CODE OF ETHICS

RESOURCES
HUMANS

P PLAN YOUR TR AB AJ O, Y LUEGO TRAB AJ A

ABOUT TUPLAN

S.A.

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 CODE OF ETHICS

CODE OF ETHICS

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 CODE OF ETHICS

Our Code of Ethics

Having the Code of Ethics of COMPU.COM S.A. in your hands is a fact.

very significant and important for those of us who are part of this Company, already
that the presentation of the rules that govern our daily work outlines the
act in each of our areas of work. Keeping in mind each
one of these rules means evaluating the way we conduct ourselves and live
our culture as individuals and as an organization.

The principles, norms, and values are the framework we use to determine
if an action is correct and is the ethical support of our behavior.
Taking the above into account, the Code of Ethics signifies the commitment of each
one of us for living and making live the guidelines that determine the way in
what we must proceed; more than a text, it is the document that marks the line for
to behave with integrity and thus reflect the culture of the Great Family
COMPU.COM S.A.

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 CODE OF ETHICS

PRESENTATION

This Code of Ethics aims to establish the principles of

our Corporate Culture, expanded basic structure,
supplemented and updated with all the personnel of the companies, to
the time that allows us to expand and clarify some points that we have
decided to develop in response to the comments and suggestions of
our collaborators.
Thus we arrive at the final text that we present and implement today.
formally. The Code of Ethics becomes the most important document
important in our actions and a source of pride for everyone
we
This is one more reason to be proud of Our Company.

OBJECTIVES OF THE CODE OF ETHICS

The Code of Ethics is the expression of our Company's commitment

to maintain the highest ethical standards in the performance of those who
they integrate it.

The Code recognizes and harmonizes moral principles, the Laws of

our country, the regulations applicable to our Company, and it spreads
with the conviction that all of us who collaborated in it, we have
acquired a conviction that allows us to commit to a
exemplary ethical conduct.

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 CODE OF ETHICS

OUR MISSION
COMPU.COM S.A. buying and selling of computers, our company
is dedicated to trade, to the service of innovation for the sector
commercial in Colombia. we use our knowledge to do so
provide good advice to our clients by fulfilling the
quality and safety standards for each of our clients

OUR VISION
COMPU.COM S.A. will have greater knowledge in 2028.
commercial sector being a company where the best is worked with
quality and thus providing reliability to our clients and thus being
recognized at the national and international level and to be competitive for
position the brand in the market by providing the best equipment
in computing under optimal conditions managing strategy and
innovating every technological design based on professionalism.

OUR VALUES ARE THE FOUNDATION OF OUR

MISSION.
HONESTY: it is the best presentation that our company will have to
our users have full assurance and confidence that they will be respected
both their computer equipment and their information.

RESPECT: it is the fundamental basis to guarantee our service to the user.

PERSEVERANCE: with great determination we will solve the needs of
our users in order to meet the objectives and goals we have set
fixed.
RESPONSIBILITY: to carry out tasks with diligence, seriousness, and caution;
A job well done and delivered on time is synonymous with responsibility.
thus ensuring compliance with the commitments made and generating trust
and tranquility among our users.
THANKS: your gratitude and the recognition of our company for your
Part, they are the best gifts we get from our users.

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SOCIAL RESPONSIBILITY
This responsibility represents doing our job well, reaffirming our
ethical values, fulfill the commitment to our clients and suppliers, respect
the current legislation and take care of natural resources and the environment.

EFFICIENCY
Efficiency means being austere, taking care of and using resources efficiently with
What we account for. Spend on what is necessary and avoid the useless and superfluous.

OUR BUSINESS ETHICAL PRINCIPLES

In the company, we direct all our activities towards compliance with

principles of:
Co-responsibility
Customer Service
Quality of our products and services
Development of our markets

CO-RESPONSIBILITY
It is the awareness that with our actions we project the image of everyone.

CUSTOMER SERVICE
Our clients are the fundamental reason for our activities. Attention to
they are essential to continue having your preference. Our clients must
to be attended to with respect, care and to seek their utmost satisfaction.

