Code of Ethics

This Code of Ethics governs the conduct of Emporia DMC employees and partners, ensuring a work environment based on integrity and responsibility. Its purpose is to set out the ethical and performance principles to which Emporia DMC, its employees and managers are committed in the performance of their duties. DMC, as well as its employees and managers in the development of their professional performance.

EMPORIA DMC understands, since its origins, that ethical business behavior is an essential requirement to guarantee and safeguard the balance between the rights of stakeholders and society in general, being indispensable to fulfill the company's objectives.

CORPORATE PRINCIPLES AND VALUES
Ethical behavior requires compliance with the legal rules and regulations applicable at all times, as well as with the internal rules and codes of conduct and good practices that EMPORIA DMC adopts voluntarily.
This commitment is summarized in the following Principles and Values:
• Quality: Commitment to excellence in every detail of our services.
• Sustainability: Promotion of responsible tourism that respects the environment and communities.
• Innovation: Constant search for new and better ways to serve our customers.
• Integrity: Transparency and honesty in all our interactions.
• Passion for Service: Absolute dedication to exceed our customers' expectations.
The business principles and values described above constitute the reference that should inspire the conduct of EMPORIA DMC's employees and managers, as well as any individual or legal entity that represents it. Ethical and responsible conduct must include the following aspects:
• To conduct business operations, as well as any other activity, in an honest, honest, professional and transparent manner.
• Comply and enforce compliance with the laws and regulations applicable at all times and places, as well as with the internal rules of conduct and any others that may be voluntarily adopted.
• Maintain due diligence for the prevention, detection and eradication of any irregular conduct.
ETHICAL AND RESPONSIBLE BEHAVIOR
The business principles and values described above constitute the reference that should inspire the conduct of EMPORIA DMC's employees and managers, as well as any individual or legal entity that represents it. Ethical and responsible conduct must include the following aspects:
• Conduct business operations, as well as any other activity, in an honest, upright, professional and transparent manner, professional and transparent manner.
• Comply and enforce compliance with the laws and regulations applicable at all times and places, as well as with the internal rules of conduct and any others that may be voluntarily adopted.
• Maintain due diligence for the prevention, detection and eradication of any irregular conduct.

