Code of Conduct (VASP)

1. Introduction

This Code sets out, in a clear and practical manner, a set of guidelines based on the Company's values.

These guidelines define the Company's ethics — that is, the attitudes considered appropriate to safeguard the reputation of its assets and to maintain good relationships with its personnel, customers, suppliers, governments and society at large.

The goal is for all conduct to be lawful, held to high moral and ethical standards, and transparent as to products and communications, so as to always deliver an excellent experience for any user, employee, customer, shareholder, or any person who interacts with the Company.

It is essential that everyone reads this document carefully in order to better understand the Company, and that they commit to sharing it and to following the conduct described herein.

While this Code provides broad guidance on acceptable individual and corporate behavior, it cannot address every possible situation.

Accordingly, this Code does not replace the responsibility and obligation of each member of the Company to exercise sound judgment reflecting the values and principles contained herein.

Once distributed, no breach of this Code will be excused on the grounds of lack of awareness or of obedience to instructions received from a superior.

2. Corporate Ethical Values

All activities carried out by the members of the Company must be grounded in the ethical values and basic principles of conduct that constitute the guide to corporate ethical behavior. These are:

Integrity: Maintain impeccable conduct, aligned with rectitude, honesty and consistency, rejecting any form of corruption, privileges or conflicts of interest, and promoting transparency in all actions.

Transparency: Disseminate truthful, clear and timely information, both internally and externally, sharing knowledge without selfishness and cooperating fully in authorized investigations.

Responsibility: Assume obligations seriously, meeting goals with commitment, dedication and proactivity, accepting the consequences of actions or omissions, and respecting institutional positions.

Respect: Recognize and value the qualities and rights of others, providing courteous and tolerant treatment, without discrimination on the basis of race, sex, religion or origin, and avoiding abusive or harassing conduct.

Lawfulness: Always act within the legal framework, complying with applicable rules without exception, even outside the workplace, and rejecting any conduct contrary to the law.

Quality and innovation: Guarantee the best quality in services and products, investing in continuous improvement and process enhancement to meet users' needs.

Security and confidentiality: Provide optimal conditions of health, safety and data protection, applying the highest standards to safeguard confidential information of customers, employees and third parties.

Sustainability: Carry out activities in a sustainable manner, oriented toward respect for the environment, diversity and financial inclusion.

Simplicity: Ensure that functions, processes and communications are clear, simple and user-friendly, facilitating understanding and efficiency in all actions.

The Corporate Ethical Values are the reference that must inspire the conduct of the members of the Company, aimed at fulfilling the obligations of their respective positions in accordance with the principles of loyalty to the Company and good faith, integrity, respect for legality and for ethical criteria; and they allow a series of behaviors to be defined that must be observed by all.

3. Scope of Application

This Code applies to all members of the Company, regardless of the position or role they hold, as well as to persons who are not employees and are performing tasks for the Company for a specific period or specific project (hereinafter, “Employees”).

It also applies to all partners, collaborators, suppliers, contractors, subcontractors, business partners, and individuals or legal entities related to the Company, whether from the public or private sector, regardless of their geographic location (hereinafter, “Third Parties”).

4. Content

4.1. Compliance with the Law

At the Company, employees undertake to faithfully and respectfully comply with all legal obligations to which the Company is subject, whether municipal, provincial, national and/or international.

Within this framework, each member of the Company must behave in accordance with local laws, provided that such laws do not contradict the Company's corporate ethical values and/or principles.

Likewise, they must take the necessary precautions to ensure that the Company cannot be involved, directly or indirectly, in breaches of applicable law.

Therefore, no Employee of the Company shall engage with Third Parties in the violation of any regulation.

4.1.1. Termination of the Relationship

Employees and/or third parties who end their employment and/or commercial relationship with the Company shall refrain from using any information obtained during their relationship with the Company, including customer lists or records.

Employees acknowledge and accept that the work developed for the Company, whether or not it qualifies as intellectual property, belongs exclusively and entirely to the Company, in accordance with the applicable confidentiality agreement signed.

Reports, proposals, studies, programs and any other product derived from professional activity at the Company shall remain in the Company's possession, and the departing person may not copy, reproduce or transmit them in any way without the Company's written authorization.

