Code of Ethics and Conduct Policy

OBJECTIVE

Establish a comprehensive framework of principles and guidelines that promote ethical behavior, foster respect,

transparency, and equality in relationships with stakeholders, ensure the proper use of corporate resources,

prevent improper practices such as bribery, corruption, and money laundering, and regulate the handling of cash,

gifts, and benefits. This policy aims to protect the reputation and sustainability of ONBOARD LOGISTICS

COLOMBIA S.A.S., ensuring compliance with legal, contractual, and ethical standards, and promoting a culture of

integrity at all levels of the organization.

SCOPE AND APPLICATION FRAMEWORK

This policy is applicable to the employees of Onboard Logistics Colombia S.A.S. and, where relevant, the

responsibilities contained herein will also apply to contractors who provide their services to the Company.

Compliance Officers

All the staff

CODE OF ETHICS AND CONDUCT

Desirable behavior

Attend to all customers, suppliers, and other stakeholders according to principles of equality and opportunity. This means showing them the utmost respect, cordiality, and tolerance. Treat customers, suppliers, colleagues, and the general public without discrimination (of race, gender, religion, sexual preference, or nationality).

Honor the commitments, meetings, and delivery of results inherent to the role or position being held.

Clearly and precisely explain to the client the benefits and conditions for handling their shipments, without intentionally omitting any of their features.

Be prudent in language and behavior. Be prudent in language and behavior.

Speak positively about the services offered by the company, promote them, and highlight their importance for the company's good image in the industry.

Be respectful of the competition, their products, and their workers, avoiding any harm to their good reputation. Be respectful of the competition, their products, and their workers, avoiding any harm to their good reputation.

Enhance the company's image with impeccable management of finances, debt, and business relationships.

Be responsible for the proper use of access keys to information systems and keep them confidential.

Install only computer programs with valid licenses that respect intellectual property and usage rights.

Use offices, departments, information systems, network access, and other work elements solely for purposes approved by the company.

Communicate the formal degree of kinship you have or establish with other company employees, candidates, clients, or suppliers.

Maintain the appropriate reserve and confidentiality regarding documents and information accessed in the course of the work.

Report suspicious activities that might harm the company's integrity and reputation.

Consistently and promptly collaborate with the authorities' requirements.

Promote adherence to sound commercial practices through procedures and controls that protect the company's reputation, mitigating the risk of being used to give an appearance of legality to resources from illicit activities related to money laundering, terrorism financing, proliferation of weapons of mass destruction, bribery, and/or corrupt acts.

Undesirable Behavior

AS A MEMBER OF ONBOARD LOGISTICS COLOMBIA SAS, I RECOGNIZE THAT THE FOLLOWING BEHAVIORS ARE UNACCEPTABLE:

Giving or accepting money, gifts, substantial favors, or any kind of benefit to do, stop doing, or influence others in the execution or omission of tasks or decisions.

Execute or define contracts on behalf of the company or make decisions that benefit family or friends.

Engage in transactions with individuals or companies for whom there are indications of involvement in criminal activities such as Money Laundering and/or Terrorism Financing (ML/TF).

To assault, mistreat, or engage in any form of abuse, inconsiderate or offensive treatment, and, in general, outrages to human dignity.

To claim as one's own or market creations, inventions, software, manuals, discoveries, and improvements in procedures developed and sponsored by the company during the period of service.

Give statements to the media about internal or external events that may jeopardize the company's reputation, except with express authorization or duties assigned to public relations personnel.

Disclose confidential information related to: - Financial statements that have not been publicly presented. - Data of clients, intermediaries, or suppliers. - Business processes, support, or information about technological infrastructure. - Data that compromises security and assets due to fraudulent actions. - In general, any information that might disadvantage the company against the competition.

Inappropriately exploiting the information accessed during the course of a working relationship with the company for personal gain.

Distributing or consuming prohibited substances or illegal and controlled drugs.

Attending the workplace while intoxicated or under the influence of controlled drugs.

Exhibiting inappropriate behavior at internal or industry social gatherings, which may compromise the company's image.

Disrespect others with pranks or tasteless jokes.

Using the company's assets or good reputation for personal purposes.

Promote or facilitate clients, suppliers, and other stakeholders with practices aimed at tax evasion or avoidance.

Promote or conduct political or religious campaigns within the premises or on behalf of the company.

Promoting or conducting raffles, collections, sales, or loans with clients, suppliers, collaborators, or coworkers.

Carrying firearms or explosives of any kind on company premises.

Specific ethical and conduct standards

3.1 Prevention of money laundering and financing of terrorism, financing the proliferation of weapons of mass destruction.

At ONBOARD LOGISTICS COLOMBIA S.A.S, we are committed to preventing the materialization of risks, which is why we pledge to ensure integrity in our processes and to control all customs operations in which we participate. In this regard, we establish various commitments related to the continuous improvement of performance in Control and Security Management, which are outlined below:

Prevent any involvement in illicit activities within our facilities, supply chain operations, and business processes.

Maintain the integrity of each process, operation, and service regarding the prevention of illicit acts.

Minimize risks in all processes related to the supply chain.

Comply with applicable legal requirements and other commitments that the organization subscribes to.

Maintain and continuously operate the organization's compliance system to prevent crimes such as money laundering, terrorism financing, bribery, corruption in public and/or private sectors, influence peddling, and other related or similar offenses.

Train, raise awareness, and educate our employees and stakeholders on topics related to supply chain security and international trade.

3.2 Gifts, courtesies or benefits

Gifts, attentions, and hospitality are courtesies designed to cultivate good business relationships. Their giving or receiving should have the sole purpose of promoting, maintaining, and strengthening commercial relationships and must comply with the internal rules of ONBOARD LOGISTICS COLOMBIA S.A.S.:

They must be granted in good faith and have a valid and legitimate purpose that does not compromise the integrity of the company, its directors, and/or employees.

They should be circumstantial and reasonable, taking into consideration the applicable laws in the country.

They must not influence, nor give the impression of influencing, that they have been granted with the aim of obtaining or retaining contracts, nor to secure undue advantages.

That they do not create the impression, nor the implicit obligation, that the person carrying them out has the right to preferential treatment.

They will not be carried out in the form of a bribe, improper payment, or commission.

Under no circumstances should they be cash or cash equivalents. If received, it must be reported to Management to be donated for the benefit of employees in general.

The company agrees that an employee may give or receive gifts or courtesies not exceeding an amount of 100 USD. In any case, their giving or receipt must relate to the purposes established here.

Partners, shareholders, employees, as well as those who provide services or act on behalf of ONBOARD LOGISTICS COLOMBIA S.A.S, must not receive or give any type of payment, gift, attention, or hospitality to a government employee, in order to avoid any risk of improper relations that could harm the company's reputation.

Employees of ONBOARD LOGISTICS COLOMBIA S.A.S. must refrain from accepting valuable gifts, favorable conditions, salaries, trips, commissions or any other form of compensation from clients, suppliers, financial institutions, contractors, companies, or individuals with whom operations are conducted.