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 CODE OF ETHICS

QUALITY OF OUR PRODUCTS AND SERVICES

Our company guarantees that the products and services we offer comply
at 100% the standards to provide the best possible quality.

DEVELOPMENT OF OUR MARKETS

The Company has consolidated itself by participating in markets with the products and
services that are offered, this has led us to have a presence and to grow in various
plazas.

OUR CODE OF CONDUCT

In the company, we respect the Principles of Conduct:

Attachment to Established Norms
Integrity
Equity
Honesty
Attitude
Responsibility
ADHERENCE TO ESTABLISHED STANDARDS

All personal activity must be carried out in accordance with the rules and laws.
current regulations and policies.
INTEGRITY

It is the congruence between what we say and what we do, pretending in everything.
moment an ethical attitude. It is our interest to treat clients, suppliers,
shareholders, authorities, and employees in a respectful, cordial, and
collaboration always maintaining a professional relationship, seeking harmony between
individual and Company.

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EQUITY
Everyone deserves to be treated with dignity, regardless of their sex, age,
hierarchical level, personal conviction or any other circumstance or characteristic.

HONESTY
Being honest is to act with integrity and uprightness. This is a fundamental principle as
Company and individually. Therefore, at all times it must be provided
the customer the correct and complete information about the product features
or services that are offered.

ATTITUDE
Our actions should reflect the optimism and enthusiasm for doing our job well.
work. Being positive helps create a suitable environment in our relationships.

RESPONSIBILITY
Responsibility is the willingness to assume the consequences of decisions.
taking responsibility for one’s own actions. This makes us reliable and truthful.
in our actions.

DEPARTMENTAL PRINCIPLES

HUMAN RESOURCES

Those who work within the company are primarily people who have:
Ability to assess situations, suggest solutions, and make decisions.
Ability to be accountable for what one does, for what can be asked of them.

hold accountable for their developed activity.

The ability to treat others as he expects to be treated.

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BOSS
It is the staff with command and authority who must provide guidance for the work and delegate.
with responsibility and to take advantage of the benefits of teamwork.
The bosses are responsible for monitoring the existence of an adequate environment for
work to promote personal development so that their subordinates achieve
high levels of performance.
The executives in the Company are the highest representatives of our Values
Corporates and they are the ones who must, above all, respect, promote and ensure that their
act and those who form their work team adhere to the highest
ethical concepts.

EQUALS
Those who operate within the Company are people who have in common
denominator the one that shares the work-related concerns and objectives of a
act and grow as a team.

SUBORDINATION
Those who execute and achieve the objectives of the Company are under the
guidance and direction from a leader, and they understand the need and significance of taking action
and grow as a team.

COMMERCIAL

WITH THE CLIENTS

The decisive factor that leads a customer to choose one company over another is the
degree of trust that the company has generated for you over time, which
it is achieved:

Offering a kind deal and exemplary service.

Providing the information you require and request
Providing an honest and respectful treatment, which means fully complying
with what we have committed to.
Attending to your requests within the possibilities.

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 CODE OF ETHICS

WITH THE SUPPLIERS

Those acting within the Company should avoid that.
generate
or maintain a relationship (either personal or business) with all suppliers and
that may constitute a conflict of interest or even affect objective judgment
that should be issued.

FINANCE
WITH THE COMPANY

The efficiency we desire in the Company implies:

An effective and efficient administration.

A responsibility to the trust placed, understood as the

assignment and proper management of resources.

CODE OF ETHICS

The present Code provides the basic guidelines to assist all personnel
from the Company to make ethical decisions. It will never be excessive to state that all
Our decisions and actions must reflect our Mission and Values.
Company, and that behaving ethically can be critical to our success
in the current business world.

COMPLIANCE WITH THE LAW

We must fully comply with all current laws, rules, and regulations.
that are applicable to us.

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 CODE OF ETHICS

USE AND MANAGEMENT OF INFORMATION

The unauthorized disclosure of internal information is prohibited.

Company by any means except that required by the authorities, and this only
It may be provided by the areas and persons authorized by each director.

