Corruption prevention.

Scope and
applicability

A company's competitive strength in the market depends largely on the integrity and legitimate conduct of the directors and staff of Metaminds S.A. (“Metaminds” or the “Company”) in carrying out its business. Acting with integrity and legitimacy is the main element in maintaining the trust of clients and business partners, protecting Metaminds' reputation and thereby contributing to long-term business success.

The essential conditions of integrity and legitimate conduct are to avoid any situation of corruption, and also any situation in which business interests could conflict with personal interests in the course of professional activity.

Corruption covers a set of illicit, unethical activities or actions carried out not only by individuals but also by various groups and organisations, public or private, in order to obtain material or moral advantages or a higher social status through forms of abuse, coercion, blackmail, deception, bribery, intimidation, threats and the like. A conflict of interest is one of the many forms that corruption can take. Personal interests must never be the reason for a business decision, and business decisions must never be taken in order to achieve personal gain.

Corruption means the abuse of power, often for personal gain. It includes conflicts of interest, embezzlement of funds, bribery, illegal payments, extortion, fraud, nepotism or favouritism.

A related subject is facilitation payments. These are bribes, often small, paid to public officials to speed up non-discretionary bureaucratic processes and to access services to which the payer is legally entitled.

Corruption undermines legitimate commercial activity, distorts competition, ruins reputations, damages brands and exposes companies and individuals to risk.

Bribery means an attempt to influence the exercise of someone's duties by providing, offering or promising an undue benefit, or accepting a promise of, or soliciting, an undue benefit.

We are committed to conducting business to a high standard of integrity and we do not tolerate any form of bribery or corruption. Accordingly:

• We avoid situations that may give the appearance of bribery, corruption or other inappropriate conduct.
• We do not solicit, accept, pay or offer to pay bribes, whether directly or through external parties acting on our behalf. Through the agreements we conclude with external parties, they undertake to observe the same anti-corruption and anti-bribery rules and procedures that apply to Metaminds S.A.
• We do not make facilitation payments, and we do not allow external parties acting on our behalf to make them, even where such payments are permitted by law.

Principles

• We do not bribe anyone for any reason. All professionals — in business and in government — are expected to perform their duties objectively.
• We do not accept anything of value that could affect our objectivity in doing our job.
• The Company's reports and records must accurately reflect all transactions, including expenses incurred in connection with gifts, entertainment, contributions and association membership, and payments to third parties engaged to interact on our behalf with government officials.

Why it matters for Metaminds

Bribery is completely against the most fundamental business standards of Metaminds S.A. It is contrary to economic growth, human rights and free markets, it dilutes public trust in business and government, and it is considered a criminal offence in every country in the world.

The reputation of a company that engages in corrupt practices is always negatively affected.

Who must comply with these principles and practices

This Policy applies to all Metaminds employees in management or execution roles (the “Employees”), to internal agents and collaborators, and to all clients and business partners, who will be made aware of it.

The rules set out in this Policy are intended to protect both the Company and its Employees from potential legal risks. It is therefore important that every Employee observes this Policy; any breach will be sanctioned in accordance with the applicable law and the Company's internal policies.

Mandatory practices

• Never solicit, accept, pay, offer or authorise a bribe, whether directly or indirectly, under any circumstances. Never attempt to improperly influence or bribe a public official, including foreign public officials, or any other person or entity.
• Do not offer or make facilitation payments, and do not allow others to offer or make such payments on your behalf.
• Ensure that you engage intermediaries only for legitimate business reasons; that fees paid to intermediaries are reasonable in relation to the services actually performed; that payments to intermediaries are properly recorded; and that supporting documentation is kept as required.
• Do not use charitable donations or sponsorships to circumvent our Code of Conduct or our anti-corruption policy.
• Never attempt to influence a public official in the exercise of their duties by offering, promising, providing or authorising undue benefits. This applies whether the advantage is offered directly or through another person.

Avoiding conflicts
of interest

The purpose of every business is to increase its value on the basis of durable and profitable business relationships with clients and business partners. Employees understand and accept that, in order to maintain a profitable and lasting business relationship, they must act with integrity and legitimately in the course of their professional activity and orient their professional conduct exclusively towards the general good of the Company.

In this respect, the first priority is to prevent conflicts of interest arising in all situations where they can be prevented. A conflict of interest is a situation in which the Employees' personal interests and professional interests overlap and may come into conflict, jeopardising the ability to achieve the common goal mentioned above. All Employees are therefore required to keep their personal interests separate from the interests of the Company.

