Code of ethics and conduct

ETICAL COMMEITMENT.

At FINART S.A.S., we believe that each person has the power to make their dreams come true. Assuming that power means recognizing our actions and decisions have an effect on our environment and, we depend on this positive sea.

To achieve this, it is important to recognize the ethical behavior guidelines that guide and ensure our relationships are based on respect, that our employees feel more united to us, that our consumers favor us with their preference and, above all, that we feel the pride of create development opportunities and contribute to the advancement of society.

Our Code of Ethics will guide us on this path. This contains our purpose, values, principles of leadership and ethical behavior to which we commit ourselves in FINART S.A.S.

Let's show by example that we can contribute to a better world.

Sincerely,

Mauricio Romero General Manager.

SUCCESS PACKAGE: OUR VERTEBRAL COLUMN


Our success package identifies us as people and as a company; It is the necessary reference for the work we do to bring our purpose to life. This represents what makes us special, but also allows us to evolve to be better and better.

PURPOSE:
Our essence and rationale is to increase self-esteem through our products.

DREAM:
Our compass towards the right path: In 2020, be the No. 1 in sales generating relationships of transparency and trust; opportunity capture; strengthening our knowledge, processes and organizational culture.

MISSION:
More than fine jewelry, in everything with our actions we generate our interest groups, experiences of luxury and value.

LEADERSHIP VALUES AND PRINCIPLES:
Our culture- What defines us.

We are passionate:

I build on the difference. I put my skills and knowledge at the service of others.

Weare close:

I put myself in the place of the other. I understand how what I do impacts others and the organization.

We are Entrepreneurs:

I communicate my ideas in an inspiring way to influence others. I am persevering and resilient.

We are Authentic:

I recognize my reality and that of the environment. I speak with the truth. I am consistent between what I think, say and do.

The success package is a powerful tool for the company's growth only if it is introduced into the culture and is led by everyone day by day. Our challenge as team leaders and leaders of our own being, is to give life with our example and actions inside and outside Finart. That is why we define four leadership principles that will help us clearly recognize how we should work and guide our teams and ourselves:

Imagine the Extraordinary:

It is growth mindset. Conviction to win, creating new possibilities to grow the business.

Focus the Energy:

It is focus on action. Prioritize critical issues, with a sense of urgency in decision making.

Unleash the Potencial:

It is talent development. Build teams through challenges that challenge their skills.

Honor your Commitments:

It is commitment. Always look for the highest performance assuming responsibility for the result.

OBJECTIVE:



Our Code of Ethics establishes the principles of behavior that should guide our actions as part of FINART and that will lead us to maintain strong relationships based on ethical conduct.

It is our responsibility and commitment to ensure compliance and set an example with our actions, as well as to inform about any ethical fault we are aware of.

We build relationships based on respect and trust with all our stakeholders:

Collaborators 2. Consumers 3. Suppliers 5. Society 6. State

SCOPE:



This code is mandatory for all employees linked to FINART at all hierarchical levels and, we welcome it as a frame of reference in each of our interactions. Here, the performance criteria of the directors, administrators and collaborators of FINART are defined so that the decisions adopted are consistent with our vision and mission. The axis of the attitudes and behaviors promoted by this Code, is the integrity understood as the determined way of being, thinking, speaking and acting in a straight, honest and faultless way, based on the conviction that without it it would not be possible to have the trust of our customers, suppliers and the environment in general.

tasks assigned to the collaborator as part of their duties. Everyone is responsible for the care of the assets they use or supervise and should avoid inappropriate uses. The same is established for the use of tools and media of the Company.

We protect company information. Information is a very valuable asset and must be managed with absolute reserve. It is everyone's responsibility to maintain confidentiality and ensure the care of the information at their disposal. If necessary, when exchanging information with third parties, we must commit them to respect its confidentiality. Similarly, all third party information shared with us must be treated with due confidentiality.

We guarantee work facilities. We provide safe and comfortable facilities that offer optimal conditions in an adequate working environment.

We reject any form of abuse, including all types of harassment. We do not accept any form of forced labor or exploitation because we believe above all in respect for the dignity of the human being. Likewise, we speak out against child labor.

Public statement on behalf of FINART. Each public statement on behalf of FINART will be made exclusively by authorized spokespersons and validated by the general management. Any collaborator who, due to the performance of a personal activity, becomes a public figure and makes statements in reference to said activity, will do so in a personal capacity. Each employee represents the company in any deal that it establishes on a personal or professional level. You must ensure at all times that FINART's reputation and prestige are not damaged due to improper conduct or communication. Our relationship with public authorities: The relationship of FINART and its collaborators with public authorities will always be within the framework of our institutional values, subject to the highest transparency and collaboration protocols. Our interaction with any public authority will always be from the legality and with the greatest commitment to collaborate with the functions of public authorities. Legal compliance: FINART is committed to compliance with all legal and regulatory provisions that establish the minimum floor that must be observed for the formal employment of its employees.

