The Code of Ethics and Corporate Good Governance is a guide to achieving the purpose of always being the best in our work. As a result, all employees and other members of the association who perform duties or tasks for S.P. INGENIEROS S.A.S. shall apply in all their actions and decisions the provisions of this Code. 

All persons who perform or carry out activities of those framed in the development of our object social, without prejudice to the rules enshrined in the national legal field, they shall assume and comply in a conscious and committed manner with the following ethical principles, values and guidelines. 

• In the development of our work: We are punctual, disciplined and committed. 
• In our relations with all third parties: Let us always give a fair and equitable treatment. 
• We respect and accept the differences, beliefs and ideals of others. 
• We manage in a respectful and transparent manner all contractual relations arising from the development of the social object of the organization. 
• We provide accurate, accurate, complete and timely information to all individuals and entities involved in the organization. 
• We do not use private information from the organization for own benefits. 
• We seek and maintain the best relations with the community, respecting the existing agreements and laws, based on the values and business principles that characterize us. 
• We are committed to meeting all our obligations, at the agreed times and with high quality standards. 

CORPORATIVE VALUE 

The values that guide the action of our employees and third parties that are linked to S.P. INGENIEROS S.A.S. are as follows: 

• Liability: We assume the consequences of our actions and fulfil our commitments and obligations. 
• Trust: As a company we fully comply with social, moral, legal agreements with our clients and the work team. 
• Honesty: We act with sincerity, under the limits of good customs, generating actions of common benefit being consistent with what we think and do. 
• Adaptability: We are in constant adaptation, ready for change, facing new challenges and learning that will enable us to stand out in the market. 

Excellence: We are a trained team that meets outstanding practices for achieving results based on: customer orientation, resource optimization, leadership and perseverance, processes and facts, continuous improvement and innovation, mutually beneficial partnerships and social responsibility. 

REGULATIONS OF CONDUCT OF GUIDELINES AND EMPLOYMENTS 

All managers and employees are required to comply with the laws, provisions and regulations issued by the authorities, as well as the policies established by the Company's Directorate.  

The interest of the Company and that of all the entities that are part of the group will always prevail over the particular interest of the persons connected to them, when in business related to the development of their object, the double quality of employee or manager and of particular interest may appear compromised. 

Compliance with the standards set out here is the responsibility of each and every employee. Each Director and Chief in their respective area shall ensure that they are duly known and respected.  

They cannot be held or carried out, directly or indirectly, either by themselves or by person, businesses which, in accordance with good commercial customs, can be described as antagonistic to the interests of the Business Group.  

Their employees and managers must always take care of the success of the group's activities and business, avoiding any conflict with their personal interests and rejecting any connection with individuals, companies or associations whose activities are equal to or similar to those of the Business Group.  

1.USOR OF THE CHARGE:  

No employee may use his or her position in the Company or the name of the Company to obtain for himself or for his or her spouse, partner or permanent partner or relatives up to the fourth degree of consanguinity, second degree of affinity and first degree of civil, special treatment in terms of loans and / or provision of goods or services by persons who commonly negotiate with companies that are part of the Business Group or who intend to negotiate with one of them. 

In the exercise of their duties, employees and managers shall give third parties fair, fair and equal treatment, so that their relations with the Business Group do not result in special treatment or benefit to each other or encourage the third party to feel obliged to have special considerations for a particular employee. 

No person who is working with the Company or its subordinates or associates may seek or obtain the benefit of himself, his relatives or third parties, of privileged or confidential information or of opportunities submitted to him for his employment. Nor may it participate in activities or businesses that are contrary to the law or good customs that affect its good name. 

A payment which, legally, legally or ethically, cannot be made by the Company, must not be made indirectly through a manager, employee, family member, agent, broker, consultant or any other person to whom the money is provided or the reimbursement of funds is made. 

The internal control system shall include procedures that will help to monitor compliance with these policies, with the obligation of all employees to disclose to the Internal Auditors and, if appropriate, to the Fiscal Review any facts that they know or discover related to the violation of these policies. 

