Transparency Policy

TRANSPARENCY POLICY

I. Scope of Application
It is expected that all members of the Firm comply with this Policy, proactively avoiding all practices that contravene moral and ethical principles. Partners support the internal programs of the Firm in order to detect and avoid acts of
corruption.

II. Fundamental Principles
Almeida Guzman & Asociados prohibits all types of acts of corruption. Members of the Firm and any related third party acting for or on its behalf cannot: *offer, *carry out, *promise, *authorize or *accept, directly or indirectly, any payment or “object of value” to/from another person, including government officials, with the aim of influencing, inducing or rewarding an action, omission or decision, to obtain an unfair advantage or to receive or hinder business.

The Firm has implemented a zero tolerance policy with respect to acts of corruption.

III. Due Diligence
It is expected that all members of the Firm will exercise due diligence with respect to third parties, and shall identify unusual circumstances prior to contracting said third party or rendering services to such. The partners are liable for knowing whom the Firm maintains professional relationships with.