Code of ethics and legal compliance

COS can only maintain its long-standing reputation as a business and professional partner by conducting itself with fairness, ethics, and integrity in all its business activities.

COS is firmly committed to legal compliance and the prevention of criminal risks, promoting compliance measures and integrating a culture of compliance applicable to all COS employees and collaborators.

In 2018, COS developed a Criminal Risk Prevention Protocol with the following basic objectives:

• To prevent the commission of crimes

• To promote a genuine culture of business ethics

• To avoid or mitigate the criminal liability of the legal entity

• To deter those who intend to commit irregularities

To comply with the basic principles of the Criminal Risk Prevention Protocol and establish a foundation for a controlled environment and continuous improvement of compliance, COS has defined its Code of Conduct and Business Ethics and has implemented a Whistleblowing Channel.

Through its Code of Conduct and Business Ethics, COS outlines its corporate values ​​and behavioral guidelines, and identifies expressly prohibited conduct within the company related to:

• Conflict of interest

• Personal gain, corruption, and bribery

• Equality and non-discrimination

• Financial arrangements

• Conduct with clients

• Conduct with suppliers

• Conduct with external consultants

• Conduct with competitors

• Conduct with partners

• Confidentiality and information security

• Respect for human rights (United Nations Covenant)

• Environment and sustainability

• Occupational health and safety

This Code applies to all COS employees and collaborators and is communicated to them regularly.

Based on these principles, the Organization has established its Whistleblowing Channel, through which both employees and other stakeholders can report complaints, suggestions, and concerns related to irregularities within the Company.

Although the organization has established a whistleblowing channel, any individual may use the external information channel of the Independent Whistleblower Protection Authority (AAI) to report any action or omission covered by the Whistleblower Protection Act, either directly or after communicating through the corresponding internal channel. Public disclosure is also permitted, provided the conditions established in the Whistleblower Protection Act are met.

COS has appointed a Compliance Committee with sufficient authority to supervise and monitor the operation, effectiveness, and compliance of the Criminal Risk Prevention Model.

– Code of Ethics

– SII Policy