However, it is understood that occasionally and at commemorative or social events, employees of ONBOARD LOGISTICS COLOMBIA S.A.S. may receive gifts of moderate value or items that are typically distributed for promotional purposes.

If, for reasons of courtesy in the business relationship, it is decided to accept a valuable gift, it must be reported to the General Management, where its final use will be decided.

3.3 Cash handling.

ONBOARD LOGISTICS COLOMBIA S.A.S. has a policy of not conducting cash transactions; consequently, it is prohibited to give or receive cash payments from clients, contractors, or suppliers. Therefore, it is established that:

Payments to be made by ONBOARD LOGISTICS COLOMBIA S.A.S. will be the sole responsibility of the Administrative and Financial area and will only be made through bank transactions.

ONBOARD LOGISTICS COLOMBIA S.A.S. will only receive payments from its clients in the bank accounts authorized for this purpose.

Only cash transactions originating from Petty Cash will be approved if they are intended for small and urgent amounts or for Social Welfare promotion activities within the company, managed by the Human Resources department.

The Compliance Officer must submit the monthly report on Cash Transactions to the UIAF, in accordance with the DIAN instructions, following the amounts and indications specified in the current External Circulars and according to the Procedure for reporting to control entities.

Cash transactions will be understood as all those transactions that, in the course of the regular business dealings of clients, suppliers, or contractors, involve the receipt or delivery of money in national and/or foreign bills and coins.

3.4 Travel, entertainment, food, and lodging expenses

ONBOARD LOGISTICS COLOMBIA S.A.S., aims to ensure that business trips are conducted safely and efficiently, by setting clear guidelines and ensuring that the associated costs are market-aligned, justified, and within the purpose of the trip.

The company's travel expense reimbursement processes are carried out by covering reasonable costs and those that have actually been incurred by the employees in the course of their responsibilities, submitting the corresponding documentation.

Travel approvals and related costs must be made ensuring that the trip is properly justified and must be authorized by Management, who will ensure that there are no unauthorized costs or cost overruns.

3.5 Compensation, bonuses, and commission payments to employees and contractors

ONBOARD LOGISTICS COLOMBIA S.A.S., We promote fair treatment for our employees, which includes fair compensation commensurate with the level of responsibility, performance, and role within the company. Compensation through commissions or bonuses allows for rewarding the employee according to their performance or the achievement of objectives.

All compensation for bonuses or commissions is defined in the respective employment contracts between the employee and the company; these contracts specify the respective conditions related to this type of payments.

It is forbidden to make payments or remunerate contractors or collaborators who are not established in the contract or employment agreement.

3.6 Relationship with the Competition

ONBOARD LOGISTICS COLOMBIA S.A.S., we act with respect, loyalty, and good faith towards our competitors; therefore, we avoid acts that improperly undermine free and fair competition. Thus:

No employee of ONBOARD LOGISTICS COLOMBIA S.A.S. may speak poorly of the competition; nor make dishonest comparisons that generate discredit and confusion or deceive the customer; use improper methods to obtain information from the competition, nor use it with ill intent.

ONBOARD LOGISTICS COLOMBIA S.A.S. will not participate in any agreement intended to limit the free play of market forces in which it operates, nor will it use improper means to improve its competitive position in these markets.

The executives and employees of ONBOARD LOGISTICS COLOMBIA S.A.S. who have contact with competitors' representatives will maintain a professional attitude, adhering to the principles and values of the company they represent, while taking care of their personal image and that of ONBOARD LOGISTICS COLOMBIA S.A.S.

We protect consumers' rights by ensuring they have access to clear and truthful information about products and services, enabling them to make informed decisions.

Establish mechanisms so that consumers can make claims and resolve disputes fairly and quickly.

We comply with laws that protect consumers against misleading advertising, unfair business practices, and other types of fraud.

Executives and employees of ONBOARD LOGISTICS COLOMBIA S.A.S. should avoid making comments or statements about competitors whenever possible, and when it is necessary, these should be fair, objective, and comprehensive.

Under no circumstances will ONBOARD LOGISTICS COLOMBIA S.A.S., nor its executives, nor its staff, attempt to obtain trade secrets or any other confidential information from a competitor by improper means.

Every worker must act with loyalty, have a sense of belonging to the company, and work with quality, fulfilling commitments to set themselves apart from the competition.

Every worker is obliged to report any unfair competition activities they are aware of.

3.7 Conflict of Interest

The executives and workers of ONBOARD LOGISTICS COLOMBIA S.A.S must avoid any conflict between their own interests and those of the Company, with its clients, suppliers, or any other person who has or may come to have ties with it. For which:

The executives and employees of ONBOARD LOGISTICS COLOMBIA S.A.S. must refrain from having relatives or family members working under their supervision, except in cases authorized in writing by Management.

When a manager or employee needs to oversee, supervise, audit, or control an area managed by a relative, they must inform their superior about the situation so that they can be relieved of this responsibility.

When an executive or employee feels unable to fulfill their responsibilities objectively due to pressure from third parties using their position, authority, or influence in the organization, they should immediately report it to their superior or to management.

Executives and employees must refrain from fulfilling the demands of superiors, subordinates, coworkers, family, or friends if it harms ONBOARD LOGISTICS COLOMBIA S.A.S., or their own ethical and professional integrity.

All employees have the duty to serve the legitimate interests of ONBOARD LOGISTICS COLOMBIA S.A.S. They should not take advantage of opportunities, use company property or information, exploit their position for personal gain, or compete with the company directly or indirectly.

Executives and employees are obliged to inform ONBOARD LOGISTICS COLOMBIA S.A.S. of any potential conflict of interest, whether their own or someone else's, from the moment they become aware of the situation.

Executives and employees should refrain from favoring one client to the detriment of another.

Gifts and considerations received (whether in money or in kind) should not hinder the freedom and independence to choose what is deemed best for the company or third parties. Everything must be done within the legal framework of action and in accordance with section 6.3 of this document.

3.8 Contributions and Participation in Politics

It is established that ONBOARD LOGISTICS COLOMBIA S.A.S. does not make political contributions of any kind, nor does it participate directly or indirectly in proselytizing acts, nor does it make donations, contributions, or contributions to any political party, movement, campaign, activity, or political candidate at the national, regional, or local level. For its part:

ONBOARD LOGISTICS COLOMBIA S.A.S. encourages its employees to engage in civic processes and the development of Colombian democracy.

The involvement of employees in politics should be during their free time, and such efforts cannot involve the name of ONBOARD LOGISTICS COLOMBIA S.A.S., nor the position held by the employee in it.

Workers may also contribute their money or assets to the cause of the candidate or candidates of their choice, but they may not contribute resources, services, or assets from ONBOARD LOGISTICS COLOMBIA S.A.S.

It is not allowed to start or participate in political campaigns within the facilities of ONBOARD LOGISTICS COLOMBIA S.A.S., nor to distribute political material to the company staff, by any means.