PRIVACY OF INFORMATION OF THOSE WHO ACT WITHIN THE

COMPANY

The Company retains only those data of individuals who act in the Company.
and that are indispensable for corporate, legal, or contractual reasons, and limits
access to such information only to authorized persons.

CLIENT AND SUPPLIER INFORMATION PRIVACY

The commercial dealings with Clients and Suppliers and the information about
its past, present or future operations and/or transactions may only be
used by the persons authorized by the Area Director.

CONFLICT OF INTERESTS
The conflict of interest arises primarily when the
interests of the Company, personal interests, and, where applicable, those of third parties.

There is an ethical duty: to refrain from accepting gifts, gratuities or

attentions that can create a commitment or for it to develop a
certain conduct to benefit a third party against policies and
Company interests.
Our external relationships must be carried out in accordance with our policies and
procedures, thus eliminating any situation that could become a
conflict of interests.

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 CODE OF ETHICS

It is not allowed and is considered an action contrary to the present, to motivate the
direct or indirect participation, through any legal relationship of the spouse,
relatives by blood or by marriage of those who act in the Company,
without express authorization from the General Directorate.

BUSINESS OPPORTUNITIES

No member of the Company can take advantage for themselves or for benefit
by any other person or organization, of the acts or activities that have been
developed, are being developed or will be developed in the future, due to
the operation of the Company, of which knowledge has been obtained due to
the assigned functions.
Likewise, those who act within the Company must refrain from obtaining,
use, copy, modify, or distribute reserved or confidential information, for the
obtaining personal benefits for oneself or for third parties.

INFORMATION, SYSTEMS, AND PROCEDURES THAT ARE CONSIDERED

AS PROPERTY OF THE COMPANY

All the information and documents contained in the software packages and in
general in the systems and processes generated and developed by those who act
within the Company are the exclusive property of the same and, therefore, are
it is considered reserved and confidential information, so there is a
absolute duty of secrecy.

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RESPONSIBILITY IN THE MANAGEMENT OF ASSETS AND RELATED RECORDS

The staff of our Company who is responsible for preparing reports

financial transactions must be carried out with fidelity and accuracy. Any
act or omission that results in the misinterpretation of information
financial.
COMPANY ASSETS

Any person who has access, use, power, or express authorization of

disposition of the Company's assets, as well as its records, merchandise,
cash, valuables, and restricted-use materials, is personally responsible for their
custody.
RULES ON POLITICAL ACTIVITIES

The company's funds may not be used personally or collectively for

purposes unrelated to those authorized by it.
Any type of proselytism is expressly prohibited in the centers.
of work and its surroundings, both during working hours and outside of the Company.

POLICIES ON COMPANY ASSETS

The Company's assets shall not be used for personal benefit or with
una resolutiva responsabilidad de quien los tiene a su cargo.
who uses them.

COMPUTING SYSTEMS
Computing systems are essential for the daily operation of the Company.
It is essential that the team, programs, and systems, as well as access,
processing and storage of the data should be adequately safeguarded
and used exclusively for the authorized purposes.

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 CODE OF ETHICS

Both the systems and programs such as email and voicemail are
goods for the service of the Company and may only be used for the purposes and
predetermined purposes by it.
1. No worker may install unauthorized programs on their computers.
institutional.
No modifications shall be made to the contracted software, except for the
adaptation for the better performance of the Company, previously authorized by the
Systems Area.
3. Unauthorized development of systems or programs should not be carried out.
4. The internal development of teams, systems, and computer programs, by
from the employees, for the planning and execution of the Company's activities,
they are the property of it.

CONDUCTS THAT MAY CONSTITUTE A CRIME

HERITAGE
Any act or omission that may constitute a property crime against the
Company must be reported, identified, and investigated.

CONSUMPTION OF ALCOHOLIC BEVERAGES, DRUGS, AND NARCOTICS

The company strictly prohibits its employees from consuming, possessing, selling,
attempt to sell, transport, distribute, or manufacture drugs or any other
another controlled substance, regardless of the quantity or the way it is, as long as
develop activities during work hours and are within the
installations, or of the Company's vehicles.

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ENVIRONMENT

The Company is strongly committed to the protection and preservation of

environment. All employees of the Company must comply with the
legal provisions in this regard, whether local, state or federal.