2. USE OF COMPANY GOODS:  

The assets, services and, in general, the human and material resources of the Company must be used by its employees only for the purpose for which they were handed over to it, which means that any of the goods delivered for the performance of their duties in the S.P. are not used for the personal or third-party benefit of any of the goods delivered for the purpose of their work. Engineers 

3. EX- SERVICES NEGOTIVES:  

No contract, business or operation with exservers of the Business Group, whose withdrawal has resulted in an offensive conduct against any of its companies or partners, or against its policies or interests, or which, after its withdrawal, has been encouraged by them. 

4. NEGOTIES WITH OTHER THIRD PARTIES: 

Employees who manufacture or distribute products that use any of the companies of the Business Group or provide services that they hire within their ordinary course of business, must make this situation known to their immediate superior, in order for the latter to obtain a written statement from the Ethics Committee, in order to resolve conflicts of interest. 

The same procedure shall be observed by the employee, when it comes to holding business with companies where his or her spouse, partner or permanent partner or relatives up to the fourth degree of consanguinity, second degree of affinity and first degree of civil participation have economic, managerial or administrative participation and, when he or she intends to provide any kind of advice to a person other than his or her employer. 

5. ACCEPTATION OF ATTENTIONS:  

It is in the interest of the Company that any manager or employee should accept attention, in cash or in kind, such as gifts, invitations, commissions, travel, participation in business and any other offer involving a significant halage that may compromise or incline their conduct in favour of the person who makes them. 

In this regard, normal and common care can only be accepted within healthy commercial practices and the chief shall be aware of them.  

The employee must indicate to the supplier that he does not make any commitment to accept his attention or gift and that he will have to give it to the head of his respective area who will define whether or not to return. 

The employee must tell the supplier that he does not make any commitment to accept his attention or gift and that he will have to deliver it to the head of his area. 

6. INFORMATION SUPPORT TO COMPANY OR ITS EMPLOYED:  

No manager or employee may provide confidential data or information from the Business Group to persons other than those authorized, whether they come to their attention on the basis of their position or by any other means. It may also not use such information for the benefit of itself or of third parties. This includes the prohibition of informing suppliers of the contributions submitted by their competitors in business with companies of the Business Group. However, national laws may require the disclosure of financial or other information. In order to ensure that the Company is aware of such revelations, copies of documents which are issued or which are available to the public and have to do with such laws must be sent to the Legal Representative. In addition, the company concerned may determine which data, related to its operations, must be made known by its own will, even if they are not legally required. These data, if significant to the Company, should be sent in advance to the Legal Representative for review and to ensure consistency with other information, applicable laws and regulations.  

7. PROTECTION OF INFORMATION: 

Our business policy is to maintain a high level of security in computing, communications and telecommunications to conduct its risk-free activities and to take all necessary measures to ensure the confidentiality of information. (See information security policy in corporate intranet). 

This means adequately protecting all components of computer and telecommunications systems that are used, i.e. information, programmes and equipment. 

Plans are needed to ensure the continuity of critical business operations in the event of damage or failure affecting the systems referred to. 

The rules or procedures established to protect the resources shall be compatible with those described here and shall be observed by all employees. In addition to complying with these rules, they shall comply with the following: 

Be particularly jealous in the care and protection of documents that constitute the historical archive of the Organization, respect for the rules for the protection of external, internal or confidential correspondence. To ensure compliance with the legal rules on accounting and correspondence records. - Before using information stored on a computer, any manager or employee shall apply for permission to access it. The authorization shall be granted and maintained by the employee as long as he or she has a real need to know him or her to perform his or her duties. Employees shall protect from unauthorized loss, use or disclosure, information and computer programs under their responsibility. 

In all cases, follow the instructions of the Director and Chief of the Tics area. 

8. PROPERTY OF THE PROVENENT CAPACITATIONS MATERIAL: 

All books or memoirs resulting from a course or seminar attended by any employee of the Business Group, sent or sponsored by the Society or its subordinates, they will belong exclusively to it and what they learned there only may be used for the benefit of the Business Group, as it is part of the company's training programme.

9. INTELLECTUAL PROPERTY:  

Inventions, as well as improvements in the processes, procedures, tools, working methods and the results of the activities of the employee or manager that generate material or hardware improvements, shall be the exclusive property of the Company and the Company shall have the right to protect them as intellectual property in its name or in the name of third parties, for which the employee shall facilitate the timely fulfilment of the relevant formalities and shall access the subscription of the necessary powers and documents for that purpose in the form and time requested by the employer, without the employer being obliged to pay any compensation. 