3.9 Donations and Sponsorships

At ONBOARD LOGISTICS COLOMBIA S.A.S., we do not make donations or sponsorships. However, if it were to happen:

They must be pre-approved and explicitly sanctioned by management, who will validate their legitimacy and purpose to prevent the risk of fraud or corruption.

They can only be executed with funds included in the company's budget.

They must have a legitimate purpose; not be anonymous; be formalized in writing; and in case they are in money, be made through any means of payment that allows the identification of the recipient of the funds, and leave evidence and traceability of the contribution.

Do not offer or engage in these actions when there is suspicion that they might conceal any illicit or suspicious behavior.

They should only be delivered to the direct beneficiaries or their accredited intermediaries.

Do not proceed if it could be interpreted that the company or its employees are seeking to gain an advantage in a bid, public tender, or obtain any other benefit or advantage.

They must be directed to donation-receiving entities in the public sector or private non-profit institutions, ensuring that the requirements are met for them to be considered tax-deductible.

They must be of reasonable value.

Those directed at the employees must be coordinated with the Administrative Management and/or the corresponding management, which must approve and leave the proper record.

You must have the corresponding donation certificate or a document confirming receipt by the beneficiary.

Regarding Sponsorships: Currently, no group is being sponsored. However, if sponsorship occurs, the following should be done:

Be directed towards activities or organizations that are aligned with the company's values and purpose.

Not applicable to events or entities that promote, tolerate, or express any form of discrimination, mistreatment, violence, human rights violations, ethics, morality, or good customs, nor for proselytizing activities.

A record of the transaction should be kept, and the current Code of Ethics and Conduct is hereby presented.

3.10 Company Image Management

All individuals who maintain a work, commercial, or any other type of relationship with ONBOARD LOGISTICS COLOMBIA S.A.S. must care for, protect, and prudently manage the company's image in order to preserve its good name and avoid reputational, economic, and legal damages.

Similarly, anyone wearing the company's identifying apparel must conduct themselves according to morally ethical principles, values, and norms, and comply with both internal regulations and Colombian national laws, always aiming for the responsible management of the company's image.

3.11 Management of the Company's Image

All existing and generated information by ONBOARD LOGISTICS COLOMBIA S.A.S. is confidential. Therefore, no employee is authorized to disclose it to third parties without prior authorization from their superiors.

It is the duty of all employees who, by virtue of their position, have access to confidential information, or information whose disclosure could harm the Company, to refrain from sharing it with third parties or using it for personal benefit.

It is prohibited to distort records and/or financial information, or falsify transactions, whether to simulate the achievement of goals or objectives, or to gain any personal benefit.

All information generated in the financial records is confidential and can only be provided to duly authorized users.

Executives and employees must refrain from undertaking actions that might influence, coerce, manipulate, or deceive any internal or external auditor or employee performing their duties.

Executives and employees must take the necessary measures to protect the confidential information they have access to, both physically and on their computer equipment, in order to prevent it from being known by unauthorized persons.

3.13 Collaboration with Authorities

The company will conduct itself with integrity and respect for the law and its representatives before the authorities, always taking into account values and ethical principles in the exercise of its activities.

All external communication received from government or regulatory entities (DIAN, Superintendencias, Mayors’ Offices, UGPP, DANE, UIAF, Secretariats, among others) must be addressed within the term established in the requirement. The response guidelines are followed according to the Communication Matrix.

The executives and employees of ONBOARD LOGISTICS COLOMBIA S.A.S. must adhere strictly, in the course of their activities, to the applicable laws and regulations.

The executives and workers of ONBOARD LOGISTICS COLOMBIA S.A.S. must cooperate at all times with the competent authorities for the full exercise of their powers and act lawfully in defense of the legitimate interests of the company.

The executives and employees who interact with authorities should treat them in a friendly and respectful manner, recognizing their status as such, and striving to create an atmosphere of openness and trust that facilitates the discussion of matters and the establishment of agreements.

The requirements and observations of the authorities must be fully attended to, seeking to effectively and courteously collaborate in fulfilling their mission, within the powers granted to them by laws or regulations.

All transactions, procedures, and relations that the company engages in with government agencies or workers, on its behalf, must be carried out in accordance with applicable laws, as well as with the standard business practices conducted by companies within the same industry in the country and region.

Management of the Code of Ethics and Conduct

4.1 Channels of Assistance

ONBOARD LOGISTICS COLOMBIA S.A.S. has set up an ETHICAL LINE, through which inquiries, complaints, and reports about possible suspicious, unusual operations, or warning signs that may occur in operations or transactions conducted in the Company related to Corrupt acts, Bribery, Money Laundering, Terrorist Financing, proliferation of weapons of mass destruction and in general any situations that may pose a risk to the company will be received.

Reports are kept secure, confidential, and anonymous. There will be no retaliation against those who, in good faith, report acts or potential acts of violation of this Code of Ethics and Conduct.

Our contact channels are:

• Email: lineaeticacolombia@onboardlogistics.net

• Phone line: +57 601 4673364, +57 320 3154413

• Physical correspondence: AC 26 # 69-63 Office 313 Business Center Tower 26 Bogotá Colombia

Every worker, client, supplier, distributor, and other stakeholders are obliged to report any behavior of their own or others that goes against what is established in this Code.

When a situation arises that needs to be reported, the following steps must be followed:

Protection is sought for the whistleblower and, in general, for the complaints made.

It is essentially an anonymous communication channel. All communication, even if received from a known source, will be treated as anonymous and the confidentiality of the source will be respected.

It must be used responsibly. The reported facts should be real and, if possible, verifiable.

There will be no reprisals against the whistleblower if the source of the complaint becomes known.

All complaints or inquiries from employees will be handled with strict confidentiality in the process given to them. Management will ensure absolute discretion regarding the identity of the person(s) making the reports, therefore it is suggested not to make anonymous reports.

It will be ensured that no retaliatory actions of any kind are taken against individuals who report violations of this Code or ethical conflicts.

4.2 Penalty regime

Violations of this Code, the internal work regulations, and/or those that go against national laws, will be subject to sanctions.

Any permissive conduct, negligence, and any omission committed by an employee, those providing services, or acting on behalf of ONBOARD LOGISTICS COLOMBIA S.A.S. will result in the sanctions outlined below and will be applied based on the circumstances of each specific case in accordance with the severity of the offense, the damage or potential damage caused, recidivism, among others:

Verbal warning.

Protection is sought for the whistleblower and, in general, for the complaints made.

Verbal warning.

Written warning, recorded in the Work Record, for the case of employees.

It is essentially an anonymous communication channel. All communication, even if received from a known source, will be treated as anonymous and the confidentiality of the source will be respected.

Written warning, recorded in the Work Record, for the case of employees.

Suspension from performing duties for one (1) to three (3) months.

It must be used responsibly. The reported facts should be real and, if possible, verifiable.

Suspension from performing duties for one (1) to three (3) months.

