexual orientation, race, religion, origin, marital status, age or social condition of individuals. For us, talent has no labels and our corporate culture is responsible for protecting this environment of mutual respect.

To comply with these principles, the organization is governed by the Equality Plan, as well as the harassment prevention protocols, harassment protocol against the LGTBIQ+ community duly implemented for Spain, and their respective ones for Mexico and Peru. These tools are mandatory and serve as a roadmap to identify, manage and resolve any deficiency or conduct that could violate the dignity of people in the work environment.

Consequently, all professionals involved in hiring, selection or internal promotion processes have the mandate to act under strict objectivity criteria. Their decisions are based exclusively on technical and professional suitability, always maintaining an open attitude to diversity and seeking to identify the profiles that best fit the needs of the position, under an equity prism.

KAIRÓS GROUP's commitment to an inclusive environment is reinforced through our active collaboration with reference entities in the field of diversity. These alliances allow us to integrate different perspectives and enrich our human capital:

Collaboration with Specialized Associations: We work hand in hand with different associations and foundations, supporting their work and promoting the integration of groups with specific needs, demonstrating that diversity is a value that adds capabilities to our common project.

Likewise, we are part of the Diversity Foundation, reaffirming our commitment to labor inclusion and the management of diverse work environments as a driver of innovation and social progress.

Through these unions, KAIRÓS GROUP projects its will to be an agent of change, promoting a more just society where equal opportunities are a tangible and daily reality.

P) Protection of Human Rights and Respect for Others

In accordance with what is contained in the Universal Declaration of Human Rights (UDHR), KAIRÓS sustains and promotes these same facts, fundamental rights and freedoms that all people have by the mere fact of existing. Respecting them allows us to create the indispensable conditions for human beings to live with dignity in an environment of freedom, justice and peace.

Human rights are universal, indivisible and interdependent. They encompass rights and obligations inherent to all human beings that no one, and make no distinction of sex, nationality, place of residence, national or ethnic origin, religion, language, age, political party or social, cultural or economic condition.

For all this, KAIRÓS commits to its absolute compliance and integration in all aspects of its business core and to promote all the rights contained and emanating from it.

Harassment, abuse, intimidation, lack of respect and consideration or any type of physical or verbal aggression are unacceptable and will not be permitted or tolerated at work, and those workers with personnel under their charge in KAIRÓS GROUP organizational units, must promote and ensure, with the means at their disposal, that such situations do not occur.

All workers and, especially, those who perform management functions, will promote at all times, and at all professional levels, relationships based on respect for the dignity of others, participation, equity and reciprocal collaboration, promoting a respectful work environment in order to achieve a positive work climate.

Q) Professional Development

Information Policy

All employees will be informed and will accept the principles and criteria on which KAIRÓS GROUP bases its professional development, the effectiveness of its management and the strengthening of its commitment to the Company's purposes and objectives.

Commitment to Training

Each employee must attend to their own training, using all the means that KAIRÓS GROUP makes available to them, in a constant commitment to themselves and to the Company aimed at updating and increasing their training, in order to achieve their full professional development and the achievement of their personal objectives.

Work Professionalism

KAIRÓS GROUP employees will act in the exercise of those competencies attributed to them by reason of their positions, putting into practice criteria that lead to the greatest effectiveness, at the lowest possible cost, always following the guidelines that, according to their respective technical training, are, in each case, pertinent.

Professional Promotion

Internal promotion at KAIRÓS GROUP is based on principles of capacity, competence and professional merits. Decisions in this regard will be adopted according to clear, objective and transparent criteria. All employees will be informed of the tools for evaluating their performance and assessing their results, which in any case will be based on criteria of objectivity and transparency.

Work and Personal Life Balance

In order to develop the commitment to corporate social responsibility assumed by KAIRÓS GROUP, to improve the quality of life of employees and their families, workers will promote a work environment compatible with personal development, helping the people on their teams to balance in the best possible way the requirements of work with the needs of their personal and family life.

Direction of KAIRÓS GROUP Managers and Directors

The attribution of managerial competencies at all levels of our Organization also entails the assumption of the responsibilities derived from decision-making. The exercise of command will also be a training school, constant evaluation exercise, talent stimulus and channel for professional development of our employees, through the design of career plans and succession of managerial positions. KAIRÓS GROUP managers and supervisors are responsible for motivation and communication among the members of their teams, promoting for this a participatory management style in which communication is strengthened, delegation is practiced and initiative, teamwork, results orientation and collaboration with others are encouraged.

R) Non-Competition

• Workers must give priority to the exercise of their functions at KAIRÓS GROUP and may not provide professional services to other competing entities or companies, paid or unpaid, and whatever the relationship on which they are based, except express authorization from the HR Department.

S) Intellectual and Industrial Property Rights of KAIRÓS GROUP

• The right to use or exploit, industrially or commercially, any innovations or inventions produced, in the exercise of their work activity, by KAIRÓS GROUP employees, and which give rise to trademarks, patents, invention models, copyrights, industrial drawings and models, etc., will belong to KAIRÓS GROUP, who will protect them in the terms established by law.
• Workers will respect the intellectual property and the right of use that corresponds to KAIRÓS GROUP, in relation to courses, projects, programs and computer systems; equipment, manuals and videos; knowledge, processes, technology, know-how and, in general, other works and works developed or created at KAIRÓS GROUP, either as a consequence of their professional activity or that of third parties. Therefore, their use will be carried out in the exercise of professional activity therein and all material on which they are supported will be returned when required.
• They will not use the image, name or trademarks of KAIRÓS GROUP, except for the adequate development of their professional activity therein.

T) Code Approval and Validity

This Code of Ethics has been prepared by the Legal Department of KAIRÓS GROUP and endorsed by its Management Committee, on the day and date ut supra.