EMPLOYEES AND MANAGERS:
EMPORIA DMC has as a principle and commitment to treat with dignity, respect, equality and fairness to all people who develop their activity in the company's environment and in its sphere of influence. That is why in its internal policy it designs labor relations and work systems to ensure non-discrimination for any reason, avoiding all situations that could lead to possible discriminatory acts.
EMPORIA DMC guarantees that:
• Working conditions are safe and healthy for all employees.
• The work environment is free from all forms of violence, harassment or abuse at work, with procedures for prevention, detection and resolution.
• Professional training and promotion of employees is developed.
• No forced labor is allowed and no child labor is used. For all these reasons, EMPORIA DMC requires from its employees and managers:
1. To protect and enhance the good image and corporate reputation of EMPORIA DMC, exercising its functions in a professional, ethical and responsible manner.
2. Comply and enforce compliance with the laws in force at all times, as well as this Code of Ethics and any other rules of conduct and behavior that EMPORIA DMC or assumes as its own.
3. Treat fellow students with dignity, respect, equality and fairness, without discrimination of any kind.
4. Promote a work environment free of all forms of violence, harassment or abuse.
5. Report through the established channels those situations potentially contrary to the principles and values of EMPORIA DMC.
6. To make good use of the material and technical means placed at their disposal.
7. To defend the interests of EMPORIA DMC in the performance of all its work activities.
8. Respect, protect and help to protect our own and others' intellectual and industrial property.
9. Exercise their activity in mental conditions not affected by the consumption of substances that hinder the good professional performance.
CUSTOMERS
EMPORIA DMC establishes as a fundamental pillar of its commercial policy to achieve maximum customer satisfaction and offer the highest level of service, specialization, quality and guarantee by offering products and services that optimize their purchase decision, according to their needs and interests.
Consequently, employees and managers will always act with responsibility, commitment and maximum respect, and their priority must be to achieve excellence in customer service, as well as in the quality and safety of the products and services offered.
SUPPLIERS AND BUSINESS PARTNERS
Relations with suppliers will be developed within a framework of transparent collaboration that allows and facilitates the achievement of mutual objectives, always in compliance with current legislation. EMPORIA DMC requires all its business partners, suppliers and operators in the supply chain to assume and comply with the ethical principles and responsible behavior contained in this Code, as applicable to them.
In order to establish mutually beneficial relationships with its suppliers and business partners, EMPORIA DMC, its employees and managers, are committed to:
1. To maintain maximum collaboration and loyalty, respecting and ensuring that the agreements reached are respected.
2. To collaborate exclusively with suppliers and business partners who respect human dignity and human rights, comply with the law and accept EMPORIA DMC's code of ethics and behavior, preventing EMPORIA DMC's reputation from being jeopardized.
3. Use quality criteria to select the products and services we offer, as well as the manufacturing and distribution conditions.
4. To develop the relationship between EMPORIA DMC's employees, its suppliers and its external collaborators within a framework of trust and mutual collaboration, in favor of transparency, efficiency, quality and cost, avoiding any favored treatment for personal reasons.
RELATIONS WITH PUBLIC ADMINISTRATIONS AND REGULATORY BODIES
EMPORIA DMC employees and officers shall relate and interact with public authorities and institutions in a lawful and respectful manner under principles of cooperation and transparency. No employee or officer of EMPORIA DMC shall make facilitation or expediting payments, in cash or other object of value, to any judicial body, public administration or official agency.
PUBLIC AND PRIVATE INSTITUTIONS, ORGANIZATIONS AND GUILDS
EMPORIA DMC participates in the organizations and/or institutions related to its activities, collaborating in the search for solutions that seek the common good of society in general. It respects all institutions and their representatives, maintaining the principle of political neutrality. It collaborates with Public Administrations and with non-governmental entities and organizations dedicated to improve the levels of social care of disadvantaged people and in situations of need.
CONFIDENTIALITY COMMITMENT AND DUTY OF SECRECY
EMPORIA DMC, its officers and employees undertake to maintain strict confidentiality and secrecy with regard to the information in their possession and to which they have access, whether financial, commercial and/or technological. They also undertake to maintain confidentiality and to protect the personal data they process about employees and managers, customers, suppliers and all those for whom special protection is legally required.
Likewise, managers and employees are committed to:
1. To take the utmost care to differentiate and not generate confusion between the expression of their opinions and personal criteria, with the transmission and dissemination of criteria, guidelines, instructions and/or company rules, which they communicate as a result of and as a consequence of the responsibility they hold according to the activity they carry out as managers and employees of EMPORIA DMC.
2. Refrain from offering in the media, social networks, opinion forums and any other information support, opinions, data, criteria for action, uses and/or internal procedures, which correspond to those of EMPORIA DMC or any of its allies, or give to understand that they come from them, their administrators, executives, area managers and/or employees, unless expressly and in writing they have been entrusted with the transmission of such information by authorized personnel for this purpose.
CONFLICTO DE INTERÉS
EMPORIA DMC managers and employees shall not engage in any behavior or activities that could give rise to a personal benefit (direct or indirect) or to any collision or conflict of interest (personal, family, other related parties, another employee, supplier or collaborating company), with those of EMPORIA DMC, and shall inform the Company through the established channel.
APPLICATION, ACCEPTANCE AND DISCLOSURE
This Code of Ethics applies to EMPORIA DMC and is binding on all its personnel and managers and may be extended to any natural and/or legal person directly or indirectly related to EMPORIA DMC, when it is appropriate for the fulfillment of its purpose and is possible due to the nature of the relationship.
EMPORIA DMC employees and managers must expressly accept and ratify the principles of action set forth in this Code. In order to ensure that all EMPORIA DMC's employees and stakeholders are aware of the contents of the Code of Ethics, it shall be made known through the relevant internal communication systems and dissemination channels. It shall be published on EMPORIA DMC Corporate Information website and shall be the subject of training, awareness and sensitization actions for its timely understanding and implementation throughout the Organization.
COMPLIANCE OFFICER
The Regulatory Compliance Officer (CCO) has among its competencies:
• Promote the dissemination, knowledge and compliance with the Code of Ethics.
• To develop the actions related to the same.
• Resolve any doubts that may arise regarding its interpretation.
• To prepare an annual report on the incidents that have been reported to it and on the opinions issued in relation to compliance with the Code of Ethics.
The intervention of the Compliance Officer, in the event of possible breaches of the Code, may be either on his/her own initiative or at the request of a party.
In these cases, the Regulatory Compliance Officer:
• It will examine, investigate and rule on known irregularities.
• It will guarantee the confidentiality of all known data and background information, as well as of the actions carried out. Confidentiality will be maintained over time, unless it has to be lifted due to requirements established by law or express judicial requirement.
BREACHES OF THE CODE OF ETHICS

Failure to comply with the provisions of this Code, as well as any other internal rules of EMPORIA DMC, may result in the application of the appropriate punitive measures, all in accordance with Colombian law and the RIT according to the Substantive Labor Code, and other applicable labor regulations.
REPORTING OBLIGATION AND WHISTLEBLOWER CHANNEL
EMPORIA DMC employees and officers have the obligation to report any irregularity in relation to compliance with this Code, as well as any circumstance in which a third party could induce him/herself or another EMPORIA DMC employee/officer to contravene the Code of Ethics.
EMPORIA DMC facilitates and manages the following communication channels to its employees and managers, as well as to third parties in general, regarding compliance with the Code of Ethics:
E-mail: rosaura@emporiadmc.com
Web: www.emporiadmc.com
• Corporate intranet
Main office address: Cll 32 8A-50 P14 Oficina 1405- Edf. Concasa, Centro Histórico. Cartagena de Indias, Colombia
This policy will be reviewed annually to ensure compliance and updating.
This commitment was signed on July 2, 2024.