Merits and capabilities of employees: FINART appreciates and values the technical, human and professional capabilities of its employees, firmly believing that the best professionals are the most relevant assets of any organization. Therefore, we have a thorough study for the allocation of salaries and structured benefits based on the technical and human techniques of its employees. As a result of the constant evaluations FINART may hire former employees who have been disconnected for reasons beyond their performance and who have determined that they are people who live this code of ethics and each of the principles and values of the company.

Working day: The working day of the employees of the company is established under the limits of the current labor regulation, with respect and protection of the rights of each of the employees, so that the maximum working day will be 48 Weekly hours and 8 hours per day, distributed at specific schedules by FINART according to the needs of the operation, always ensuring the satisfaction of our consumer and the well-being of all employees. Overtime is voluntary for employees.

Free association: We respect and support the freedom of association of our collaborators, to join and form groups, associations or organizations provided they have legitimate objectives. FINART supports its collaborators in order to maintain relationships harmonious work based on an open and constructive dialogue.

Recruitment of former third parties: We faithfully comply with the commercial agreements with each of our suppliers, therefore, FINART refrains from hiring former third parties who have had relationships with suppliers in our business chain provided that such stipulation has existed in the relationship commercial.

CONSUMERS:
Our reason for being.

We know our consumers deeply. We consider your needs and expectations in the creation of our products. Our brands consider the consumer the focus of their actions.

Ensuring the quality of our products is one of our main responsibilities. We care about the safety of our consumers and we are characterized by offering products and services of excellent quality, which are constantly evaluated in order to maintain their quality over time.

We offer truthful information about the products. In each of the communications addressed to the customer and final consumer, we transparently communicate the qualities and restrictions or precautions of use of our products.

We know the latest trends. We know the scientific and technological trends in order to be at the forefront of our product portfolio. We promote innovation as a growth engine.

We respect intellectual property. We recognize our property rights in the brands and products created and produced by FINART and by third parties who have trusted us and have developed business options with FINART.

We believe in fair competition. We reject all kinds of practices that can be considered unethical with our competition.

SUPPLIERS:
We grow with them.

Our suppliers are a fundamental part of the business. We establish with them positive relationships that mean in the growth of your business along with ours as they are our business partners.

Every provider must be aligned. The principles established in this Code are applicable to suppliers, who must show at all times ethical conduct and respect for the rights of their employees.

We maintain a transparent relationship with the supplier and the customer. This allows us to establish relationships of trust and generate positive feedback that helps strengthen the relationship for the benefit of both parties.

We have confidentiality agreements respected by both parties in cases deemed necessary. This with the purpose of protecting our intellectual property, as well as that of the provider.

We avoid any type of interference in the business relationship we establish with our suppliers. We do not accept or offer gifts, gratuities, favors or anything of value from current or potential suppliers that influence decision making.

SOCIETY:
We contribute to a better world.

Our aspiration is to contribute to a better world. FINART seeks to leave a mark on every action it performs. From our beginnings we have generated a positive social impact by offering each one of its stakeholders the opportunity to have a space for personal development and to transform their lives.

We are positive actors in the development of the society in which we work by promoting among our collaborators a philosophy of supportive and respectful citizens of Human Rights. Collaborators who strive to make their actions have positive effects, have the ideas, beliefs and expectations of the people with whom they relate.

We believe in the imagination, synergy and trust we build in our relationships to achieve our purpose and contribute to the progress of society. In FINART the extraordinary is in you.

We respect Human Rights: We carry out all our operations in a framework of respect and promotion of human rights. We reject that any of our stakeholders directly carry out or act as accomplices of practices that violate human rights.

Our values and principles guide each of our actions, even above those specifically established by law. This in order to generate and maintain ethical and sustainable relationships with our stakeholders. Know the legal requirements that regulate the production and limitations of our products. If there is any doubt, we seek the corresponding advice.

Our donation policy: The company may receive applications or evaluate projects to make donations to entities and individuals that collaborate in projects and activities of social utility to the community. Donations always require the purpose of improving the quality of life of the community. Donations that exceed 50 SMLVM will request to be processed by public deed by notarial authorization. All donations will be approved by senior management of the company.

Donations to political campaigns: The company does not make donations in any way to campaigns or political parties without prejudice to its shareholders may participate in personal titles without implying that they act on behalf of the company.

STATE:
Respect for the law.

Our corporate values and principles guide each of our actions, even above the standards established by law. This in order to generate and maintain ethical and sustainable relationships with our stakeholders.

