OBJECTIVE
The objective of this policy is to foster an environment of transparency, integrity, and ethics within CHECOREPUESTOS S.A.S. This policy establishes the procedures for reporting illegal, immoral, or unethical activities related to the Transparency and Business Ethics Program (PTEE), as well as measures to protect whistleblowers against retaliation and/or any type of risk to their occupational, physical, or emotional integrity, or different types of threats within the company.

SCOPE
This policy applies to all employees, contractors, suppliers, and third parties that maintain a business relationship with CHECOREPUESTOS S.A.S.

TERMS AND DEFINITIONS

Abuse of duties: the performance or omission of an act by an employee in the performance of their duties, with the aim of obtaining an improper benefit for themselves or another person or entity.

Corruption: any action or omission committed by an employee in the performance of their duties to obtain undue advantages of any kind, for themselves or a third party.

Whistleblower: any person who files a complaint about behavior that violates the PTEE, or illegal, immoral, or unethical activities within the organization.

Recipient of the complaint: a person designated to receive and manage complaints filed by employees.

Illicit enrichment: a significant increase in an employee's assets compared to his or her legitimate income that cannot be reasonably justified by him or her.

Hostility: any intentional action or omission, regardless of who is responsible, that may cause harm or damage to the whistleblower.

Embezzlement: the misappropriation or other forms of misappropriation by an employee, for their own benefit or that of third parties or other entities, of public or private assets, funds, securities, or any other thing of value entrusted to them by virtue of their position.

Protective measures: a set of measures aimed at protecting the exercise of the personal and labor rights of whistleblowers and witnesses of illegal or irregular actions.

Protected person: a whistleblower or witness of an illegal or irregular action who has been granted protective measures to guarantee the exercise of their personal and labor rights.

Retaliation: any harmful measure, direct or indirect, against a person who has reported any illegal or irregular action or provided information about it.

Witness: any person who has relevant information about illegal or irregular actions and is willing to cooperate by giving testimony or providing evidence relevant to the investigation, prosecution, or sentencing of those responsible for such actions.

REPORTING PROCESS 
The channel provided by the company is the compliance officer's inbox oficialcumplimiento@checorepuestos.com

GENERAL POLICIES

• Complaints will be treated confidentially, and to the extent possible, the anonymity of the complainant will be maintained. CHECOREPUESTOS S.A.S. will make reasonable efforts to protect the identity of the complainant and maintain the confidentiality of the complaint. Therefore, disclosure of the complainant's identity without their consent is prohibited, except in cases where it is necessary to conduct a proper investigation.

• The necessary requirements to initiate an investigation are:

• Nature of the complaint
• Description of the facts
• People involved
• Documents and evidence
  
  

• When all internal and external information sources have been exhausted and the complaint remains unfounded, it will be dismissed and closed.

• CHECOREPUESTOS S.A.S. does not accept any form of retaliation against a whistleblower as a result of filing a complaint. If confirmed, appropriate action will be taken against any individual who retaliates against a whistleblower.

• CHECOREPUESTOS S.A.S. delegates to the Compliance Officer, Administrative and Financial Department, who will be responsible for investigating all complaints received in an impartial and objective manner. Whenever possible, information and/or results will be provided regarding the status of the complaint filed by the whistleblower, as long as this is feasible.

• All CHECOREPUESTOS S.A.S. employees must comply with this policy, accepting their duties and rights and the tools available to them to report any anomalies when necessary.

• This policy will be publicly available within the organization and, if appropriate, outside of it, as a demonstration of its commitment to transparency and integrity.

Code: A-PO-0003

Version: 0.0

Effective date: 01/01/2025