Accordingly, Employees and Third Parties undertake to return material owned by the Company upon ceasing their activity.

4.1.2. Breaches and Disciplinary Sanctions

Violations of or failures to observe the provisions of this Code shall be subject to disciplinary sanctions in accordance with applicable law.

Sanctions shall be aggravated if the offender holds a senior position, given the greater duty of diligence and responsibility that holding such a position entails.

The applicable disciplinary sanctions, depending on the severity of the breach, may consist of:

  1. Warning or reprimand; and/or

  2. Suspension; or

  3. Suspension with warning of dismissal; and/or

  4. Dismissal for just cause.

These measures are adjusted according to the severity of the breach:

Minor (such as an unintentional error — for example, forgetting a minor check): a warning or reprimand will be applied, together with a conversation aimed at improvement.

Moderate (such as neglecting controls on several occasions): may include a temporary suspension or a suspension with warning of dismissal, which is a serious notice that another error may lead to termination of the contract.

Serious (such as deliberately breaching confidentiality or accepting bribes): dismissal for just cause will be applied, and may lead to legal action where appropriate.

Everything will be handled with prior notice, the right to a defense, and a secure record accessible only to the Compliance Officer, in accordance with the Company's internal rules and the law.

4.1.3. Reporting of Breaches

In accordance with applicable law, the Company has implemented a Whistleblower Line to receive inquiries, requests for guidance, and reports of situations or behaviors that conflict with the principles of this Code of Conduct.

Employees and third parties may report inquiries, complaints or potential breaches of this Code or of any other internal policy through the channels communicated in due course.

Those who reach out may:

  • File the report anonymously.

  • Request confidential or restricted treatment of their report.

  • Request protection of their identity or the use of a pseudonym in order to guarantee the confidentiality of their identity.

What can be reported?

  • Economic fraud (money laundering, theft of goods, assets or valuables, expenses, etc.).

  • Falsification of accounting, operational and financial information, legal documents, and circumvention of the company's internal controls.

  • Harassment, discrimination and mistreatment of personnel (acts to the detriment of gender, race, nationality, etc.).

  • Poor performance by employees/collaborators, supervisors and/or managers (including abuse of power, threats and misconduct).

  • Corruption and collusion with suppliers/customers (including conflicts of interest).

  • Neglect or improper use of the organization's assets, services and/or information. Theft or misappropriation of the company's internal information.

This list is not exhaustive. Any irregularity not included in this list may also be reported.

To enable an effective investigation, it is recommended to provide as much detail as possible in the report, including:

  • Who engaged in fraud, corruption or other improper conduct, and identifying any potential parties involved.

  • What happened, describing the facts accurately and providing relevant details.

  • When it happened, including dates, times and frequency of the events.

  • Where it took place, specifying the location in as much detail as possible (city, address, office, etc.).

  • Who else might have information about the reported event.

  • Who will know that the report has been filed.

Every report will be treated with strict confidentiality, and under no circumstances will retaliation be taken against those who make good-faith inquiries or reports about potential unlawful acts or regulatory breaches.

The person filing the report must have reasonable grounds and provide concrete facts. Intentionally filing false reports or reports with incorrect information constitutes a serious breach of the Code of Conduct and may result in disciplinary sanctions.

Where a violation of the Code involves illegal acts, the relevant authorities will be notified. For questions about the application or interpretation of the Code, it is recommended to contact the Compliance Officer.

4.2. Information Protection and Confidentiality Policy

The Company's private and confidential information includes non-public data (commercial, financial, operational, personal or strategic) whose disclosure could harm the company, its customers, suppliers or employees. It is a key asset that employees must protect in order to maintain ARQ's competitiveness and compliance with the law.

In addition, in order to ensure the proper functioning of the Anti-Money Laundering, Counter-Terrorism Financing and Counter-Proliferation Financing (AML/CFT/CPF) System, the confidentiality of information related to this system must be guaranteed.

Personnel Responsibilities

Employees must:

  • Protect the confidentiality, integrity and security of all sensitive information, especially that related to AML/CFT/CPF (physical, digital or discarded).

