GENERAL MANAGEMENT CODE: GG-AUD-MNL-0002

Edition: 04
TRANSPARENCY AND BUSINESS ETHICS
Issue Date: 25-Sep-2023
PROGRAM (PTEE) HANDBOOK
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PREPARED BY: REVIEWED BY: APPROVED BY:

CHARGE: CHARGE: CHARGE:
PTEE Compliance Officer Legal Affairs Coordinator General Manager

TRANSPARENCY AND BUSINESS ETHICS PROGRAM (PTEE) COMPLIANCE MANUAL

 GENERAL MANAGEMENT CODE: GG-AUD-MNL-0002
Edition: 04
TRANSPARENCY AND BUSINESS ETHICS
Issue Date: 25-Sep-2023
PROGRAM (PTEE) HANDBOOK
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Table of Contents

1. OBJECTIVES ......................................................................................................................................... 3
2. SCOPE................................................................................................................................................... 3
3. PTEE COMPLIANCE POLICIES ............................................................................................................ 3
3.1. Policy for the Management and Prevention of Corruption and/or Transnational Bribery C/ST ............... 3
3.2. Due Diligence Policy .............................................................................................................................. 4
3.3. Compliance Audit Policy......................................................................................................................... 4
3.4. Procurement Due Diligence Policy ......................................................................................................... 4
3.5. Organization's Accounting Due Diligence Policy .................................................................................... 5
3.6. Policy for the Payment of Remuneration and Commissions to Contractors ........................................... 5
3.7. Policy on Gifts, Payments, Entertainment and Invitations Offered by Collaborators, Suppliers,
Contractors and Interested Parties ......................................................................................................... 5
3.8. Policy on Gifts, Payments, Entertainment, Invitations to Collaborators and Associates ......................... 6
3.9. Sponsorship Policy ................................................................................................................................. 6
3.10. Donation Policy ...................................................................................................................................... 7
3.11. Policy on Political Contributions ............................................................................................................. 7
3.12. Documentation Maintenance Policy ....................................................................................................... 8
3.13. Policy, Update and Modifications of the Transparency and Business Ethics Program - PTEE .............. 8
4. INTERNAL REPORT OF AN UNETHICAL EVENT................................................................................ 8
5. EXTERNAL REPORTING OF ALLEGATIONS OF TRANSNATIONAL BRIBERY ................................. 9
6. SANCTIONING REGIME ....................................................................................................................... 9
 GENERAL MANAGEMENT CODE: GG-AUD-MNL-0002
Edition: 04
TRANSPARENCY AND BUSINESS ETHICS
Issue Date: 25-Sep-2023
PROGRAM (PTEE) HANDBOOK
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1. OBJECTIVES

 Provide the policies and procedures that must be taken into account by the Company's employees, suppliers,
contractors and stakeholders, within the framework of the Transparency and Business Ethics Program.
 Comply with the provisions of Law 1778 of February 2, 2016, which dictates rules on the liability of legal entities
for acts of Corruption and/or Transnational Bribery C/ST and other provisions in the fight against corruption.
 Carry out the provisions of the Superintendence of Companies in External Circular 100-00003 of July 26, 2016,
addressed to legal entities for the implementation of business ethics programs within their organizations, as well
as the provisions of the regulations that complement and add to it.

2. SCOPE

The provisions of this Manual must be observed and complied with by employees, suppliers, contractors and
interested parties who have any type of relationship with Belleza Express S.A. or who are directly or indirectly linked
to the company.

3. PTEE COMPLIANCE POLICIES

3.1. Policy for the Management and Prevention of Corruption and/or Transnational Bribery C/ST

The Board of Directors and the Legal Representative of Belleza Express S.A. expressly declare their commitment to
the implementation of procedures that allow identifying, detecting, preventing and mitigating risks related to
Corruption and/or Transnational Bribery C/ST in relation to the operations of the Organization where a national or
foreign public official intervenes.
To comply with the above, they will carry out the following actions:
 Provide the economic, human and technological resources required by the Compliance Officer to carry out
his/her work.
 Implement procedures to identify, prevent and mitigate risks related to Transnational C/ST Corruption and/or
Bribery.
 Establish an anonymous channel for employees, contractors, or other third parties to report red flags or situations
related to C/ST
 Promote the anonymous whistleblowing channel of the Superintendence of Companies and the Secretariat of
Transparency so that employees, contractors or other third parties can report warning signs or situations related
to C/ST.
 Develop policies and procedures aimed at mitigating conflicts of interest among employees, associates,
contractors, and other counterparties that could motivate or facilitate the commission of acts of corruption and
bribery of national or foreign public officials.
 Apply Due Diligence processes that provide for the periodic review of the legal, accounting and financial aspects
related to a business or transaction, the purpose of which is to identify and evaluate the Risks of Corruption
and/or Transnational Bribery C/ST that may affect the Organization, its Subordinate Companies and contractors.
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TRANSPARENCY AND BUSINESS ETHICS
Issue Date: 25-Sep-2023
PROGRAM (PTEE) HANDBOOK
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 Execute the pertinent administrative and legal actions against the administrators and collaborators of the
Organization, when any of the above violates the provisions of the Transparency and Business Ethics Program.
 Facilitate the dissemination of compliance policies and the Transparency and Business Ethics Program to
employees, suppliers, contractors and interested parties.

