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5


 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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