Anti-Bribery Policy

CITIBEATS, as a provider of advanced analytical services, is aware that the phenomenon of corruption represents an obstacle to economic, political and social development, as well as a serious distortion of the rules, fairness and transparency of markets.

We are committed to designing, implementing and improving an Anti-Bribery Management System to prevent, detect and deal with bribery and to comply with anti-bribery laws and voluntary commitments applicable to our activities.

Our principles of action are:

• Absolute prohibition of any type of bribery and conduct that may involve corruption or attempted corruption.

• Strict compliance with current anti-bribery legislation applicable to our organization and our code of ethics.

• Commitment to continuous improvement of our Anti-Bribery Management System.

• Encourage the reporting of possible bribery actions by providing personnel and stakeholders with tools to report conduct and raise concerns in good faith or based on a reasonable belief, which do not comply with company policies and protect whistleblowers against possible retaliation;

• The prosecution of any conduct that does not comply with the anti-bribery policy and the application of the company's system of sanctions.

• The presence of an Anti-Bribery Compliance Function, assumed by the CO that ensures full authority and independence and compliance with the entire Anti-Bribery Management System.

• Sensitize and train personnel on issues related to the prevention of corrupt practices.

This policy is complemented by the anti-bribery objectives approved annually, and is available to all our stakeholders through publication on our website.