However, if a conflict of interest cannot be avoided, the Employee is obliged, in their own interest, to act as follows, regardless of the form of conflict of interest involved (as set out below in this Policy):

• Notify their line manager and the Company's management (the members of the Management Board / Supervisory Board);
• Document in writing the existence of any conflict of interest; and
• Act in accordance with the legal requirements and the Company's decisions.

The Company's management will analyse and assess each case individually and respond to the Employee, stating whether the Employee is required to resolve the situation that led to the conflict of interest, or whether they will have other obligations in their employment relationship with Metaminds (for example, not to take part in any way in dealings between the company where the Employee works and the company in which they have personal interests).

Conflicts from
secondary activities

A secondary activity is any activity in which Employees work for third parties, whether individuals or legal entities, in addition to their main occupation within the Company, regardless of (a) whether they are paid for their work (as employees under an employment contract, as authorised individuals, or under any other type of contract) and/or (b) whether they hold the status of partner or shareholder/associate of that company.

3.1 Conflict of interest from competing secondary activity

A competing secondary activity is any personal commercial activity, or participation in a company, that competes with the Company's activities. If there is even a suspicion that a conflict of interest could harm the Company's reputation and interests, Employees are prohibited from, directly or indirectly, taking part in or obtaining any kind of benefit from, or being associated with as a partner, shareholder, director or employee in any form, or obtaining or taking part in a business activity of any kind that is in competition with the Company and/or with any other individual or legal entity that cooperates with the Company in any form (suppliers, clients, etc.).

Likewise, if such a competing activity is carried out by the Employee's spouse or a relative or relative-by-marriage up to the third degree, the Employee must report this situation to their line manager and the Company's management.

3.2 Conflict of interest from non-competing secondary activity

Employees of the Company are obliged to inform management about any future non-competing secondary activities, so as to avoid a potential conflict of interest. Voluntary, unpaid secondary activity carried out by the Employee in their free time is permitted, with no obligation to report it.

3.3 Conflict of interest from political activity

The Company respects its Employees' wish to take part in social or political activities. However, an Employee who takes part in such activities must do so outside working hours, and must not associate, or allow the association of, the Company's name with such political or social activity without the Company's prior written consent. In accordance with the provisions of existing legislation, this section does not include participation in trade-union activities.

3.4 Conflict of interest from private financial investments

Employees' private transactions, especially financial ones, must not run counter to the interests of Metaminds. Specifically, Employees may not be shareholders or associates, may not sit on the Boards of Directors / Management Boards of joint-stock companies (S.A.), and may not be Administrators within limited-liability companies (S.R.L.), without the Company's prior written consent. A refusal to grant such approval must be justified.

3.5 Individual conflicts of interest

The following provisions detail the rules of the Company's Code of Conduct concerning the integrity of Employees. Avoiding conflicts of interest and reducing corruption are basic principles for creating an economic framework for business growth, by creating a stable business environment. Corruption can take various forms (bribery, trading in influence, abuse of office, conflict of interest, etc.) and involves costs to the Company and Employees that cannot be measured. For this reason, Employees must also observe the rules below in the exercise of their duties.

(A) Accepting and granting benefits

The business decisions and activities carried out by Metaminds' Employees must be oriented exclusively towards the interest and good of the Company. Accepting and granting benefits, in connection with business activity, is subject to substantial restrictions in both the public and the private sector.

A benefit refers to any consideration to which the recipient is not entitled and which objectively contributes, or may be perceived as being likely to contribute, to the improvement of their financial, legal or personal situation. The term “benefit” must be understood broadly, including but not limited to business meals, the funding of travel expenses, holiday invitations, promotional materials, goods, monetary gifts, discounts, free products/services, rewards, special privileges, the granting of disproportionately large remuneration (for example, for personal and secondary activities), and so on.

If the anti-corruption legislation is breached, the Company, its Employees and its business partners may face civil, criminal and administrative sanctions, and the Company's reputation may suffer. Regardless of the above, it is not in Metaminds' interest to influence the business decisions or professional conduct of third parties by offering benefits to obtain favours for the Company. Metaminds attaches great importance to attracting business partners solely through its quality products and services.

With regard to legal risks, any appearance of unfair influence, or of the capacity to be influenced, in taking business decisions or business actions in connection with granting or receiving benefits must be avoided. The granting and acceptance of benefits must comply with the legal provisions and be thoroughly documented as to the date, occasion, value, provider and recipient of that benefit. The granting and receiving of benefits in secret is not permitted.