3.2. Due Diligence Policy

Belleza Express S.A. establishes as a policy to ensure that Due Diligence is carried out by collaborators or third
parties specialized in this work, ensuring at all times that they have sufficient human and technological resources to
carry out periodic reviews on the legal, accounting and financial aspects related to the businesses or transactions
carried out with counterparties evaluated with a critical C/ST risk profile. in order to identify and assess the risks of
Corruption and/or Transnational Bribery C/ST that may affect the Organization, its Subordinates and contractors.
In support of the above, it has defined the following guidelines:
 Any activity of linking or contracting with natural or legal persons, which involves payment or exchange of assets
in cash or kind, in any capacity, must be carried out in accordance with the provisions of this Manual and the
SAGRILAFT Manual of the Organization.
 Incorporate in the agreements entered into with the different natural or legal persons, clauses as a mechanism
for the prevention of the risk of Corruption and/or Transnational Bribery C/ST, with the aim of giving legal support
to the unilateral termination of the contractual relationship, when the other party is formally linked by the
authorities to investigations for the crimes of Corruption and/or Transnational Bribery C/ST.

3.3. Compliance Audit Policy

Belleza Express S.A. will ensure that systematic, critical and periodic reviews are carried out with respect to the
proper execution of the different compliance Risk Management Systems.

The Assurance Body designated by the company must include in its audit programs a specific program for the
verification of the processes and controls related to the prevention and control of compliance risks, in order to measure
the effectiveness of each and every one of the stages and elements of the aforementioned Systems.

On the results and conclusions of this work, the Agency must submit reports to the Compliance Officer, who, in turn,
will initiate the necessary corrective actions. Likewise, the other instances will be informed about the results of the
review of the Compliance Risk Management System.

3.4. Procurement Due Diligence Policy

In cases where Belleza Express S.A. carries out operations as a possible acquirer (merger operations, purchase of
assets, shares, quotas or parts of interest or any other business restructuring procedure), the company will guarantee
the performance of Due Diligence activities, with the aim of identifying all the economic components of the described
operations and the contingencies related to possible acts of Corruption and/or Transnational Bribery C/ST.
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TRANSPARENCY AND BUSINESS ETHICS
Issue Date: 25-Sep-2023
PROGRAM (PTEE) HANDBOOK
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3.5. Organization's Accounting Due Diligence Policy

Belleza Express S.A. is obliged to keep complete and reliable accounting books and records. Expenses, liabilities
and contingencies must be fully and accurately described in all business documentation, not only in terms of amounts,
but also in terms of their nature or destination. Therefore, it is strictly forbidden to create false or misleading
registrations, or to accept from suppliers or third parties a registration that does not meet the requirements demanded
by the company.

To guarantee the above, the Organization will require the Auditor to include in its audit plans, verify the accuracy of
the accounting and ensure that in the transfers of money or other assets made by the Organization, direct or indirect
payments related to Corruption and/or Transnational Bribery C/ST are not hidden.

3.6. Policy for the Payment of Remuneration and Commissions to Contractors

When Belleza Express S.A. requires, for the development of its operations, to bind contractors as suppliers,
intermediaries, agents, distributors, advisors, consultants and third parties who are parties to collaboration or risk-
sharing contracts with the Organization, it may not make or promise payment other than that stipulated in the
agreement, corresponding to legitimate goods or services. In any case, such payments must be in accordance with
the fair market value of the goods or services legitimately received and may not exceed this amount.
Likewise, before hiring any contractor, the designated Compliance Officer must perform the Due Diligence in order to
verify the suitability, good credit or reputation of the third party, and that it does not have any impediment to legally or
commercially relate to national or foreign public officials on behalf of Belleza Express S.A.
Notwithstanding the foregoing, Belleza Express S.A. expects contractors to comply with and respect the applicable
laws in this area and to maintain the highest ethical standards of business conduct.

3.7. Policy on Gifts, Payments, Entertainment and Invitations Offered by Collaborators,

Suppliers, Contractors and Interested Parties

As a policy of Belleza Express S.A., collaborators, associates and contractors, the latter in consideration of their
specific legal relationship with the Organization, may not give gifts, make payments for entertainment and make
invitations in favor of third parties.
Exceptionally, collaborators, suppliers, contractors and interested parties may give gifts, make payments for
entertainment activities and make invitations; only when these are a gesture of courtesy and are exclusively related
to their activity.

