Code of Ethics

Introduction

At Quantik Group we act ethically and work with integrity, with honesty standing out as one of our core values.

For us, meeting our objectives means respecting national and international laws and regulations, as well as our organization's operating rules, above any financial result.

This code sets out the guidelines for how we must act in our daily work in order to honor these values.

It is important to read it carefully and to turn to it whenever necessary. We are all responsible for upholding it and ensuring compliance, as it applies equally to all Quantik staff (directors, managers, supervisors, and, in general, everyone in the organization), as well as to all third parties who carry out activities on behalf of the group's companies.

In this organization we expect our staff and all their representatives to live our organizational values in every aspect of our work, complying with our policies and with all applicable laws and regulations. We must never compromise those values, whether for personal gain, for the benefit of third parties, or for the supposed benefit of Quantik.

Our principles and values are far more important than any result on the balance sheet.

Rafael Staricco, CEO

1. Scope

By accepting a position, role, or representation at Quantik Group (“Quantik”, “the organization”, “the group”) for any of its affiliated companies (“Affiliates”), you will be considered a member of the organization, with each person responsible for their own conduct, including compliance with laws and regulations, as well as adherence to this Code of Ethics (the “Code”) and the policies and procedures of their respective areas.

This code is part of Quantik's set of measures aimed at preserving a good working environment based on respect, cordiality, collaboration, and mutual support among its members, avoiding any conduct that is harmful to the organization.

Failure to comply with the provisions of this document, as well as with Quantik's policies, may lead to disciplinary sanctions (potentially up to the immediate termination of the employment relationship or of any other type of contractual relationship).

This code does not constitute, and must not be interpreted as, part of a fixed-term employment contract or a guarantee that the employment relationship will be maintained.

Where a violation of the provisions of this code breaches any law in force in the various territories in which Quantik operates, it will give rise to the civil or criminal penalties against the person, their managers, and/or any member of the organization that the courts may determine.

In addition, no one will suffer any adverse consequence for raising an honest concern, and Quantik will not tolerate any form of retaliation or pressure against those who do so.

2. Ethics Committee

The Ethics Committee (the “Committee”) was created within the Management Committee in order to oversee matters related to this code.

For specific matters, the Committee may bring in other members of Quantik, as well as individuals, institutions, advisors, or others it considers relevant to support its work.

Its functions are:

• Advise the Board on improvements and/or changes to this code.
• Provide oversight and strategic direction to the compliance function.
• Act as an escalation point for Quantik members on any matter related to compliance with the Code.
• Advise the Board on all compliance issues and risks.
• Ensure that adequate procedures are in place to communicate the Code and other key compliance topics to staff, in order to maximize awareness and understanding.
• Address and decide on matters submitted for its consideration, defining and implementing the actions needed to ensure full compliance with all provisions set out in this code.

3. Ethical principles

All Quantik staff must behave according to the following principles:

• Share the organizational values: teamwork, passion for service, responsibility, positive attitude, continuous improvement, humility, and honesty.
• Respect their colleagues, clients, suppliers, and anyone else they interact with, fostering an inclusive environment, valuing diversity, and avoiding any form of discrimination or harassment.
• Align their actions with principles of loyalty and business ethics.
• Compete on the basis of the price and/or merit of our products and services, as well as our ability to provide them in an innovative and efficient way.
• Act responsibly with respect to the social and environmental impact of their actions. This includes promoting sustainable practices and contributing positively to the community, ensuring a fair balance among social, environmental, and economic aspects.
• Carry out their activities with integrity, truthfulness, impartiality, and discretion.
• Observe the rules applicable to their activity, making the effort to know them and contributing to maintaining a safe and healthy environment.
• Comply with due diligence procedures for the clients, suppliers, and partners they contract with, in accordance with this code.