Accepting and granting benefits is subject to rules intended to protect the Company against ethical breaches and any other non-compliance that would cause reputational, commercial or financial harm or attract legal sanctions, reducing the organisation's prestige and profitability in both the short and the long term.

Regardless of the nature and value of the benefit, the following are prohibited:

a. As regards receiving benefits

• Employees must never request any benefit from a business partner in connection with their duties within the Company, or give a business partner the impression that a benefit is expected;
• Benefits must not be accepted if they are sent by a business partner to an Employee's personal address. Such benefits must be returned without delay, and the situation must be brought to the attention of the direct manager;
• Benefits must not be accepted where the Employee knows or anticipates that, by offering or promising a benefit, the business partner expects or hopes for preferential treatment in taking a business decision;
• Benefits must not be accepted if, from the impartial point of view of a third party, the nature, value and timing of the benefit offered or promised could raise suspicions about influencing a business decision or an official action.

In addition to the above, and given that no benefit will be accepted if it is promised or granted with the intention of taking a bribe, the following situations and conditions apply:

i) Hospitality invitations

It is permitted to accept invitations classed by the partner as socially acceptable (as defined below) — hospitality offered by a business partner in connection with a business activity or event that Employees attend in the Company's interest by virtue of their position, provided it is considered customary and appropriate to the occasion; official/business meetings, negotiations, receptions or social events that Employees attend in the Company's interest, and the like. Benefits are considered socially acceptable if they are offered out of courtesy and, provided they are analysed objectively, can be considered not to be intended to influence the recipient into granting preferential treatment to the one who offered the benefit, or if the benefit is granted without creating relationships of dependence.

ii) Invitations to activity-related events

Participation in activity-related events (presentations, briefings, discussions on professional topics, etc.) is permitted provided that:

• Participation is in the Company's interest; and
• The Company bears the cost of travel and accommodation; and
• Participation has been approved in advance by the Company's management.

iii) Invitations to other events with a personal-benefit component (e.g. cultural, sporting or entertainment events)

These are permitted provided that:

• Participation is in the Company's interest; and
• The Company bears the cost of travel and accommodation; and
• There is no material correlation with a specific business decision; and
• The value does not exceed €200 per calendar year; and
• Participation has been approved in advance by the Company's management.

iv) Funding of travel and accommodation expenses

This is permitted only where there is an existing legal basis, or for official courses and events to which the Employee themselves actively contributes in the Company's interest. Any exceptions to this rule require individual approval from the Company's management.

v) Material gifts

Benefits offered by business partners out of courtesy in the course of normal activity may be accepted — such as flowers, sweets, coffee, or CDs/DVDs — where refusing them could be considered impolite, for the same reason. Nevertheless, material gifts are permitted if they meet the following conditions:

• The value of the gift is below €200 per calendar year; and
• There is no material correlation with a specific business decision.

vi) Monetary gifts

Accepting money, value vouchers, shopping vouchers or other types of vouchers is not permitted.

vii) Approval by the Company's management

Wherever approval by the Company's management is required, it will be in writing and will set out the reasons underlying the decision to approve.

viii) Refusing/returning benefits

Where the approval requirements for accepting a benefit have not been met, the benefit will be refused or returned, together with a letter of refusal.

b. As regards granting benefits

Granting benefits must fall within appropriate business limits and comply with the following conditions:

• No type of benefit must be promised, offered or granted to business partners in connection with their role, regardless of whether they have previously requested benefits or given to understand that they expect benefits;
• Benefits will be sent to the address of the recipient's company (in the case of business partners);
• Benefits must not be offered, promised or granted to business partners with the purpose, expectation or hope of influencing a business decision in the Company's favour;
• Benefits must not be promised, offered or granted to a business partner in contravention of the business partner's own internal regulations/policies. In case of uncertainty, the Employee will consult their direct manager before extending an invitation. This applies in particular to granting benefits to public-sector employees;
• Benefits must not be offered, promised or granted to business partners if their nature, value and timing could be interpreted by an impartial third party as an illegitimate influence on the business decision.

In addition to the above, and given that no benefit will be accepted if it is promised or granted with the intention of giving a bribe, the following situations and conditions apply:

i) Granting benefits to members of the public sector

Given the risks associated under criminal law, invitations offered to members of the public sector are possible only within very narrow limits and must never be issued with the aim of influencing the guest in carrying out their activity. Only socially accepted invitations are permitted, provided they comply with hospitality standards and/or can be considered socially customary according to the type of event, the venue, the group of people invited or any other circumstances.