Termination of contractual relationships whether with employees, clients, suppliers, distributors, and other stakeholders.

There will be no reprisals against the whistleblower if the source of the complaint becomes known.

Termination of contractual relationships whether with employees, clients, suppliers, distributors, and other stakeholders.

Filing complaints with the authorities.

Generating consequently, responsibilities of type:

Work responsibility.

Protection is sought for the whistleblower and, in general, for the complaints made.

Work responsibility.

Civil liability.

It is essentially an anonymous communication channel. All communication, even if received from a known source, will be treated as anonymous and the confidentiality of the source will be respected.

Civil liability.

Criminal liability.

It must be used responsibly. The reported facts should be real and, if possible, verifiable.

Criminal liability.

In cases of serious offenses or crimes, the penalties can range from dismissal and contract termination to criminal charges being filed with the competent authorities. The severity of these penalties will depend on the seriousness of the offenses committed, as outlined in the Internal Work Regulations. However, there will be no standardization of penalties; it will depend on the analysis of each case.

From the issuance of this document and for illustrative purposes, the following are established as serious offenses that may result in the termination of the employment contract and/or contracts with third parties:

a) Negligently disregarding the policies, rules, and practices for the proper management of ONBOARD LOGISTICS COLOMBIA S.A.S., causing serious harm to them.

b) Failing to comply with legal provisions resulting in sanctions by authorities, including drug trafficking, money laundering, terrorism, financing of terrorism, proliferation of weapons of mass destruction, and smuggling. Also, causing financial damage or future contingencies for ONBOARD LOGISTICS COLOMBIA S.A.S.

c) Omitting or failing to inform in a timely manner about violations of the Code, the Security Policy, and actions that may jeopardize the good name and operation of ONBOARD LOGISTICS COLOMBIA S.A.S.

d) Evidencing intoxication by drugs or alcohol and/or engaging in immoral conduct on company premises.

e) Discriminating, intimidating, or harassing another person due to race, color, sex, age, origin, beliefs, sexual preference, or physical ability.

f) Failing to comply with safety and protection norms that endanger the life of personnel or company assets.

g) Unjustifiably and maliciously accusing an innocent person.

h) Consuming, distributing, transporting, selling, and possessing any type of prohibited substances.

i) Influencing, coercing, manipulating, or deceiving any employee conducting an investigation or review within the company.

j) Conducting operations for personal, family, or third-party benefit, to the detriment of ONBOARD LOGISTICS COLOMBIA S.A.S.

k) Distorting accounting records.

l) Forging or altering vouchers, documents, signatures, and seals.

m) A serious violation by the employee or contractor of the contractual obligations and/or those contemplated in the Internal Work Regulations.

PERSONAL DATA PROCESSING POLICY

OBJECTIVE

This document outlines the guidelines and procedures to be followed for the proper protection of personal data and sensitive information of individuals in various processes and generally, in the development of the organization's business model.

SCOPE AND APPLICATION FRAMEWORK

This policy is applicable to the employees of Onboard Logistics Colombia S.A.S. and, where relevant, the responsibilities contained herein will also apply to contractors providing services to the Company.

Compliance Officers

All the staff

Regulation

Decree 1072 of 2015 and other current legal regulations.

No.

DEFINITIONS

Authorization:

Prior, express, and informed consent of the Owner to carry out the processing of personal data.

Authorization:

Prior, express, and informed consent of the Owner to carry out the processing of personal data.

Authorization:

Prior, express, and informed consent of the Owner to carry out the processing of personal data.

Authorization:

Prior, express, and informed consent of the Owner to carry out the processing of personal data.

Privacy Notice:

Verbal or written communication generated by the data controller, directed to the data subject for processing their personal information, through which they are informed about the existence of information processing policies that will apply to them, how to access these policies, and the purposes for which the personal data is intended to be used.

Privacy Notice:

Database:

Organized set of personal data that is subject to processing.

Database:

Organized set of personal data that is subject to processing.

Database:

Organized set of personal data that is subject to processing.

Database:

Organized set of personal data that is subject to processing.

Personal data:

Any information linked or that can be associated with one or more specific or identifiable natural persons.

Personal data:

Any information linked or that can be associated with one or more specific or identifiable natural persons.

Personal data:

Any information linked or that can be associated with one or more specific or identifiable natural persons.

Personal data:

Any information linked or that can be associated with one or more specific or identifiable natural persons.

Private or Sensitive Data:

It is the information that, due to its intimate or confidential nature, is only relevant to the owner. This implies that private data is any information related to a person's private life, such as their religious ideas and beliefs, sexual orientation, and health condition.

Private or Sensitive Data:

Semi-private data:

It is the information that is neither private, reserved, nor public in nature, and whose knowledge or disclosure may be of interest to the holder, a certain sector or group of people, or society in general. Semi-private data includes financial and credit information managed by banks and credit agencies.

Semi-private data:

Public data:

It is the data classified as such according to the mandates of the law or the Political Constitution and all those that are not semi-private or private. By their nature, these data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly enforced judicial rulings that are not subject to confidentiality.

Public data:

Data Controller:

A natural or legal person, public or private, who, alone or in association with others, carries out the processing of personal data on behalf of the Data Controller.

Data Controller:

A natural or legal person, public or private, who, alone or in association with others, carries out the processing of personal data on behalf of the Data Controller.

Data Controller:

A natural or legal person, public or private, who, alone or in association with others, carries out the processing of personal data on behalf of the Data Controller.

Data Controller:

A natural or legal person, public or private, who, alone or in association with others, carries out the processing of personal data on behalf of the Data Controller.

Claim:

Request by the data subject or by individuals authorized by them or by law to correct, update, or delete their personal data, or to revoke the authorization in the cases provided by law.

Claim:

Request by the data subject or by individuals authorized by them or by law to correct, update, or delete their personal data, or to revoke the authorization in the cases provided by law.

Claim:

Request by the data subject or by individuals authorized by them or by law to correct, update, or delete their personal data, or to revoke the authorization in the cases provided by law.

Claim:

Request by the data subject or by individuals authorized by them or by law to correct, update, or delete their personal data, or to revoke the authorization in the cases provided by law.

10.

Responsible for processing:

A natural or legal person, public or private, who, either alone or in partnership with others, makes decisions regarding the database and/or the processing of data.

10.

Responsible for processing:

A natural or legal person, public or private, who, either alone or in partnership with others, makes decisions regarding the database and/or the processing of data.

10.

Responsible for processing:

A natural or legal person, public or private, who, either alone or in partnership with others, makes decisions regarding the database and/or the processing of data.

10.

Responsible for processing:

A natural or legal person, public or private, who, either alone or in partnership with others, makes decisions regarding the database and/or the processing of data.

11.

Headline:

An individual whose personal data is subject to processing.

11.

Headline:

An individual whose personal data is subject to processing.

11.

Headline:

An individual whose personal data is subject to processing.

11.

Headline:

An individual whose personal data is subject to processing.

12.