  • Comply with applicable data protection regulations.

  • Access information and systems only if authorized and for work-related tasks.

  • Not use, share or transfer confidential data, including AML/CFT/CPF data, for personal purposes or with third parties.

  • Guarantee the confidentiality of customer data obtained in the context of AML processes and policies, including monitored transactions or reports to the regulator, and not disclose it under any circumstances, except with legal authorization or upon official request.

  • Take care of assets (equipment, systems) and avoid damage, theft or misuse.

  • Accept that work tools may be monitored by the company.

  • Manage operating expenses accurately and only for authorized purposes.

  • Protect intellectual property and follow internal security policies.

  • Immediately report any suspicion of misuse to their supervisor, the Compliance Officer, or the whistleblower channel.

Third-Party Responsibilities

Suppliers, contractors or partners with access to confidential information, including AML/CFT/CPF information, must undertake not to disclose it without authorization. This duty of confidentiality continues after the end of their relationship with the Company.

4.3. AML/CFT/CPF Prevention System

The Company maintains a robust and up-to-date Anti-Money Laundering, Counter-Terrorism Financing and Counter-Proliferation Financing (AML/CFT/CPF) System, in accordance with the regulations applicable to the jurisdiction.

This system is not optional: it represents ARQ's unwavering commitment to integrity and transparency, protecting its customers, the company and society from illicit financial risks.

Any omission or negligence in its implementation will be considered a serious violation of the Code of Conduct, with zero tolerance toward conduct that compromises ARQ's reputation.

It is mandatory for personnel to:

  • Thoroughly understand and strictly apply the AML/CFT/CPF policies in all work activities; lack of awareness does not exempt from responsibility.

  • Immediately report to the Compliance Officer any suspicious transaction, conduct or indication, without exception or delay, under penalty of sanctions.

  • Maintain absolute confidentiality regarding the information generated by the system, including customer data and internal reports, even after the end of the employment relationship with the Company; any disclosure will be pursued with the utmost rigor.

  • Mandatorily participate in annual AML/CFT/CPF training, demonstrating active commitment to updating technical and ethical knowledge.

4.4. Non-Discrimination and Equal Treatment Policy

All persons who are part of the Company must treat one another with respect, fostering a comfortable, healthy and safe work environment.

Any offensive conduct, or any conduct that implies discrimination on the basis of race, religious, political or union beliefs, nationality, language, sex, marital status, age, disability or any other personal difference, is strictly prohibited.

Under no circumstances will conduct involving harassment, abuse of authority, threats, pressure, mobbing, offense or any other form of aggression and hostility that fosters a climate of intimidation be permitted.

Employees are respectful of the people with whom they interact, especially with regard to equal treatment and non-discrimination.

This entails:

  • Providing kind and equal treatment to their colleagues and to the company's representatives in general.

  • Refraining from any offensive conduct or conduct that implies any form of discrimination on the basis of race, color, sex, language, religion, political or other opinions, national or social origin, economic status, birth or any other social condition.

  • Those who lead or manage a team must address their reporting personnel with respect and offer fair treatment, especially in the assignment and supervision of work tasks, internal career advancement and training.

The Company does not tolerate discrimination in any of its forms. Therefore, suitability for the proper performance of the position or role is the determining criterion for personnel selection.

4.5. Zero Tolerance for Bribery and Corruption

All Employees and Third Parties associated with the Company must ensure that their activities are carried out with the highest level of integrity and effectiveness.

The Company has zero (0) tolerance for any act of bribery and/or corruption.

Employees and Third Parties are strictly prohibited from offering any advantage or payment, of any nature or kind, to any person — including, but not limited to, public officials, political parties, the public sector, or any private company or natural person — with the intention of unlawfully obtaining or retaining business or other advantages, or of causing such person to abuse their influence for the benefit of the Company.

All Employees of the Company and Third Parties acting on its behalf are prohibited from participating, in any way — by encouraging, approving, paying, providing, relaying, concealing, cooperating with, or in any way enabling — the practice of bribing any public official to influence or reward any official action or decision of such person for the benefit of the Company.

