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                            WHAT OUR


                                                                                                                                             SUPERVISE.  Monitor execution and conduct audits that ensure that the
                            COMPANY EXPECTS OF:                                                                                              processes that support regulatory relationships and compliance with
                                                                                                                                             standards are operating effectively.


                                                                                                                                             Ratify our commitments regarding this Code of Ethics by reading and signing
                                                                                                                                             the following documents, among others:


                            5.1 OUR EXECUTIVES

                            All executives have the following special responsibilities  to comply with
                            appliable laws:                                                                                                  1     Annual Certification of Related Parties


                            LEAD. Ensure personal and team commitment in accordance with policies
                            and  regulatory  requirements,  adequately  managing  associated  risks.                                         2     Annual Declaration on Conflicts of Interest
       CODE OF ETHICS     RESPECT IS THE GOLDEN RULE
                            Consider the regulatory requirements in the key processes of our business
                            operation.  Training  continuously  and  acquire  a  genuine  knowledge  of  the
                            industry in which the Company participates. Promote integrity programs,                                                Commitment Letter of Confidentiality and Information
                            policies and procedures among employees and third parties interested in                                          3     Management
                            the Company, as well as convey the importance of respecting and complying
                            with them.

                            EVALUATE OBJECTIVELY AND FAIRLY.  Understand and apply the laws,
                            requirements, policies and principles corresponding to the operation of the
                            business and/or its activities.

                            VERIFY COMPLIANCE. Assign responsible parties for the different regulatory
                            risks and ensure that they coordinate the relationships between the respective
                            government authorities and corporate experts on legal issues. They must
                            certify they have the knowledge and experience for the efficient management
                            of regulatory relationships and to guarantee compliance with laws. Care for the
                            Company’s resources diligently and in the best interest of others. Regard our
                            human element, communicate and promote competitiveness, our philosophy
                            and principles, thoroughly developing our personnel.

                            ANTICIPATE. Implement effective processes that alert about new regulations
                            or  modifications  in  them.  Always  include  regulations  in  their  risk  analysis.
                            Be proficient in the industry so that we can plan and meet the objectives,
                            having the necessary information to carry them out.


                            COOPERATE.  Develop and maintain effective relationships with regulatory
                            bodies, coordinating with experts in government relations and compliance.
                            Work proactively for the development of regulations that allow to efficiently
                            achieve objective and proper policies.


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