Treatment:

Any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion; as well as its transfer and/or transmission to third parties through communications, inquiries, interconnections, assignments, or data messages.

12.

Treatment:

12.

Treatment:

12.

Treatment:

13.

Transfer:

The transfer of personal data occurs when the controller and/or processor of personal data, located in Colombia, sends personal data information to a recipient, who in turn is responsible for processing and is located either inside or outside the country.

13.

Transfer:

13.

Transfer:

13.

Transfer:

PRINCIPLES

In accordance with Article 4 of Law 1581 of 2012, the principles governing the processing of personal data at ONBOARD LOGISTICS COLOMBIA SAS. are:

Principle of legality: The processing of personal data is a regulated activity that must comply with what is established in the law and other provisions that develop, add, or modify it.

Purpose principle: The Processing must have a legitimate purpose in accordance with the Constitution and the Law, which must be communicated to the Holder.

Principle of freedom: Processing can only be carried out with the prior, express, and informed consent of the Data Subject. Personal data cannot be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that waives consent.

Principle of truthfulness or quality: The information subject to Processing must be truthful, complete, accurate, updated, verifiable, and understandable. The Processing of partial, incomplete, fragmented, or misleading data is prohibited.

Principle of transparency: In the Processing, the Holder's right to obtain information from the Data Controller or the Data Processor about the existence of data concerning them, at any time and without restrictions, must be guaranteed.

Principle of restricted access and circulation: The Processing is subject to the limits arising from the nature of personal data, legal provisions, and the Constitution. - Processing may only be carried out by individuals authorized by the Data Subject and/or by persons provided for by law. - Personal data, except for public information, may not be available on the Internet or other means of mass dissemination or communication, unless access is technically controllable to provide restricted knowledge only to the Data Subjects or third parties authorized according to the law.

Security principle: The information subject to processing by the Controller or Processor must be handled with the necessary technical, human, and administrative measures to ensure the security of the records, preventing their alteration, loss, consultation, unauthorized or fraudulent use, or access.

Principle of confidentiality: All individuals involved in the processing of personal data that is not of a public nature are required to ensure the confidentiality of the information, even after their relationship with any of the tasks involved in the processing has ended. They may only provide or communicate personal data when this is in accordance with the development of activities authorized by law and under its terms.

DATABASE CONTENT

In the databases of ONBOARD LOGISTICS COLOMBIA SAS., general information is stored such as full name, identification number and type, and contact information (email and mobile). In addition to these, and depending on the nature of the database, ONBOARD LOGISTICS COLOMBIA SAS. may have specific data required for the processing to which the data will be subjected. In the databases of employees and contractors, additional information is included regarding work and academic history, sensitive data required by the nature of the employment relationship (photograph, family group composition, biometric data). Sensitive information may be stored in the databases with prior authorization from the data owner, in compliance with what is established in Articles 5 and 7 of Law 1581 of 2012.

Rights of the Titleholders

In accordance with the provisions of Article 8 of Law 1581 of 2012, natural persons whose Personal Data are processed by ONBOARD LOGISTICS COLOMBIA S.A.S., have the following rights, which they can exercise at any time:

To know, update, and correct their personal data in front of ONBOARD LOGISTICS COLOMBIA S.A.S., or the Responsible Parties.
- This right can be exercised, among others, on partial, inaccurate, incomplete, fragmented data, that induce error, or those whose Processing is expressly prohibited or has not been authorized.
Request proof of the authorization granted to ONBOARD LOGISTICS COLOMBIA S.A.S., except when it is expressly excluded as a requirement for Processing, in accordance with the provisions of Article 10 of this law.
Be informed by ONBOARD LOGISTICS COLOMBIA S.A.S., or the Responsible Party, upon request, regarding the use given to their personal data.
Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of this law and other norms that modify, add, or complement it.
Revoke the authorization and/or request the deletion of the data when Processing does not respect constitutional and legal principles, rights, and guarantees.
- The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that ONBOARD LOGISTICS COLOMBIA S.A.S., or the Responsible Party, has engaged in conduct contrary to this law and the Constitution.
Access their personal data that have been processed free of charge.

Exercise of Rights

In accordance with Decree 1074 of 2015, the exercise of the aforementioned rights may be exercised by:

The Holder, who must sufficiently prove their identity by the different means made available by the Responsible Party.
Their successors, who must prove such status.
The representative and/or attorney of the Holder, upon accreditation of representation or power of attorney.

OBLIGATIONS OF ONBOARD LOGISTICS COLOMBIA SAS.

ONBOARD LOGISTICS COLOMBIA SAS. must:

1. Guarantee the Holder, at all times, the full and effective exercise of the right to habeas data.

2. Request and retain, under the conditions provided in this law, a copy of the respective authorization granted by the Holder.

3. Properly inform the Holder about the purpose of the collection and the rights that assist them by virtue of the granted authorization.

4. Preserve the information under the necessary security conditions to prevent its alteration, loss, consultation, unauthorized or fraudulent use or access.

5. Ensure that the information provided to the Processor is truthful, complete, accurate, updated, verifiable, and understandable.

6. Update the information, promptly communicating to the Processor any new developments regarding the data previously provided, and adopt any other necessary measures to keep the provided information updated.

7. Rectify the information when it is incorrect and communicate the pertinent correction to the Processor.

8. Provide the Processor, as applicable, only data whose Processing is previously authorized in accordance with the provisions of this law.

9. Require the Processor, at all times, to respect the security and privacy conditions of the Holder's information.

10. Handle inquiries and complaints formulated under the terms specified in this law.

11. Adopt an internal manual of policies and procedures to ensure appropriate compliance with this law and, in particular, for handling inquiries and complaints.

12. Notify the Processor when certain information is under dispute by the Holder, once the claim has been filed and the respective process has not concluded.

13. Inform the Holder, upon request, about the use of their data.

14. Notify the data protection authority when security code violations occur and there are risks in the management of the Holders' information.

15. Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

PURPOSES

5.1 Hiring, business relationships and engagement of third parties

Employment Contract Joining: For the induction of new staff with an employment contract, it is necessary for each staff member who begins any type of work to acknowledge, accept, and apply the personal data protection policies.

a) Contact the Data Subjects to send information related to the contractual and obligational relationship with the employees.

b) Know, store, and process all the information provided by the Data Subjects in one or several databases, in the format deemed most convenient.

c) Comply with the obligations undertaken as the person responsible for Processing with the Data Subject, concerning the payment of salaries, social benefits, and other compensations stipulated in the employment contract or as provided by law and the contract.

d) Develop health and safety at work prevention and promotion programs based on medical and occupational health information from the moment of entry, as well as during the execution and completion of the assigned activities.

e) Develop training, education, and training programs according to the worker's position.

f) Execute to the fullest the contracts that have been concluded with the employees.

g) Manage, maintain, develop, and control the existing contractual relationship between the parties, address their information requests, as well as manage their claims, process their requests to terminate the contract and revoke the Authorization for Personal Data Processing.