The term “public official” is used generically to include officers, officials and employees of the government or of any public body, agency or legal entity, at any level, including officers or employees of publicly owned companies or of public international organizations. It also includes candidates for political office, employees or politicians of political parties, as well as political parties themselves.

In order to prevent and avoid the laundering of capital derived from criminal or unlawful activities, Employees shall pay special attention to those cases in which there are indications of a lack of integrity of the persons or entities with which business is conducted, in addition to their general duty to comply with applicable legal provisions.

4.6. Conflicts of Interest

A conflict of interest will exist when an Employee's interest — whether personal or that of third parties related to them — collides or could collide with the duties and obligations inherent to their status as an Employee of the Company (whether due to the position they hold and/or any other circumstance), threatening the fairness and impartiality expected of all Employees.

Employees may participate in financial and business activities other than those they carry out for the Company, provided they are lawful and do not collide with their responsibilities as Employees of the Company.

Employees must refrain from engaging in situations that could give rise to a conflict between personal interests and those of the Company, as well as from representing the Company, intervening in, or influencing decision-making, in any situation in which, directly or indirectly, they have a personal interest.

Employees must always act, in the performance of their responsibilities, with loyalty and in defense of the interests of the Company, also complying with applicable rules.

Likewise, Employees may not perform tasks, work or provide services for the benefit of companies in the sector that carry out activities capable of competing, directly or indirectly, with those of ARQ.

Employees must:

  • Disclose any direct or indirect holdings that they own, by themselves or through third parties and/or family members, in supplier, customer, competitor, contractor and/or subcontractor companies of the Company.

  • Avoid making recommendations that breach the standards of professionalism and necessity that the Company upholds when conducting business, whether with companies, organizations or individuals in which they have any direct or indirect personal interest.

  • Refrain from granting other companies, organizations or individuals undue advantages in any business transaction, remaining impartial.

  • Refrain from becoming involved in relationships that could give rise to an actual, potential or apparent conflict with the Company, or that could in any way have a negative effect on their own freedom of action.

  • Refrain from using the Company's assets or information available to them by virtue of their position for personal benefit or that of third parties, or to compete with ARQ.

Those who may be affected by a conflict of interest must report it through the ethics line mentioned above, or comply with the procedure implemented in the future, prior to carrying out the transaction or concluding the business in question, so that it can be assessed whether their impartial performance may be compromised.

4.7. Gifts, Presents and Hospitality

Gifts, presents and hospitality, depending on their magnitude and timing, may give the impression of having been given or received to unduly persuade or influence the recipient's decisions; therefore, they must not be accepted or given if they may be perceived as compromising judgment or integrity, or as a way of inappropriately influencing a business relationship or decision.

Any gift, present and/or hospitality of any kind that is offered, provided or delivered, directly or indirectly, by public officials, must be rejected regardless of its value.

All gifts, presents and hospitality should preferably be institutional (for example, bearing a logo), not intended for individuals, and comply with applicable law. However, those that are not may be accepted provided they do not represent a form of inappropriate influence toward one or more employees.

4.8. Protection of Assets

All members of the Company are obligated to safeguard the tangible assets (premises, equipment, work tools, etc.) and intangible assets (image, prestige, financial information, product and personnel information) that belong to the Company, and to be alert to report situations that could lead to the loss or misuse of such assets.

Information that may be considered illegal, offensive or inappropriate must in no case be processed, downloaded, stored and/or disseminated. It is prohibited to download, store, copy and/or disseminate by any means information and/or content of any nature in violation of intellectual property laws.

The downloading, installation, transmission and/or use of software in violation of any copyright or related right is prohibited.

Company assets must be used only for the purposes entrusted to them in connection with the work; therefore, all members of the Company expressly acknowledge that the use of information, systems and, in particular, Internet services must be governed by the needs of the Company and not by personal interests, and that there will be no expectation of privacy in the information generated and/or transmitted using the tools and networks provided by the Company.

The Company reserves the right to control and monitor the use of assigned assets, since the information produced and stored in the Company's systems is the property of ARQ.

4.9. Transparency of Information

All Employees of the company must take the necessary precautions to ensure transparent handling of information.