THREATS AND VIOLENCE IN THE WORKPLACE

Physical violence or threats in the workplace must be reported and
attended to immediately and in accordance with the respective procedures.
The company prohibits the possession of any type of weapon in the workplace.

HARASSMENT OF AUTHORITY OR SEXUAL

Under no circumstances may a boss or superior who delegates demand from

a subordinate the execution of actions of others for which they have been
hired; hence the prohibition of exercising any kind of pressure to
to force or incite an employee to perform a certain act that does not
corresponds with its functions and job description. It is prohibited for
anyone who acts within the Company, harassing any other who acts
within the Company for the establishment of a personal relationship.

ETHICS COMMITTEE
It is the body designated by the Board of Directors of the Company in charge

1.Establish the ethical conduct and guideline policies.

2. It will monitor compliance with this Code of Ethics and the policies.
established by him.
3. Sanction the violations of the provisions mentioned above in terms
of the internal work regulations corresponding.

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DECALOGUE

1. Keep our Vision and Mission as a guide for the Company's actions.
Promote and respect our Corporate Values and Ethical Principles.
3. Conduct our activities in accordance with our Principles of Conduct and
Departmental Principles.
4. Seek customer satisfaction with our products and services.
5. Maintain a professional and respectful relationship with our suppliers,
making decisions based on the merits of the offered product or service.
6. Take care of and make proper use of the assets and resources of our Company.
7. Respect the laws, norms, and regulations.
8. Avoid establishing relationships that involve a conflict of interest.
9. Safeguard the confidential information of our Clients, Suppliers, and
Employees.
10. Actively participate in the dissemination and compliance with the Code of Ethics.

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INDEX
3 OUR CODE OF ETHICS.
4 PRESENTATION.
4 OBJECTIVES OF THE CODE OF ETHICS.
5 OUR MISSION.
5 OUR VISION.
6 OUR VALUES.
7 OUR BUSINESS ETHICAL PRINCIPLES.
8 OUR CODE OF CONDUCT.
9 DEPARTMENTAL PRINCIPLES.
10COMMERCIAL.
11COMPLIANCE WITH THE LAW.
USE AND MANAGEMENT OF INFORMATION.
CONFLICT OF INTERESTS.
12 BUSINESS OPPORTUNITIES.
INFORMATION, SYSTEMS, AND PROCEDURES THAT ARE CONSIDERED
AS PROPERTY OF THE COMPANY.
RESPONSIBILITY IN THE MANAGEMENT OF ASSETS AND RELATED RECORDS.
13 RULES ON POLITICAL ACTIVITIES.
13 POLICIES ON COMPANY ASSETS.
14COMPUTER SYSTEMS.
14 CONDUCTS THAT MAY CONSTITUTE PROPERTY OFFENSE.
15CONSUMPTION OF ALCOHOLIC BEVERAGES, DRUGS, AND STIMULANTS.

15ENVIRONMENT.
15Threats and Violence in the Workplace.
15 HARASSMENT OF OFFICE OR SEXUAL.

ETHICS COMMITTEE.
18DECALOGUE.
19ACUSE OF LETTER OF ADHESION.

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LETTER OF ADHESION

NOMBRE
employee_number
COMPANY:
AREA:
POSITION:
OFFICE PHONE:

I have read, accepted, and commit to respecting the Code of Ethics of our
Company. I understand that violating its precepts results in disciplinary action.
that may lead to the termination of my Employment Contract. I will also submit my
better effort to promote the corporate values of the Company.

FIRM

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ACKNOWLEDGMENT OF LETTER OF ADHESION

NOMBRE
EMPLOYEE NO.
COMPANY:
AREA:
POSITION:
OFFICE PHONE:

I have read, accept, and commit to respecting the Code of Ethics of our
Company. I understand that the violation of its precepts results in disciplinary action.
that may lead to the termination of my Employment Contract. Likewise, I will put my
better commitment to promoting the corporate values of the Company.

SIGNATURE

Please deliver to the Management of your Unit or to the Human Resources Department.
Humans.

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