4. Employee obligations

Legality

Organizational objectives may only be achieved through activities that comply with applicable laws and regulations as well as with Quantik's policies, protocols, and rules. Accordingly, Quantik members must refrain from:

• Carrying out in-person and/or virtual activities (inside or outside the workplace) that affect Quantik's reputation.
• Using Quantik's resources for exclusively personal purposes.
• Engaging in activities that would breach the legal framework of any territory.
• Preparing, processing, keeping, or handling in any way information of Quantik or the Affiliates, whether commercial, employment-related, economic, financial, or of any other nature, that is not accurate, truthful, adequate, and up to date.
• Carrying out unlawful movements of funds under the national legislation of each country where activities are conducted.
• Conducting transactions with individuals or entities identified as unlawful by the bodies responsible for law enforcement in each territory of operation, or by foreign governments or competent bodies, provided this does not conflict with applicable law and does not stem from arbitrary decisions by those governments or bodies that lack recognition from the competent authorities, their agencies, or the corresponding parliamentary ratification.
• Conducting transactions with persons about whom there are well-founded doubts regarding the origin of their funds and the legality of their activities. Quantik members must strictly comply with policies and procedures on the prevention of money laundering and the financing of terrorism.
• Conducting transactions with individuals or entities that carry out activities prohibited by laws and regulations, without the required licenses, permits, or authorizations, or that undermine the credibility or interests of Quantik.

5. Political contributions and activities

Quantik does not support political parties or figures. Members and their agents must not make direct or indirect contributions on behalf of the group or its Affiliates to political parties, organizations, or individuals involved in politics. Quantik members are free to take part in democratic political activities, but this must be done on their own time, with their own money, without reference to their relationship with Quantik or its Affiliates, outside the scope of the organization, and without directly or indirectly affecting the relationships the group maintains with all members of society.

6. Charitable donations

Quantik members must refrain from making donations, charitable activities, or social responsibility actions in the name and on behalf of the company for initiatives that have not been previously promoted and/or endorsed by the organization and communicated through formal channels.

7. Protection of information

The following information must be kept confidential by all staff and protected even after the employment or contractual relationship with any of the Affiliates has ended, without prejudice to the provisions of RRH024 Confidentiality Agreement:

• Client information: Client information must never be used, except for purposes related to Quantik's activities, and its confidentiality and security must be safeguarded.
• Staff information: All information held about current and former staff of Quantik and its Affiliates must be kept confidential and secure. All personal information collected by the organization regarding employees (for example, and without limitation: salary, financial information, performance evaluations, etc.) or contractors is restricted to authorized persons. It may only be disclosed to third parties with the consent of the employee or contractor, except where the organization is required to do so by applicable law.
• Supplier or partner information: All information held about the purchase of products or services by Quantik and its Affiliates, or about their commercial agreements, must be kept confidential and secure. Sharing information with the wrong source could give the supplier or its competitors an undue advantage and breach agreements the group has with suppliers or partners.
• Third-party intellectual property: The intellectual property rights of third parties must be respected. Staff must not obtain or use third-party intellectual property through means that breach confidentiality obligations or by any other improper means. The use, sale, or any other distribution of intellectual property that infringes license agreements or related laws is prohibited.

8. Money laundering and financing of terrorism

In the course of its activities and operations, Quantik commits as an organization to rejecting any activity related to money laundering and the financing of terrorism. All members of the group must act with integrity and comply with local laws and regulations. It is essential to maintain constant vigilance over transactions and business relationships, ensuring that the group's services are not used for unlawful purposes.

Any indication of suspicious activity must be reported immediately to the Ethics Committee. Failure to comply with these provisions can not only have legal consequences but also puts the reputation and sustainability of the organization at risk.

9. Bribery and corruption

Quantik commits to conducting all of its business in accordance with the anti-corruption regulations applicable in each territory, refraining from any unlawful action or action prohibited by applicable laws and regulations.

Quantik prohibits its members, representatives, or agents from engaging in any form of bribery or corruption, whether before public or private bodies.