In no case may the exceptional delivery of gifts, entertainment payments and/or invitations be considered as an
incentive for a national or foreign public servant to omit, perform, accelerate or delay a management at his or her
expense.
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In order to determine the cases in which gifts, payments for entertainment activities and/or invitations are appropriate
and exclusively related to their activity, collaborators, suppliers, contractors and interested parties must observe the
following guidelines:

 Gifts, entertainment payments, and/or invitations should be modest.

 Gifts, entertainment payments and/or invitations may not be cancelled in cash under any circumstances and
under any circumstances. Payment for these items must be made directly to the supplier, which must be
accredited by means of the corresponding invoice. Likewise, there must be no contractual relationship between
the recipient and the third party that receives it.
 Gifts, entertainment payments and/or invitations must be given in good faith.
 Gifts, entertainment payments and/or invitations should be occasional.
 Such gifts, entertainment payments and/or invitations must not violate local morals and good customs.
 Gifts, entertainment payments, and/or invitations must comply with all applicable local laws and regulations.
 Gifts, entertainment payments and/or invitations must be classified as acts of courtesy, acts called friendly and
will have to conform to the practice of the business.
 Any gift, entertainment payment and/or invitation must be approved in advance by the company and will be
subject to its expense policies and procedures.

The guidelines indicated in this section must be applied in all cases in which, exceptionally, a gift or payment for
entertainment is made, including those events in which payments are made with the own resources of collaborators,
associates, contractors and interested parties.

3.8. Policy on Gifts, Payments, Entertainment, Invitations to Collaborators and Associates

Payments, gifts, commissions, meals and hospitality are not necessary to strengthen healthy business relationships.
The Company's collaborators and associates will not accept payments, gifts, meals, hospitality or travel in exchange
for favoring third parties linked or seeking to join the company.

However, they may accept gifts and invitations and public recognition of their management on behalf of BELLEZA
EXPRESS S.A., such as POP material, training, attendance at events, as long as they do not represent a particular
benefit in the head of the collaborator and associate and without this implying loss of objectivity in decision-making.

In any case, the employee must report to his/her immediate supervisor and the associate to the Board of Directors,
of all those situations in which he/she is offered gifts or attention of any nature, so that he/she can guide his/her
actions with the highest ethical criteria.

3.9. Sponsorship Policy

In cases where Belleza Express S.A. carries out or participates in events sponsored by it or by third parties, with the
aim of advertising its products or obtaining some other commercial benefit, the Due Diligence Policy will be applied
for the engagement of Contractors.
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Any invitation extended by Belleza Express S.A. to a national or foreign public servant to events sponsored by the
company will not be understood as a proposal conditional on the latter performing, omitting or delaying a management
at his or her expense.

In all cases, the purpose of the invitation to the events described in the previous paragraph, to national or foreign
public servants, must be to strengthen their knowledge in the different topics associated with the social purpose of
the Organization. Likewise, any invitation must be made in good faith.

3.10. Donation Policy

Belleza Express S.A. may make donations through collaborators and associates, observing the procedures defined
by the company. These donations must be made for charitable purposes, in good faith and without any economic
benefits for the Organization other than those established by law.

Donations as defined in the preceding paragraph must be made in compliance with all applicable laws and
regulations.

The Due Diligence policies described in this Manual and in the SAGRILAFT Manual will be applied to the beneficiaries
of the Donations.

3.11. Policy on Political Contributions

For the Organization, "Political Contributions" means the giving of sums of money, objects of pecuniary value or other
economic benefit to a political party, political candidate or political campaign.

Only the members of the Board of Directors may authorize the making of political contributions on behalf of the
Organization, such as contributions or donations to political parties, political campaigns, or to third parties publicly or
privately linked to them.

Notwithstanding the foregoing, the collaborators and associates of Belleza Express S.A. they may, from their
personal sphere and in their private capacity, make Political Contributions. In this case, they must bear in mind at all
times that they are collaborators or associates of Belleza Express S.A. and that, therefore, their actions may be
confused with those of the Organization, for which they must take all necessary and recommended measures to avoid
it being understood that their political activism directly or indirectly compromises Belleza Express S.A.

Due to the above guideline, the following activities will be considered as not authorized by Belleza Express S.A. to its
collaborators and associates:

 Use the Organization's goods, services, or equipment, and the time of your workday, to carry out or support your
personal Political Contributions.
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 To negotiate with the Organization the total or partial return or recognition of their Political Contributions.

The Due Diligence policies described in this Manual will be applied to the beneficiaries of political contributions.

