Code Of Ethics

The partners at Arbtrust Venture LLC. (“Managers”) strive to create and maintain a culture where all those who have a position, function, position, employment, commercial, professional, contractual or trust relationships with the Company are able to witness a solid expansion of our business and the exercise of our code of ethics as interconnected factors.

This Code of Ethics (“the Code”) aims to establish the rules, principles, concepts and values that should guide the ethical standard of conduct of the Employees in their internal performance and with the financial and capital markets, as well as in their relations with the various investors and the general public.

STANDARDS OF CONDUCT

All employees, contractors and related business must:

BE RESPECTFUL

Although opinions may differ, it is important to remain civil and respectful.

WORK TOGETHER

To foster a productive environment where everyone is allowed to have an opinion without repercussions.

BE INCLUSIVE

We are welcoming of people from all backgrounds on our team, including members of any race, ethnicity, culture, class, orientation, education, age, size, family status, political or religious beliefs and mental and physical ability.

BE CONSIDERATE

Treat others how you would like to be treated in the workplace. Each person on this team is important and essential, and each person’s decisions and actions affect our outcomes and morale.

BE PROFESSIONAL

Conducting yourself professionally includes being kind to others. Maintain professional interactions when communicating with others at all times.

BE HONEST AND TRANSPARENT

We are dedicated to the full disclosure of our professional life and activities.

BE ACCOUNTABLE FOR SHORTCOMINGS OR MISTAKE

We take actions and strive to deliver excellence and we commit to hold ourselves accountable for any action that the person we are morally responsible for. Accepting accountability if there is any harm caused includes righting unintentional wrongs.

KNOW AND UNDERSTAND THEIR OBLIGATIONS

To wards the Manager, as well as the legal rules that regulate them, in order to avoid any practices that infringe or conflict with the rules and principles contained in this Code and in the regulations in force.

PERFORM ACTIVITIES WITH TRANSPARENCY AND IN COMPLIANCE

With the laws and determinations of the supervisory and inspection bodies of the sector in which they operate.

CONSOLIDATE OUR REPUTATION AS A CUSTOMER-CENTERED

Avant-grade high-tech company, keeping it complete and solid, strengthening its corporate institutional image.

WORK ACCORDING

To the principles of moral and professional integrity.

CARE FOR THE BUSINESS AS THEIR OWN COMPANY

Taking responsibility, and be proactive.

ACT GUIDED BY THE PRINCIPLES OF FREEDOM OF INITIATIVE

And free competition, avoiding the adoption of practices that characterize unfair competition and/or unfair conditions, respecting the principles of the free market.

OUR TEAM BELIEVES IN STRENGTH IN DIVERSITY

Every person has a different perspective and valuable input to offer, whether it’s solving a problem or contributing to new ideas. Not understanding someone’s perspective does not mean that their view is incorrect.

REMEMBER TO KEEP THE FOCUS ON CREATIVE RESOLUTIONS AND CONTINUOUS LEARNING

The Manager has adopted the standards of conduct described above to create a work environment free from discrimination of any kind, including moral, sexual, or other types of harassment in the workplace.

RELATIONSHIP WITH THE MEDIA

The Manager sees in the media a relevant channel of information for the various segments of the business manager and is open to meeting their requests whenever possible, and there are no legal or strategic obstacles, which will be explained to journalists when they occur. The Manager’s representatives, before any means of communication, are exclusively its managing partners, indicated in the company’s article of incorporation, who may delegate this function whenever they, deem appropriate.

The other Employees may only provide information to third parties in general (including, but not limited to, matters related to the Manager’s activities), reporters, interviewers, or journalists with the express authorization of the Manager. Additionally, notwithstanding the foregoing, Employees must respect customers, competitors, suppliers, regulatory and governmental bodies.

This Code of Ethics (“the Code”) aims to establish the rules, principles, concepts and values that should guide the ethical standard of conduct of the Employees in their internal performance and with the financial and capital markets, as well as in their relations with the various investors and the general public.