h) Manage information associated with the potential commission of acts or circumstances that imply the development of ethical or disciplinary control procedures, in accordance with the applicable internal regulations and other normative provisions.

i) Generate copies and security archives of the information on the equipment provided by ONBOARD LOGISTICS COLOMBIA S.A.S.

j) Organize, catalog, classify, divide, or separate the information provided by the Data Subjects.

k) Offer corporate welfare programs and plan business activities for the Data Subject and their beneficiaries.

l) Meet the legal demands and information requests from administrative, social security, and judicial authorities that regulate, supervise, or monitor the activities and operations of ONBOARD LOGISTICS COLOMBIA S.A.S., subject to due process compliance.

m) Comply with the Internal Work Regulations, as well as the internal policies of ONBOARD LOGISTICS COLOMBIA S.A.S.

n) Verify the information contained in the resume provided to ONBOARD LOGISTICS COLOMBIA S.A.S.

o) Prevent fraud or misuse of the company's services.

p) Register the family group information of the employees of ONBOARD LOGISTICS COLOMBIA S.A.S. to fulfill the duties stipulated by law, as well as to involve them in the welfare activities or benefits provided by the company.

q) Carry out access control to the facilities of ONBOARD LOGISTICS COLOMBIA S.A.S.

r) Collect information deposited in credit bureaus.

s) Use the supplied data in case of integration or change of control of ONBOARD LOGISTICS COLOMBIA S.A.S.

5.2

Commercial Linkage: In the event that during the course of commercial relations, database management of suppliers, partners, or third parties with whom such a relationship is developed is required, the respective processes must be established by the different responsible areas, including clauses, annexes, contracts, or procedures to ensure the protection of information and personal data in these relationships; whether it's a personal data protection clause, confidentiality agreement, Transfer contracts, etc.

a) Collection to verify compliance with the entity's policies regarding the selection and hiring of suppliers, as well as to verify and confirm the identity of the supplier.

b) Contact suppliers to send information related to the contractual and obligational relationship as required.

c) Know, store, and process all information provided by the Owners in one or multiple databases, in the format deemed most convenient.

d) Contact suppliers by electronic means – SMS, email, and/or telephone to fulfill the contract's purpose with ONBOARD LOGISTICS COLOMBIA S.A.S.

e) Comply with the obligations undertaken as the party responsible for Processing with the information owner, concerning the relationship between ONBOARD LOGISTICS COLOMBIA S.A.S. and each supplier.

f) Structure and inform general or personalized commercial offers, as well as contact suppliers for such purposes, even once the relationship with ONBOARD LOGISTICS COLOMBIA S.A.S. has ended.

g) Manage, maintain, develop, and control the existing contractual relationship between the parties, attend to their information requests, as well as manage their claims, process their requests for contract termination and revocation of authorization for personal data processing.

h) Promote events hosted by ONBOARD LOGISTICS COLOMBIA S.A.S. or by third parties related to the industry.

i) Collect information for commercial and marketing research purposes and for companies affiliated with ONBOARD LOGISTICS COLOMBIA S.A.S.

j) Provide contact information to the sales force and/or distribution network, marketing, market research, and any third party with whom ONBOARD LOGISTICS COLOMBIA S.A.S. has a contractual relationship for the development of such activities and their execution.

k) Verify compliance with the agreements and commitments assumed by virtue of the existing relationship or bond.

The purposes of collecting and processing personal data of CLIENTS of ONBOARD LOGISTICS COLOMBIA S.A.S., will be as follows:

a) Contact the holders to send information related to the contractual and obligational relationship as required.

b) Know, store, and process all information provided by the holders in one or multiple databases, in the format deemed most convenient.

c) Keep the Client informed and updated about products or promotions by any means, including but not limited to: electronic means (SMS, email) or traditional physical means, to conduct satisfaction surveys regarding the goods and services offered by ONBOARD LOGISTICS COLOMBIA S.A.S.

d) Conduct proper order taking and quality evaluation of the products and services of ONBOARD LOGISTICS COLOMBIA S.A.S.

e) Manage, maintain, develop, and control the existing contractual relationship between the parties, attend to their information requests, manage their claims, process their requests for contract termination and revocation of authorization for personal data processing.

f) Verify references and obtain commercial, banking, and financial information from the client.

g) Organize, catalog, classify, divide, or separate the information provided by the holders.

h) Perform the proper data updating.

i) Collect information for commercial and marketing research purposes.

MINOR DATA

The services of ONBOARD LOGISTICS COLOMBIA SAS are only available to individuals who have the legal capacity to contract; therefore, the company collects data only from individuals over 18 years of age. Those who do not meet this condition should refrain from providing personal information to be included in the databases. Similarly, company employees must not register information related to minors in the processing systems. However, if it becomes necessary to collect data from minors, the authorization of the minor's legal representative must be obtained, complying with the purpose principle established in Law 1581 of 2012.

PERSON OR RESPONSIBLE AREA

Every request, complaint, or claim related to the handling of personal data, in accordance with the provisions of the Law

1581 of 2012 and Decree 1377 of 2013, must be sent to:

• COMPANY: ONBOARD LOGISTICS COLOMBIA SAS.,

• Office: AC 26 # 69-63 Office 313, Bogotá D.C

• Colombia Email: lineaeticacolombia@onboardlogistics.net

• Phone: 601 4673364

• Cell: 302 8345229

8. DUTIES OF THE PERSON IN CHARGE AND RESPONSIBLE FOR PROCESSING

In accordance with Article 17 of Law 1581 of 2012, the following are the duties of those responsible for Processing:

Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
Request and keep a copy of the respective authorization granted by the holder.
Properly inform the holder about the purpose of the collection and the rights they are entitled to by virtue of the authorization granted.
Keep the information under necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.
Ensure that the information provided to the processor is truthful, complete, accurate, up-to-date, verifiable, and understandable.
Update the information, promptly notifying the processor of all developments regarding the data previously provided and adopt other necessary measures to keep the information provided to them up-to-date.
Rectify the information when it is incorrect and communicate the pertinent details to the processor.
Provide the processor, as applicable, only data whose processing is previously authorized.
Require the processor to respect the security and privacy conditions of the holder's information at all times.
Process consultations and claims formulated under the terms stipulated in this policy.
Adopt an internal manual of policies and procedures to ensure the proper compliance with personal data protection regulations and, especially, for handling inquiries and complaints.
Inform the processor when certain information is under discussion by the holder, once the claim has been filed and the respective process has not yet been completed.
Inform the holder of the use given to their data upon request.
Inform the data protection authority when there are breaches of security codes and risks in the management of holders' information.
Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
Carry out the timely updating, rectification, or deletion of data under the terms of this law.
Update the information reported by those responsible for Processing within five (5) business days from its receipt.
Record in the database the legends “claim in process” in the manner regulated by this law.
Insert in the database the legend “information in judicial discussion” once notified by the competent authority about judicial processes related to the quality of personal data.
Refrain from circulating information that is being disputed by the holder and has been blocked by order of the Superintendence of Industry and Commerce.
Allow access to the information only to those who are entitled to it.
Inform the Superintendence of Industry and Commerce when there are breaches of security codes and risks in the management of holders' information.
Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

PARAGRAPH. In the event that the roles of the Processor and Processor Assistant concur in the same person, compliance with the duties stipulated for each will be required.