• Hospitality invitations for public-sector members — permitted provided they are courteous, proportionate and appropriate to the event, and do not exceed €50 per person / individual case.
• Inviting public-sector members to activity-related events — permitted provided they are courteous, proportionate and appropriate to the event, and do not exceed €50 per person / individual case.
• Inviting public-sector members to other events — permitted only if the public-sector representative was invited for reasons of representation and the written approval of their line manager has been obtained.
• Funding travel and accommodation expenses for public-sector members — such expenses may be borne by the Company only for lectures and discussions to which public-sector representatives are active contributors, and where the written approval of the guest's line manager has been obtained in advance.
• Material and monetary gifts for public-sector members — these must not be granted to members of the public sector. An exception is made for advertising materials and ordinary gifts that can be used in the workplace, with a maximum value of €35 per calendar year and where there is a justification for granting such a gift (a product stand, etc.). Monetary gifts are strictly prohibited.

ii) Granting benefits to business partners in the private sector

• Hospitality invitations for private-sector business partners — permitted provided they are considered customary, proportionate and appropriate to the event, and do not exceed €100 per person / individual case.
• Inviting private-sector business partners to events related to the Company's activity — permitted provided they are considered customary, proportionate and appropriate to the event, and do not exceed €100 per person / individual case.
• Inviting private-sector business partners to other events — permitted provided there is no material correlation with a specific business decision, and the value does not exceed €100 per person.
• Funding travel and accommodation expenses for private-sector business partners — in general, business partners must bear their own travel and accommodation expenses. Exceptions may be made where the Company is an active contributor to the event to which the invitation relates.
• Material and monetary gifts for private-sector business partners — material gifts may be granted provided their value does not exceed €200 per calendar year and there is an official justification for it. Monetary gifts are strictly prohibited.

In conclusion, benefits may be received/granted if these activities are carried out in an honest and transparent manner, their frequency does not create suspicions of conflicts of interest and does not amount to breaches of professional ethics, they have a reasonable value, and they are not the result of an expectation of influencing business decisions.

Employees are obliged to notify their direct manager immediately and without delay of any attempt at illegitimate influence over business decisions by business partners, through the promise or granting of illegitimate benefits.

(B) Donations and sponsorships

For the purpose of applying the law, the Company may support, by offering donations, projects in the fields of education, science, art and culture, as well as social, sporting and environmental campaigns. Donations include cash payments, benefits and services provided free of charge. No donation is offered to individuals or organisations that may harm the Company's reputation, whether or not such donations are lawful.

Donations to dignitaries and public officials are prohibited.

We do not sponsor or make direct or indirect donations to political parties or organisations, and we do not directly or indirectly support any political campaign.

All donations or sponsorships will be made exclusively by bank transfer and will be recorded in the accounting records of both the sponsor or donor and the organisation. Metaminds reserves the right to request the reimbursement of amounts that were the subject of a donation/sponsorship where it finds that the recipient of the money used the sponsored or donated amounts wrongly or improperly.

At the same time, Metaminds may be involved in sponsorships in areas related to the Company's interests, or in social-responsibility campaigns. Metaminds uses sponsorships as a corporate-communication tool. In addition to the support offered, sponsorship also involves achieving the Company's own promotional or advertising objectives on the basis of a contractual agreement. Unlike donations, to sponsor means to make a payment in exchange for obtaining a service. Sponsorship activities are permitted only where the sponsored partner or the event organiser (which must be an entity permitted by Romanian law) provides reasonable and verifiable corporate-communication and marketing services. Any sponsorship or donation must fully comply with applicable national legislation and international legislation (anti-bribery, anti-corruption, sponsorship, etc.).

(C) Anti-competitive arrangements

Employees must not enter into anti-competitive arrangements or abuse a dominant position in the market. Concrete action must be taken against breaches committed by participants or applicants in tenders, who must be excluded from the competition on the basis of serious breaches (for example, offering, promising or granting benefits with the aim of exerting unfair influence, or collaborating in restrictive arrangements).

(D) Money laundering

Money laundering is an act of disguising the source of criminal money or assets to make them appear to have come from a legitimate source. Metaminds S.A. conducts business only with reputable clients and business partners engaged in legitimate commercial activities, with funds obtained from legitimate sources. Metaminds S.A. notifies the relevant authorities of reasonable suspicions of money laundering, under the applicable legislation.