Therefore, all improvements made by the employee, whether in the processes, in the formulations, in the work systems, in the products or in all the initiatives he provides as a result of his work or of the travel carried out on behalf of his employer, shall be owned by him and shall not be used by the employee for his own benefit or by third parties, or when he is working at the service of his employer, much less when he has withdrawn from the undertaking, the above, since the intellectual property of the results of his work shall belong exclusively to his employer or to the person who he indicates. 

10. CHARGER ACCEPTATION: 

All employees of the Business Group must obtain an approval from the Legal Representative of the Company for be able to accept positions as a member of the Board of Directors of any legal person, whether public or private, because their dedication will have to be exclusive to the activities for which they are engaged. 

11. POLICY CONTRIBUTIONS: 

Managers and employees shall be free to intervene in non-working hours in the political activities of their choice. Their participation, whether with money, time or property, must be a purely personal matter and in no way may it involve the Business Group. 

Employees and managers must refrain from any practice of internal political proselytism. 

12. ADDITIONAL CONDUCT REGULATIONS: 

Any management or employee of the Company shall be obliged to communicate to the immediate superiors and, where appropriate, to internal control and / or to the Public Review, any irregular act of another management, employee or third party, which affects or may harm the interests of the Business Group; and to refrain from: 

• To intervene in actions which allow, protect or facilitate the conduct of unlawful acts or which may be used in a manner contrary to the public interest or the interests of the Business Group. 
• To carry out activities which are competent with the Business Group. 
• To engage in conduct aimed at generating fear, intimidation, terror, anguish, causing work damage, dismotivation at work, inducing renunciation, ill-treatment at work, persecution, discrimination, obstacles and / or lack of protection at work with their subordinates and / or co-workers. 
• When partner relations between employees are present, they must be located in different areas and in no case be the Chief and subordinate, if they do not move to another area, one of them must resign. Unless the results and behaviour demonstrate effectiveness, efficiency and professionalism in their work, it is also approved by the Ethics and Conflict of Interest and Management Committee. 

SELECTION OF THE PROVEHERS OF BEDROOM OR COMPANY SERVICES.  

The selection of suppliers of goods and services of SP INGENIEROS will be done with the criterion of free competition, allowing and providing equal opportunities to all suppliers who want to participate in the required processes, and in turn always respecting the healthy customs of the market.  

The company will design a supplier selection process, which will work according to the amounts of each negotiation process, in compliance with the policies of prevention of active washing and financing of terrorism, but always focused on improving efficiency and seeking the profitability of the Company.  

S.P. INGENIEROS S.A.S, has a supplier registration process, in which all persons who intend to start business with the Company will be registered, in which basic information will be entered in accordance with the AIL-F-017 format.  

All information provided by suppliers must be updated each year or when there is a major change.  

The contract of suppliers in the company shall be guided by the following principles, which must be complied with and respected by all the suppliers that are linked:  

• Equality: The processes will be equipped with tools to establish clear, prior and objective selection criteria. All suppliers that meet the requirements of each selection process will be evaluated on an equal basis.  
•  Efficiency: The selection process will always be aimed at developing efficient processes that will allow the selection of the supplier that is most suited to the need of the company, the supplier with the best delivery time and effective after-sales service.  
•  Impartiality: The review of all tenders submitted in the various supplier selection processes is carried out taking into account only the content of the tenders and the compliance with the requirements of the solicitation documents or the invitation to quote. In view of the above, the contracts will be made without consideration to factors of closeness or affection with a given supplier. 
• Speed: The selection process of suppliers will be carried out within established times, avoiding unwarranted delays or delays 

ANNONIMAL DIFFERENCES POLICY 

S.P. INGENIEROS S.A.S. has developed a system to ensure transparency in the execution of all the processes of the company, providing complaints channels that ensure the timely and relevant reporting of situations contrary to the law, its social statutes and the adopted Code of Good Governance. 

Channels:

comitedeseguimientoetico@sp.com.co

oficialdecumplimiento@sp.com.co 

 S.P. INGENIEROS S.A.S., guarantees full confidentiality, discretion and timeliness in dealing with the complaint that is brought by one of the interest groups. The report is anonymous, and it is not necessary for the person submitting the complaint to provide personal data.