10. Gifts, hospitality, and entertainment

Reasonable gifts or entertainment, as part of normal business courtesy and relationship building, are generally acceptable for Quantik staff. However, any form of gift or entertainment, regardless of its value, can be a problem if it causes, even unintentionally, the receiving party to be improperly influenced. Staff must not give or accept any gift or entertainment that is intended, or could be perceived as intended, to influence the outcome of a decision or action that the employee may or must take. As for everything related to gifts, benefits, promotions, etc. that are not, or may not be, covered by the previous paragraphs and that result from purchases generated by the organization, these will be handed over to Human Resources, which will be responsible for deciding the best use for the benefit of Quantik and its Affiliates.

11. Conflicts of interest

Persons covered by this code will avoid placing themselves in situations that could mean a conflict between their personal interests, or those of persons or entities closely linked to them, and those of Quantik.

Accordingly, they must identify and report any situation that, in the performance of their duties, could affect their professional objectivity or involve a conflict between their personal interests and those of the organization.

In order to prevent conflict situations, these persons must refrain from approving, granting, participating in, or exerting influence to have approved any operations, services, or business between Quantik and clients or suppliers to which they are linked, and from taking part in transactions in which their personal interests could clash with the interests of the group. They may not maintain personal commercial relationships, on a habitual basis, with Quantik's clients or suppliers.

Likewise, before accepting or engaging in any personal commercial activity with clients or suppliers, they must notify their superior and the Committee in writing, as a mandatory step and sufficiently in advance.

Regarding family ties within Quantik and its Affiliates, the coexistence of staff whose direct or indirect family relationship does not generate conflicts of interest will be accepted.

A conflict of interest is any situation or position in which personal interests may harm, or appear to harm, the interests of the organization, or affect the objective and independent judgment or the ability of the employee to make impartial decisions for the benefit of the company.

Conflicts of interest can arise when our personal activities and interests clash with our responsibilities at Quantik.

Examples of situations that may create a conflict:

• Holding a job, business, academic or nonprofit activity, or an investment that could interfere with the ability to meet obligations toward the organization.
• Family members with financial interests in an external company (supplier, client, etc.) that does business, or intends to do business, with Quantik, or that is a competitor of the group.
• Taking part in certain management committees, media, panels, or other professional associations that may have interests conflicting with those of Quantik.
• Taking part in the hiring process of any person with a close relationship or for a direct-report position.
• Using confidential, sensitive, or material information related to Quantik (obtained in the course of the employment relationship) for personal financial gain.

During the selection process, whether internal or external, the person must declare that they do not have a direct or indirect family relationship that creates a conflict of interest. Any underlying conflict of interest must be reported immediately by the employee to Human Resources so that the situation can be assessed.

12. Communication, reporting, and investigation channels

Staff may use the following mailbox to raise any kind of concern and/or report: etica@quantikgroup.com

This communication may be made upon becoming aware of any breach of laws and regulations, of the provisions of this code, of situations that harm rights (workplace or sexual harassment or mistreatment), or of any circumstance that alters or disturbs the good working environment.

Reports will be handled confidentially and anonymously, with the corresponding investigations carried out according to the nature of the facts involved. Quantik will not tolerate any form of internal retaliation or pressure against such staff. Doing so is a very serious disciplinary offense that could result in dismissal for gross misconduct. Any allegation of internal retaliation will be thoroughly investigated.

13. Sanctions

Failure to comply with the provisions set out in this code is subject to the application of internal sanctions within the organization, in accordance with the “RG020 - Internal Sanctions Regulations” or the applicable internal rules (including dismissal, removal, termination of the relationship, or removal from the position), without prejudice to any civil or criminal sanctions that may apply under the laws of each territory and/or other applicable regulations.

14. Effective date, review, and updates

This code takes effect as of August 1, 2023.

Everyone covered by this code will receive a copy as evidence of their awareness and acceptance.

The Ethics Committee will review the Code at least annually, or whenever significant regulatory changes or changes in the organization's activity occur, and will submit it to the Board for evaluation and approval. The revised version will be returned to the Committee for communication to everyone covered.

15. References

• Policy on respect for the person and their diversity
• Occupational Health and Safety Policy
• RG020 - Internal Sanctions Regulations
• Employment and confidentiality contract