Money laundering usually involves irregularities in the transfer of money. You must be particularly cautious in cases of:

• Payments from or to someone who is not a party to the contract;
• Payments to or from offshore accounts, or accounts in countries outside our home markets;
• Requests to make payments to accounts other than those indicated in the relevant contracts and agreements;
• Requests for cash payments;
• Requests for overpayments;
• Requests to break payments down into individual batches.

Managing
third-party risks

Payments made to third parties in the knowledge that they will be used for acts of corruption may attract civil and criminal liability. As such, Metaminds manages its relationships with third parties taking into account the corruption risk associated with them.

For the purposes of this regulation, third parties are, without limitation, the following:

• Consultants — all individuals and/or legal entities (except in-house lawyers) that provide consultancy services to the Company for carrying out / implementing the Company's various projects;
• Suppliers;
• Intermediaries;
• Agents;
• Other third parties assimilated to the above categories.

Before establishing a relationship, the corruption risk associated with a third party must be assessed and a risk level assigned: low, medium or high. The purpose of the assessment is to obtain reasonable assurance that the third party does not make corrupt payments and that the business relationship is normal and legitimate. For long-term relationships, the assigned risk level must be periodically reconfirmed or amended by applying verification measures, and additional checks may be applied.

To minimise the risk of corruption and other conflicts of interest, special attention must be paid to selecting and monitoring the consultants involved in the Company's activities. When consultancy services are requested, the selection must be made on the basis of objective, transparent and justified criteria.

All relevant service contracts with third parties must include provisions on avoiding corruption. Thus:

• The subject matter of the contract will be precisely defined, both as regards the services and deliverables to be provided by the consultant and as regards the provisions on remuneration.
• For consultancy services, the rule is that remuneration provisions must be agreed on the basis of the time allocated. Lump-sum remuneration is considered only in exceptional cases, to limit costs.
• Success fees are inadmissible as a general rule. Any exceptions require the approval of the Company's management.
• Fees must include all direct and indirect costs (salaries, taxes, consumables, etc.). Exceptional expenses (accommodation and transport), where necessary and strictly related to the provision of the services, will be subject to the Company's prior approval and will be limited by contract to a maximum amount. The contract will provide for the Company's right not to approve certain expenses where there is a suspicion of fraud.
• Payments are made on the basis of quantitative and qualitative acceptance, after the services have been provided or after certain project phases have been completed, always on the basis of the deliverables provided.
• In the contract, the deliverables must be clearly identified, and the consultant must provide accurate information on the activities performed. The contract will include clauses on the qualitative and quantitative acceptance of the services and deliverables.

Where the third party to be selected indicates a high level of risk — in particular as regards possible links with public-sector persons, or a certain predisposition to corruption in the country/region and/or sector in question — additional contractual clauses must be agreed in order to reduce the corruption risk, as follows:

• An explicit declaration by the consultant that they will not misuse the remuneration received, in whole or in part, for the purpose of influencing public officials or the employees or agents of partner companies, and that the remuneration will not otherwise be used for any unlawful purposes;
• An express declaration that the consultant has no personal or business links with public officials as defined in the applicable criminal law;
• An obligation to fully reimburse the remuneration received in the event of their involvement in a corruption case;
• The Company's right to terminate the contract where there is a reasonable suspicion of corruption;
• The consultant's obligation to provide special information or grant access rights — including in respect of their subcontractors — where there is a reasonable suspicion of corruption;
• The Company reserves the right not to approve certain specific expenses incurred by the consultant, such as travel expenses or entertainment costs, or to treat certain expenses as inadmissible (for example, gifts for business partners).

All contracts concluded with third parties will contain the anti-corruption clause agreed by the Company.

Employment-related
risks

Activities related to human-resources management — such as offers of employment, internships or training activities — must observe the principles of transparency and anti-corruption; offering, or promising to offer, them in order to obtain or retain an undue advantage is considered an act of corruption.

Metaminds firmly condemns any human-resources activity that does not observe the highest ethical standards and the principles of objectivity, competence, professionalism and equal opportunity, whether or not it falls within the scope of the legal provisions on combating corruption.

Where any human-resources activity is requested, directly or indirectly, by a client, business partner or any third party known to have direct or indirect relationships with Metaminds, or is requested by a person holding an official position or a close associate of theirs, the request will be handled by reference to merit criteria and, where applicable, through the usual competitive process; it will be handled objectively, and it will be clearly documented that any decision taken was not based on the third party's request.