3.12. Documentation Maintenance Policy

In order to guarantee the highest degree of collaboration with state control entities, Belleza Express S.A. will keep
the following documents and records related to the Transparency and Business Ethics Program for a period of ten
(10) years:

 The minutes of the Board of Directors approving the policies of the Transparency and Business Ethics Program,
as well as those corresponding to the approval of the adjustments or modifications made to said policies.
 The instructions or manuals that contain the processes through which the approved policies and procedures of
the Transparency and Business Ethics Program are put into practice.
 Reports submitted by the Compliance Officer.
 The reports submitted by the Fiscal Auditor on the operation of the Program.
 Records of the training provided to the Organization's staff on the Transparency and Business Ethics Program.
 The Organization's Code of Ethics.
 The minutes of the Board of Directors stating the presentation of the reports of the Compliance Officer and the
Fiscal Auditor at the appropriate periodicity.
 Documents related to the Due Diligence carried out for the hiring of Contractors, Intermediaries, business
partners and third parties.
 Proof of payments to Contractors, Intermediaries, Sponsorships, Gifts, and other allowable and approved
expenses.
 Certificates supporting donations and political contributions.

3.13. Policy, Update and Modifications of the Transparency and Business Ethics Program - PTEE

The Organization establishes as a policy the review and updating of the Program at least once (1) every two years,
considering the needs of the Organization and the changes in the regulations issued by the control and oversight
bodies.

Any modifications made must be approved by the Board of Directors.

4. INTERNAL REPORTING OF AN UNETHICAL EVENT

Any collaborator or related party in collaboration or risk-sharing contracts with Belleza Express S.A., has the obligation
to report in a timely manner through the channels established by the Organization when, in the development of its
activities, it identifies a situation that goes against the principles and values declared in the Code of Ethics and the
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Transparency and Business Ethics Program for the prevention of the risk of Corruption and/or o Transnational Bribery
C/ST.
If they become aware that an employee, supplier, contractor or any interested party has engaged in any behavior that
goes against the principles and values of the Organization, or the prevention of the risk of Corruption and/or
Transnational Bribery C/ST, as well as any other corrupt practice, they must report them to one of the following
instances: your immediate Supervisor, PTEE Compliance Officer, Human Resources Management Manager or
General Manager, as appropriate and as defined in the Code of Ethics.
The channels established for reporting are as follows:
 WEBSITE: link Ethics Line provided in www.bivien.com
 Complaint Box: MOVA station located within the Company.
Reports will be kept confidential and anonymous. Investigations will be conducted under the principles of good faith
and presumption of innocence.

5. EXTERNAL REPORTING OF ALLEGATIONS OF TRANSNATIONAL BRIBERY

In addition to the reporting channels indicated in the preceding paragraph, the Company's employees, administrators,
associates and contractors may make use of the reporting channel provided by the Superintendence of Companies
to the general public to inform this Entity of any fact or situation related to the alleged conduct of transnational bribery.
Complaints must be treated confidentially by this Entity, whether or not they are anonymous.
It is important to note that these complaints may lead to the initiation of an administrative sanctioning process for
transnational bribery conduct by the Superintendence of Companies against a legal person or branch of a foreign
company when there is merit for it.
To make a report, the link provided by the Entity is the following:

https://www.supersociedades.gov.co/es/web/asuntos-economicos-societarios/canal-de-denuncias-por-soborno-
transnacional

6. SANCTIONING REGIME

This Manual has been designed in accordance with national laws, in compliance with the different applicable
standards defined by the Superintendence of Companies and the rules issued by the UIAF (Financial Information and
Analysis Unit). It also contains a series of control policies and activities that should govern all the Organization's
transactions.

This Manual is a formal invitation from the Organization to its collaborators, suppliers, contractors and interested
parties to promote the performance of their work in a transparent and ethical manner, and also seeks to develop the
Policies promoted and their understanding. To that extent, compliance with it is mandatory for each and every one
of them.
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It is the responsibility of each of the Organization's managers and collaborators to ensure strict compliance with legal
provisions and internal rules and procedures. Permissive behavior in the violation of norms by the boss or superior
should not exist.

The collaborators of the commercial processes, supply management, human talent management and Internal Control
assurance, in their periodic and frequent visits, will evaluate the degree of compliance with the rules and procedures
described herein, in order to detect deviations, and inform the Compliance Officer to take the necessary corrective
measures and, if necessary, apply the sanctions that may arise.

The application of the sanctioning regime derives from the occurrence of irresponsible, permissive, negligent,
inefficient or omissive actions and attitudes in the performance of any employee that affects the Organization, said
regime consists of the application of the provisions of the Internal Work Regulations approved by the Highest Social
Body, which is fully known to the employees.

The sanctions and disciplinary actions that may be taken will be based on each specific situation and depend on the
severity of the violation. In any case, in order to adjust the sanctions, the Organization's managers will be consulted
in order to ensure that the measures taken are fair and guarantee the protection of the rights of the collaborators and
the Organization.