This principle of transparency and truthfulness of information shall also apply to internal communication.

All of the Company's transactions must be reflected clearly and accurately in its files, records and books.

Likewise, a decision is transparent when:

  • It is made in accordance with applicable regulations and within their limits, with practical sense and good judgment.

  • It is based on objective elements and on a reasonable analysis of the risks involved.

  • It prioritizes the interests of the Company over any particular interest.

  • Its grounds are clearly documented.

  • It is communicated in a timely manner through the appropriate channels.

4.10. Fair Competition and Antitrust

The Company will not engage in misleading advertising of its business activities and will avoid any conduct that constitutes or may constitute an abuse or unlawful restriction of competition.

The Company understands that fairness in competition and respect for consumer rights are factors that foster the development of the market on sustainable bases.

5. Statement of Principles

Those who are part of the Company undertake to:

  • Carry out their duties with honesty and integrity.

  • Perform their duties with respect toward all members of the organization, fostering a healthy and safe work environment.

  • Conduct business management in an open and transparent manner.

  • Act with rectitude, responsibility and professionalism regarding the obligations in their charge.

  • Guarantee equal opportunities for all members of the organization.

  • Not tolerate any act of discrimination in any of its forms.

  • Perform their duties fairly, complying with the law whether working with government authorities, customers or suppliers.

  • Make a genuine commitment to the fight against corruption and the promotion of integrity, and report breaches of the code of ethics and any potential corruption offenses that come to their knowledge to the appropriate party in the company and/or to the public authorities.

  • Advance the development and implementation of an integrity program.

  • Ensure that all members of the organization and third parties know and comply with ARQ's principles.

  • Consult any doubts about the application of the integrity policies with the person responsible for compliance or with their superiors.

6. Customer Protection and User Rights

The Company undertakes to provide its customers with a secure, transparent service oriented toward the effective protection of their rights. In compliance with applicable regulations, the following user rights are recognized:

a) Right to clear and truthful information

Customers have the right to receive, before contracting any product or service, complete, clear and non-misleading information about: the services available, the costs, commissions and applicable charges, the terms and conditions, the associated risks, and the settlement times of transactions.

b) Right to privacy and personal data protection

Customers' personal data will be processed in accordance with applicable regulations. Customers have the right to know what data is collected, for what purpose it is used, and to update, rectify and request its deletion in the cases provided by law.

c) Right to file complaints and obtain a response

Every customer has the right to submit inquiries, complaints and claims through the enabled channels. The Company will respond to claims within the timeframes established by applicable regulations, informing the customer of the status of their case. The complaints channel will be available on a permanent and free-of-charge basis.

d) Right to transaction security

The Company implements adequate technological security measures to protect its customers' transactions and funds. In the event of any unrecognized transaction or suspicion of fraud, the customer may report it immediately through the customer service channels, and the Company will act diligently to investigate and resolve the incident.

e) Right to cancel the service

Customers may request, at any time, the closure of their account or the cancellation of the contracted services, without penalties and following the procedure published on the website and/or mobile application.

7. Fair Customer Treatment Policy

The Company adopts a fair treatment policy that ensures all customers receive equitable, transparent and non-discriminatory service, regardless of their origin, gender, nationality, economic status or other personal characteristics.

Principles of fair treatment

Equity: Products and services are offered under objective and uniform conditions. Different conditions will not be applied to customers in equivalent situations except on objective and non-discriminatory grounds.

Transparency: All communication with the customer — commercial, contractual or informational — will be clear, truthful and free of ambiguities or techniques that could mislead them.

Accessibility: The Company will strive to make its products and communications understandable and accessible.

Non-discrimination: It is prohibited to deny, limit or condition access to services on the grounds of gender, race, religion, nationality, political opinion, social origin, income level or other conditions unrelated to technical or objective criteria.

Fair dispute resolution: Claims will be handled impartially, following predefined and documented procedures, guaranteeing the customer the right to be heard and to obtain a reasoned response.

Protection against abusive practices: The Company expressly prohibits any practice that may be considered abusive, coercive or misleading toward customers, including undue pressure, undisclosed charges or unjustified restrictions.