To avoid the risk of being perceived as an act of corruption, any human-resources practice — including, without limitation, offers of employment for a fixed or indefinite term, offers of paid or unpaid internships, offering training or promotion opportunities, promotions or transfers to other positions, and reviews of compensation packages — will be carried out exclusively on the basis of merit and, where applicable, a competitive process.

Responsibilities
and measures

One of the objectives of the anti-corruption programme is to establish and maintain a culture of compliance in which acts of corruption are never acceptable. To this end, Metaminds invests resources in training and raising awareness among Employees, by communicating this Policy.

To ensure, across the whole workforce, the appropriate level of attention and due importance given to the anti-corruption field — and thereby to maintain a culture of compliance in which acts of corruption are never acceptable — Metaminds' management and senior staff periodically emphasise and pursue initiatives intended to underline the importance of an anti-corruption culture. All these initiatives may be part of internal communication actions, including this Policy.

The Company's management must pay particular attention to delegations of authority and must bear in mind the following basic principles when delegating tasks:

• Appropriate choice of the level of responsibility, having regard to the underlying competencies;
• Control mechanisms will be taken into account during the selection and assignment of tasks, so that risks are diminished;
• Avoiding the transfer of duties and responsibilities to the lowest level of the hierarchy;
• Instructing those responsible in an unambiguous, clear and complete manner;
• Periodically monitoring the specialist knowledge and reliability of those responsible;
• Intervening in the event of fault by those responsible, by establishing the facts, investigating, and taking measures to eliminate the sources of problems in future.

Risk analysis — An important basis for an effective and efficient defence against corruption and other conflicts of interest is the systematic collection and analysis of the existing and investigated risks or, on the other hand, the detection of breaches of the applicable rules.

Control mechanisms:

• Business decisions must be transparent at every stage, including in the preparation phase of decision-making. Operations must always be accompanied by documents, which are described in the relevant processes and stored appropriately.
• During the planning of the relevant processes, appropriate measures must be incorporated to control the transaction. These measures must serve to protect Employees, and it must be clearly understood that they are taken to avoid any breach of the applicable law/procedures. In areas where there is an increased risk of corruption and other conflicts of interest, according to the results of the risk analysis, particularly strict control measures are required. The implementation of the control mechanisms must be documented in such a way that they can be verified.

Establishing the facts / procedural rules: where there is a concrete reason to suspect acts of corruption or other conflicts of interest, as defined in this Policy, the circumstances must be investigated and brought to the attention of the Company's management.

Reporting
concerns

Compliance policies, such as this one, express the mandatory principles and practices that the Company expects all employees to observe, so that we can keep our promise to do business ethically and lawfully.

It is therefore important that you report if you suspect a breach of this policy, or if someone has asked you, directly or indirectly, to breach it. Feedback is an essential part of our activity and is expected and always welcome. You have a responsibility to report suspicions or cases of improper conduct to your manager or their superior.

The Company takes seriously all good-faith reports of breaches of this policy, whoever is involved, and investigates all compliance allegations, observing the standards and guidelines established. The Company does not tolerate retaliation against employees who speak in good faith about an alleged breach of the conduct policies or who cooperate in an investigation.

A breach of this policy and of other policies may lead to disciplinary action against those involved, up to termination of employment. However, the main objective of an investigation is to understand what happened and, if necessary, to correct the situation and prevent its recurrence.

In order to detect any possible act of corruption, any conduct that could breach the legal provisions, or any breach of the principles set out in this Policy or other internal regulations, Metaminds relies on its own Employees, clients, partners and other third parties with which it has a business relationship, and encourages them to report immediately any suspicion or concern related to acts of corruption.

To this end, Metaminds provides several channels, which usually include:

Metaminds guarantees full confidentiality of the identity of the person making the notification, where this is permitted by the applicable law, as well as absolute protection against discrimination or actions directed against that person. The same level of attention is given to anonymous reports. Any action intended to unlawfully disclose the identity of the person who submitted the notification, or directed against that person, is considered a breach of this regulation and subject to disciplinary sanctions.

Metaminds investigates all acts of corruption mentioned in notifications, except where the information provided is insufficient to initiate an investigation, or where it is evident that the information received is false. All Employees are informed of the provisions of this Policy, which they adhere to from the moment it is communicated.

This Policy is supplemented by the provisions of the Metaminds S.A. Code of Conduct. Every Employee of Metaminds S.A. is obliged to observe the applicable legislation, the internal regulations, and the principles of conduct applicable within the Company.