1. Objectives

This Code of Ethics includes the conduct guidelines and ethical principles that must be followed in the decisions, actions and communications of Dicsys in the exercise of its activity, without prejudice to the specific regulations pertaining to the companies and institutions that comprise it. The objectives are:

• Establish the behavior guidelines and ethical principles that govern Dicsys.
• Encourage all relationships to be developed within an ethical and transparent framework.
• Ensure dignity, privacy, equity and respectful and harmonious coexistence.
• Define responsibilities and commitments to stakeholders within the framework of compliance with this Code of Ethics.

2. Scope

This Code of Ethics applies to members of Senior Management and all Dicsys employees. It must always be kept in mind in relationships with associates/clients, suppliers, consultants, government entities and all sectors of the community with whom we interact. All those mentioned above have the responsibility to familiarize themselves with the provisions of this Code and commit to its compliance.

New situations arising from business dynamics and the general environment will be incorporated into this Code as necessary.

This Code of Ethics will be governed based on compliance with local law and international regulations, including:

• The International Bill of Human Rights, formed by the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and its two protocols, and the International Covenant on Economic, Social and Cultural Rights.
• The Declaration of the International Labour Organization on Fundamental Principles and Rights at Work.
• The United Nations Global Compact.
• United Nations instruments and principles aimed at gender equality, diversity, inclusion and elimination of all forms of discrimination, including the Women's Empowerment Principles.
• The Guiding Principles on Business and Human Rights: Implementing the United Nations "Protect, Respect and Remedy" Framework.
• The Children's Rights and Business Principles Guide (UNICEF, Global Compact and Save the Children).
• The 17 Sustainable Development Goals and their 2030 targets (United Nations).
• Law 27.401 on Criminal Liability of Legal Entities.

3. Development

3.2. Conduct guidelines – ethical principles

Respect and trust are the foundation of all relationships. For this reason, Dicsys, based on respect for the individual and trust in its stakeholders, is especially concerned with the dignity and privacy of each of them.

The reasonableness in the provision of the regulatory framework for desirable behaviors and the application of sanctions to those who transgress them, account for Dicsys' responsibility and its commitment to respectful and harmonious coexistence.

That is why our company is obliged to respect and promote the ethical guidelines set forth below.

3.2.1. General considerations

• Comply with tasks in accordance with laws, regulations, procedures and standards applicable to the company. The legality and legitimacy of acts will be taken into account.
• Maintain an attitude of respect and collaboration with natural or legal persons with whom one interacts.
• Develop tasks considering criteria of suitability, equity, transparency, honesty, respect for others and the dignity of work, and a responsible attitude in their actions.
• Respect ethnic, religious, age, opinion, sex, sexual orientation, gender identity and disability diversity.
• Promote equal opportunities and social inclusion.
• Keep confidential company information under reserve. Influences or resources assigned to personnel by virtue of their positions shall not be used, directly or indirectly, for their own benefit or that of third parties.
• Maintain objectivity in decision-making, always keeping in mind the interest and benefit of the company.
• Seek the best result for the company, defending its interests and patrimonial integrity, always maintaining a proactive, professional attitude of respect and collaboration with those who interact.
• Do not issue opinions on public matters on behalf of Dicsys, except with express authorization from the corresponding authority.
• Collaborate with actions aimed at compliance with this Code of Ethics.

3.2.2. Human Rights

• Comply with the Universal Declaration of Human Rights, Children's Rights and Business Principles and not be complicit in abuses of the aforementioned rights and principles, nor establish formal or informal interactions with organizations that commit them.
• Ensure that employees, associates, clients, stakeholders, members, or anyone with whom one is linked are not discriminated against.
• Raise awareness about respect for human rights.

3.2.3. Labor practices

• Comply with working conditions according to national laws and regulations.
• Provide decent working conditions regarding wages, working hours, vacations, health and safety.
• Ensure equal opportunities for all employees.
• Promote skills development and opportunities for professional advancement for all employees.
• Respect workers' right to free collective association.
• Protect the privacy and personal data of employees.