REVOCATION OF AUTHORIZATION

The holders of personal data can at any time request ONBOARD LOGISTICS COLOMBIA S.A.S. to delete their personal data and/or revoke the Authorization granted for their processing.

The holder has two options to revoke their consent:

Request the revocation of all consented purposes, meaning that ONBOARD LOGISTICS COLOMBIA S.A.S., from the time of the request and onwards, cannot process the holder's personal data again, unless the holder authorizes the data processing again in the future.
Request partial revocation of consent, meaning the responsible party may continue processing the data for the purpose(s) not revoked by the holder.

Considering the above, it is necessary for the holder, when requesting revocation, to clearly and expressly indicate whether the revocation required is total or partial.

Note: The request to delete the information is not applicable when the holder has a legal or contractual duty.

In addition, personal data of the holders may be removed from the database when the Superintendence of Industry and Commerce has determined that contrary behaviors have occurred.

PROCEDURES FOR SUBMITTING AND RESPONDING TO INQUIRIES

The holders of personal data that are contained in the databases of ONBOARD LOGISTICS COLOMBIA S.A.S., or their successors, can consult the data that will provide information in the terms provided for in the applicable legislation. Any request for consultation, correction, updating, or deletion must be submitted in writing or by email, according to the information contained in this document.

Consultations will be answered within a term of ten (10) business days starting from the date of receipt of the respective request. When it is not possible to respond to the inquiry within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which their query will be addressed, which in no case may exceed five (5) business days following the expiration of the first term.

Procedures for submitting and responding to queries, complaints, and claims Claims must be submitted in writing or by email, in accordance with the information contained in this document, and must contain at least the following information:

Holder's Identification
Description of the facts leading to the claim
Holder's Address
Documentation you wish to present as evidence

If the claim is incomplete, the interested party will be required within five (5) days following the receipt of the claim to remedy the deficiencies. After two (2) months from the date of the requirement, without the applicant providing the required information, it will be understood that the claim has been withdrawn.

In the event that the person receiving the claim is not competent to resolve it, they will transfer it to the appropriate party within a maximum term of two (2) business days and will inform the interested party of the situation.

Once the complete claim is received, a legend stating "claim in process" and the reason for it will be included in the database within no more than two (2) business days. Said legend must be maintained until the claim is decided.

The maximum term to respond to the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to attend to the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

VALIDITY OF THE PERSONAL DATA PROCESSING POLICY

The Personal Data Processing Policy of ONBOARD LOGISTICS COLOMBIA S.A.S. will be effective from its approval. ONBOARD LOGISTICS COLOMBIA S.A.S. reserves the right to modify it, in accordance with the terms and limitations provided by law.

The databases managed by ONBOARD LOGISTICS COLOMBIA S.A.S. will be maintained indefinitely, as long as it carries out its purpose, and as long as necessary to ensure compliance with legal obligations, particularly labor and accounting, but the data may be deleted at any time upon request of its owner, provided that this request does not conflict with a legal obligation of ONBOARD LOGISTICS COLOMBIA S.A.S., or an obligation contained in a contract between ONBOARD LOGISTICS COLOMBIA S.A.S. and the Holder.

COMPREHENSIVE POLICY

OBJECTIVE

Establish a framework guiding ONBOARD LOGISTICS COLOMBIA SAS in implementing international logistics solutions based on principles of safety, sustainability, and operational excellence, ensuring compliance with applicable legal, regulatory, organizational, and contractual requirements, promoting continuous improvement, the prevention of illicit activities, and the development of trustworthy relationships with stakeholders.

SCOPE AND APPLICATION FRAMEWORK

It applies to all operations, processes, and activities of ONBOARD LOGISTICS COLOMBIA SAS related to the international supply chain, involving employees, business partners, visitors, and other stakeholders.

Compliance Officers

All employees, business associates, visitors, and other stakeholders.

Regulation

Circular 170, SARLAFT, BASC Standard V6, BASC Standards 6.0.2, Decree 1072 of 2015, Law 1562 of 2012

No.

DEFINITIONS

Security:

Implementation of measures and controls to prevent risks and illicit activities such as smuggling, money laundering, and illegal trafficking in the supply chain.

Security:

Implementation of measures and controls to prevent risks and illicit activities such as smuggling, money laundering, and illegal trafficking in the supply chain.

Security:

Implementation of measures and controls to prevent risks and illicit activities such as smuggling, money laundering, and illegal trafficking in the supply chain.

Security:

Implementation of measures and controls to prevent risks and illicit activities such as smuggling, money laundering, and illegal trafficking in the supply chain.

Sustainability:

Implementation of responsible practices that minimize environmental and social impacts, ensuring a balance between economic development and environmental conservation.

Sustainability:

Implementation of responsible practices that minimize environmental and social impacts, ensuring a balance between economic development and environmental conservation.

Sustainability:

Implementation of responsible practices that minimize environmental and social impacts, ensuring a balance between economic development and environmental conservation.

Sustainability:

Implementation of responsible practices that minimize environmental and social impacts, ensuring a balance between economic development and environmental conservation.

Continuous Improvement:

Systematic process aimed at identifying and applying improvements in systems, processes, and outcomes to increase organizational efficiency and effectiveness.

Continuous Improvement:

Systematic process aimed at identifying and applying improvements in systems, processes, and outcomes to increase organizational efficiency and effectiveness.

Continuous Improvement:

Systematic process aimed at identifying and applying improvements in systems, processes, and outcomes to increase organizational efficiency and effectiveness.

Continuous Improvement:

Systematic process aimed at identifying and applying improvements in systems, processes, and outcomes to increase organizational efficiency and effectiveness.

Cybersecurity:

A set of strategies and technologies aimed at protecting sensitive information by ensuring its confidentiality, integrity, and availability against digital threats.

Cybersecurity:

A set of strategies and technologies aimed at protecting sensitive information by ensuring its confidentiality, integrity, and availability against digital threats.

Cybersecurity:

A set of strategies and technologies aimed at protecting sensitive information by ensuring its confidentiality, integrity, and availability against digital threats.

Cybersecurity:

A set of strategies and technologies aimed at protecting sensitive information by ensuring its confidentiality, integrity, and availability against digital threats.

Operational Excellence:

Efficient execution of business processes, meeting high quality standards and exceeding the expectations of customers and stakeholders.

Operational Excellence:

Efficient execution of business processes, meeting high quality standards and exceeding the expectations of customers and stakeholders.

Operational Excellence:

Efficient execution of business processes, meeting high quality standards and exceeding the expectations of customers and stakeholders.

Operational Excellence:

Efficient execution of business processes, meeting high quality standards and exceeding the expectations of customers and stakeholders.

Regulatory Compliance:

Ensuring that the company's operations and activities comply with laws, regulations, and standards applicable to the logistics sector.

Regulatory Compliance:

Ensuring that the company's operations and activities comply with laws, regulations, and standards applicable to the logistics sector.

Regulatory Compliance:

Ensuring that the company's operations and activities comply with laws, regulations, and standards applicable to the logistics sector.

Regulatory Compliance:

Ensuring that the company's operations and activities comply with laws, regulations, and standards applicable to the logistics sector.

POLICY:

At ONBOARD LOGISTICS COLOMBIA S.A.S., we lead logistics solutions in the international freight forwarding of imports, exports, and consulting, under principles of safety, sustainability, and operational excellence.

Aligned with the needs and expectations of our Business Associates, collaborators, and other interested parties, from top management we allocate financial, human, technological resources, and appropriate infrastructure to optimize our processes and effectively manage risks in our supply chain, complying with applicable regulatory, legal, organizational, and contractual requirements.

To this end, we focus our efforts on:

Prioritizing the labor welfare, health, safety, and development of our collaborators, promoting a culture of self-care, prevention, and participation.
Establishing reliable relationships with Collaborators and Business Associates, based on transparency, safety, and compliance with international and national standards.
Preventing the occurrence of illicit activities in the supply chain and crimes related to international trade, such as:
- money laundering
- smuggling
- drug trafficking
- trafficking for narcotics processing
- terrorism
- terrorism financing
- forced labor
- arms trafficking
- proliferation of weapons of mass destruction
- cargo contamination
- corruption
- wildlife trafficking
- bribery in all its forms
  This through a risk management-based approach, allowing us to effectively monitor our operations and processes to anticipate, mitigate, and control these threats.
Managing resources responsibly, reducing environmental impacts and promoting sustainable practices throughout our operation.
Protecting information using advanced cybersecurity tools, ensuring its confidentiality, integrity, and availability.

We are committed to the continuous improvement of our management systems, technological innovation, and sustainable development, ensuring customer satisfaction and contributing to the fulfillment of our strategic objectives, with a constant focus on operational excellence and business sustainability.

Quality Policy

Onboard Logistics provides solutions in international logistics, establishing a firm commitment to the continuous improvement of its quality management system, along with the compliance of applicable requirements and the adoption of internationally recognized standards.

The following are the principles and objectives of our strategy.

1. Increase customer satisfaction by offering a high level of commitment, advice, and

attention, promoting continuous growth in business relationships.

2. Permanent innovation as a culture, to achieve and maintain efficient processes.

3. Develop committed teams, encouraging them to reach their maximum potential, through

an environment of open communication, creativity, and recognition.

4. Generate mutually beneficial and long-term relationships with stakeholders who

influence our results, based on trust and mutual cooperation. Management ensures that this Quality Policy is understood, implemented, and maintained at all levels; committing to provide the necessary and sufficient resources to achieve the sustainability of such commitments over time.

BASC Management in Control and Security Policy

The Senior Management of ONBOARD LOGISTICS PERU S.A. has issued this policy with the purpose of establishing its commitment to the prevention of illicit activities.

At ONBOARD LOGISTICS PERU S.A., we are dedicated to providing international freight forwarding services, coordinating logistics in air, maritime, and land transportation for importing or exporting companies that require the movement of their goods to and from any part of the world. Being aware of the responsibility in our supply chain, we are committed to maintaining secure trade, making the necessary efforts so that in our operations, processes, and shipments, all types of illicit activities, such as drug trafficking, smuggling, drug dealing, acts of terrorism, money laundering, bribery, public and/or private corruption, among others, are prevented. The aim is to ensure integrity in our processes and to control all foreign trade operations in which we participate.

In this regard, through this policy, we establish various commitments related to the continuous improvement of performance in Management Control and Security, which are outlined below:

• Prevent our facilities, supply chain operations, and commercial processes from being involved in illicit activities.

• Minimize the occurrence of risks in the operations carried out by the company, by identifying threats, assessing and evaluating risks, and establishing the respective controls that help maintain the integrity of the processes involved in the supply chain.

• Keep the organization's compliance system updated and in continuous operation, for the management of risks inherent to the operation and prevention of money laundering and terrorism financing crimes, bribery, or other acts of corruption in the public and/or private domain, influence peddling, and other related or similar crimes.

• Maintain mutually beneficial relationships with business partners based on building enduring relationships according to their satisfaction and compliance with requirements, agreements, and security standards.

• Establish appropriate mechanisms for the selection and association of personnel, allowing us to have an ideal and committed human team, which matches the needs and objectives of the company.

• Train, sensitize, and raise awareness among our employees and stakeholders on issues related to supply chain security and foreign trade.

Code of Ethics and Conduct Policy

OBJECTIVE

SCOPE AND APPLICATION FRAMEWORK

Compliance Officers

MORE INFORMATION IN THE FOLLOWING DOCUMENTS

CODE OF ETHICS AND CONDUCT

Desirable behavior

Undesirable Behavior

Specific ethical and conduct standards

3.1 Prevention of money laundering and financing of terrorism, financing the proliferation of weapons of mass destruction.

3.2 Gifts, courtesies or benefits

3.3 Cash handling.

3.4 Travel, entertainment, food, and lodging expenses

3.5 Compensation, bonuses, and commission payments to employees and contractors

3.6 Relationship with the Competition

3.7 Conflict of Interest

3.8 Contributions and Participation in Politics

3.9 Donations and Sponsorships

3.10 Company Image Management

3.11 Management of the Company's Image

3.13 Collaboration with Authorities

Management of the Code of Ethics and Conduct

4.1 Channels of Assistance

4.2 Penalty regime

PERSONAL DATA PROCESSING POLICY

OBJECTIVE

SCOPE AND APPLICATION FRAMEWORK

Compliance Officers

Regulation

PRINCIPLES

DATABASE CONTENT

Rights of the Titleholders

OBLIGATIONS OF ONBOARD LOGISTICS COLOMBIA SAS.

PURPOSES

5.1 Hiring, business relationships and engagement of third parties

5.2

MINOR DATA

PERSON OR RESPONSIBLE AREA

8. DUTIES OF THE PERSON IN CHARGE AND RESPONSIBLE FOR PROCESSING

REVOCATION OF AUTHORIZATION

PROCEDURES FOR SUBMITTING AND RESPONDING TO INQUIRIES

VALIDITY OF THE PERSONAL DATA PROCESSING POLICY

SOCIAL RESPONSIBILITY POLICY

OBJECTIVE

SCOPE AND APPLICATION FRAMEWORK

Compliance Officers

Regulation

POLICY:

COMPREHENSIVE POLICY

OBJECTIVE

SCOPE AND APPLICATION FRAMEWORK

Compliance Officers

Regulation

POLICY:

Quality Policy

Quality Policy

Quality Policy

BASC Management in Control and Security Policy

BASC Management in Control and Security Policy

BASC Management in Control and Security Policy