3.2.4. Staff relations

• There must be no discrimination in the workplace. All workers enjoy equal opportunities and treatment, regardless of their ethnic, religious, age, opinion, sex, sexual orientation or particular abilities.
• Act courteously, with availability and attention to all people with whom one interacts, respecting individual differences.
• Be loyal to the people with whom tasks are developed and recognize the merits of the work done by them.
• Do not harm the reputation of any Dicsys member through preconceptions, false testimony, destructive criticism, unfounded information, or in any other way.
• Report any type of harassment or bullying inside and outside the workplace and do not participate in such actions.

3.2.5. Community participation and development

• Promote participation in organizations close to its operations, with the objective of contributing to the public good and the development objectives of communities, generating value with the activity and knowledge that the company possesses.
• Maintain transparent relationships with government officials at all levels.
• Encourage participation in volunteer services for the benefit of the community.

3.2.6. Use of assets and information

• Dicsys assets, facilities and IT resources are used solely to fulfill the tasks assigned to each employee. Criteria of integrity, rationality and effectiveness must be applied.
• All information known in the development of work/business activity is confidential in relation to third parties, even if it has not been classified as reserved. Personnel must maintain the confidentiality of information accessed in the development of work performed at the company and not comment on or deliver it to third parties outside Dicsys who are not duly authorized.
• The Collaborator acknowledges that the use of free, open or third-party AI tools (for example, ChatGPT, Gemini, Copilot, Claude, Perplexity, among others) may involve risks of exposure or involuntary transfer of confidential information, therefore expressly commits to: not enter, upload, copy, transcribe or describe client information, projects or internal Dicsys processes on free or open AI platforms. Additionally, to use such tools only for support or general reference purposes, without including sensitive data, client names, proprietary code fragments or protected information.
• Do not share identification and access elements to Dicsys IT platforms.
• Do not use confidential data for one's own benefit or that of third parties, contrary to laws or in a manner detrimental to Dicsys' interests.
• Do not use or invoke the company to obtain personal benefits.
• Protect and preserve company information and assets, as well as their proper use to contribute to achieving business objectives and not for personal benefits.
• Do not engage in activities that go against the company's interests and that may affect Dicsys' assets or reputation.
• Do not participate in actions that generate unfair competition and avoid comments or statements that unjustifiably harm the image and reputation of competitors.
• Provide collaboration in activities arranged by Dicsys for the review, audit, access and control of information processed or stored on equipment or technological devices owned by the Company.

3.2.7. Client relations

Dicsys has as its premise to satisfy the needs and expectations of its clients with maximum efficiency, through optimal resource management and continuous process improvement. Under these guidelines, differential and highly valued services are obtained for clients, therefore:

• Provide products and services that are safe for users and other people, for their property and for the environment.
• Do not engage in confusing, fraudulent or unfair practices when communicating with clients. Ensure that marketing and advertising actions respect the rights and guiding principles set forth in this code.
• Offer customer service, analyzing claims and resolving conflicts.
• Protect and not disclose, under any aspect, clients' personal data, both outside the company and among coworkers.

3.2.8. Conflict of interest

Conflict of interest shall be understood as: "the incompatibility that is verified in any act or negotiation between Dicsys and a third party, when between the latter and the employee who in any way participates in the act or negotiation, there are relationships of kinship or affection up to the third degree of consanguinity or affinity, that reasonably allow presuming their lack of independence or impartiality". The recipients of this document will warn and avoid, with due diligence, incurring in direct or indirect, current or potential conflict of interest with those of Dicsys, and if the conflict manifests or in case of doubt, they must inform the Ethics Committee, refraining from making decisions related to the matter in question.

The individual decision to participate in associations of any kind or to assume public positions must be accepted as long as it does not derive a conflict of interest with Dicsys, or does not interfere with the activities that the employee develops in it.

3.2.9. Relations with suppliers, intermediaries and business partners

• The selection, contracting or linking with suppliers, intermediaries and business partners must always be based on technical, professional, ethical criteria and Dicsys' needs, and must be conducted through Dicsys' corresponding procedures.
• Relate to suppliers of goods and services, intermediaries and business partners in an ethical and lawful manner.
• Select only suppliers, intermediaries and business partners whose business practices respect human dignity, do not violate the law and do not endanger the company's reputation.
• Link with suppliers, intermediaries and business partners based on suitability and real and concrete valuation of their products or services, sustainability of their processes, respect for labor human rights and the environment, as well as their price, delivery conditions and quality, not accepting gifts or commissions, in money or in kind, that may alter the rules of free competition in the production and distribution of goods and services. Courtesy gifts of symbolic value or advertising character are excepted.
• Inform your direct superior about any situation of receiving gifts, invitations or other benefits for corresponding analysis and approval.
• The application of policies contrary to this Code of Ethics by a supplier, intermediary or business partner will enable the application of measures that may include the discontinuation of the relationship established with them.

3.2.10. Prevention of money laundering and terrorism financing

Dicsys is committed to the international fight against money laundering and the financing of terrorist activities, and, consequently, against any conduct that has the purpose of providing support or promoting these crimes. Therefore:

• Collaborate in the identification and prevention of situations that facilitate money laundering and/or terrorism financing.
• Have full knowledge and be updated regarding relevant restrictive measures adopted by local Governments and international organizations against certain countries, persons, assets or services.

3.2.11. Fraud

• Collaborate in the identification and prevention of situations that facilitate fraud.
• Under no circumstances participate in or promote fraud.
• Comply with all current provisions on the matter.
• Keep and maintain accounting and financial books and records with accuracy and honesty, so as to allow obtaining information and making decisions on integral bases.

3.2.12. Anti-corruption

Dicsys maintains a zero tolerance policy towards corruption in all its forms, including bribery and graft. Therefore, it commits to:

• Train and support employees and other related stakeholders in the development of ethical and transparent behaviors.
• Have some form of anonymous reporting channel that receives communications of possible violations of the provisions of this Code of Ethics. These reports will be analyzed and managed by the Dicsys Ethics Committee.
• Promote responsibility and transparency in all relationship processes with the different actors with whom it is linked.
• Not give or obtain undue advantages or benefits of any kind and not participate, order, authorize, induce or assist anyone in practices of corruption, bribery or extortion, either directly or through a third party.
• It is prohibited to promise or grant gifts in cash or in kind to public officials of any jurisdiction of the National, Subnational State and/or Dicsys' area of operation. Courtesy gifts of symbolic value or advertising character are excepted.

3.2.13. Relations with the public sector and officials

Do not make any type of contribution, payment or offer of any object of value to government officials, political parties or candidates to obtain or retain business, nor can such acts be replaced by donations or sponsorship.

Any contribution to political parties may only be made in strict compliance with applicable laws and regulatory standards, and with prior authorization from the Ethics Committee.

In the event that any employee acquires the status of Government official or Politically Exposed Person, they must inform Dicsys of the aforementioned circumstance.

3.2.14. Due Diligence

Within the framework of the execution of due diligence processes carried out by third parties, Dicsys commits to:

• Collaborate in good faith in sending all information and/or documentation that is required.
• Ensure the veracity, integrity and reliability of the information and/or documentation presented.
• Notify any relevant change in its organizational structure, corporate composition or main management officers, in case such information is part of the evaluation requirements.
• Guarantee that shared information is delivered in accordance with applicable confidentiality and data protection regulations.
• Act with total transparency and ethical commitment throughout the process.

3.3. Ethics Committee

Dicsys has an Ethics Committee that is responsible for enforcing the provisions of this Code and therefore makes it known and establishes the appropriate mechanisms to guarantee its application. The Committee is composed of Directors and the Human Resources leader. It holds quarterly meetings with the objective of ensuring proper compliance with this Code of Ethics.

3.4. Ethics Line

This line functions as a confidential channel for reporting unethical conduct, or conduct contrary to this Code. It is the responsibility of all those covered by this Code of Ethics to report situations that represent a failure to comply with it. The confidentiality of case details and persons involved will be maintained throughout the investigation. Under no circumstances will the identity of the whistleblower be disclosed.

Link: https://es.surveymonkey.com/r/NSW7CR7

3.5. Compliance with Code of Ethics standards

All Dicsys members have the responsibility to familiarize themselves with the provisions of this Code and commit to its compliance. The Ethics Committee and the Board of Directors as appropriate must guarantee its implementation.

Any violation of the Code of Ethics or Dicsys' internal guidelines may result in the application of disciplinary measures depending on the severity of the violation, or even administrative, civil or criminal sanctions.