At FINART, we respond in a timely manner to all legitimate requests for information from regulatory and government authorities, respecting their regular conduct.

At FINART we promote compliance with the Anti-Corruption laws, we know that it is prohibited to promise, offer, compromise, pay, lend or give anything of value to a public and / or private official directly or indirectly through third parties, in order to obtain a benefit In return.

COMPLIANCE AND GOOD CORPORATE GOVERNANCE:
We communicate with transparency.

We promote responsible autonomy in the development of the functions of our collaborators. FINART's culture is based on the close, authentic, passionate and entrepreneurial behavior of each one, in this sense, employees are expected to perform their duties in a self-regulated manner.

At FINART, leaders are responsible, for inspiring action, honoring and living the purpose.

Each collaborator must ensure that institutional communication is carried out in a coordinated manner, is effectively managed and inaccurate information is not transmitted.

We are careful with the management of financial resources, we strictly comply with the procedures established for the correct use of the company's assets in an ethical and transparent manner. All expenses must be duly supported and documented.

Each employee is responsible for informing and complying with the internal policies of the corporation, their ignorance does not exempt them from complying with them.

In FINART, institutional decisions are made in compliance with the international Good Corporate Governance practices.

At FINART we commit ourselves to take the necessary measures to not facilitate the crime of Money Laundering. In this sense, we are all in the absolute obligation to comply with the current guidelines regarding the prevention and laundering of assets of the corporation.

It is prohibited to modify or falsify documents, records and accounting reports, as well as to hide information that may alter the financial records and affect or may affect the corporation.

CORRUPTION, BRIBE AND EXTORSION:
Total commitment against any act of corruption.

Senior Management Commitment In developing its commitment of non-tolerance against any act of corruption, including national and transnational bribery or extortion, the Company performs all actions to ensure full compliance with the regulations aimed at prevention of national and transnational bribery.

MONEY LAUNDERING AND TERRORISM FINANCING
. Preventión y detectión.

FINART in the development of its commercial and contractual activities with collaborators, contractors, suppliers and other related third parties, has decided to develop and implement LA / FT risk prevention and management policies in accordance with the applicable Colombian regulations, carrying out due diligence and documentation processes to prevent the company's relationship in any way and in any area with the risks of money laundering and terrorist financing.

BEHAVIOR MANAGEMENT:


You agree that our workers are the pillar of FINART, then the rules of conduct to which all our employees must submit at all hierarchical levels are recorded: FINART Regulatory Compliance and therefore its employees, abide by the laws, regulations and standards of regulation where it has a presence, which is why its collaborators should tend for their knowledge, without it representing a detailed knowledge of the rules, but a general knowledge.

Regardless of the position or position developed by the collaborator, adequate and correct behavior is expected, consistent with the principles and values of our company and the good practices and customs that contribute to the fulfillment of the mission, vision and objectives of FINART. In no case is the offer of benefits or bribes allowed to any person, institution for the fulfillment of the objectives of the operation.

If you have concerns about the application or interpretation of the rules, they can be consulted with the Human Resources Department of FINART.

Commitments (duties) and responsibilities

All FINART employees must fulfill the following commitments, in addition to those described in the internal regulations:

✓ Report and inform in a comprehensive and immediate manner to your immediate boss and / or ethics committee any moral or bad faith act or incident of which you have knowledge that affects FINART and / or its staff.

✓ Keep complete reservations about operations, business, and business procedures, or any kind of data about FINART that you know by reason of your functions or your relationships with it.

✓ Promote an environment of mutual respect and comply with relevant laws, policies, regulations and regulations.

✓ Be promoters of the values and principles of FINART, and set an example of the behaviors and practices that are promoted in this Code.

✓ Request the pertinent clarifications in case of doubt regarding possible situations that violate the Code.

✓ Promote teamwork and support between units and areas of the organization, in order to share knowledge, experience and the best of themselves.

✓ Communicate opportunely and responsibly ideas, concerns, and / or constructive comments to FINART, which make the processes more efficient and effective.

✓ Avoid unfounded judgments of other people.

✓ Request feedback, know how to listen to it and use it as a means to improve.

✓ Give constructive feedback when appropriate, and with honesty and objectivity, describe more than evaluate and suggest alternatives to improve. ✓ Recognize the good work of others and express it in a timely manner.

✓ Comply with assigned responsibilities in a consistent, honest and responsible manner.

✓ Project with the good example, the image of the company, inside and outside the facilities.

✓ Promote open communication and appropriate channels for effective feedback.

✓ Collaborate in the development of audits and / or fraud investigations that may arise.

Rights.

All FINART employees have the right to:

✓ Have a healthy work environment in which principles and values are fostered, as well as healthy competition and professional growth.

✓ FINART must protect the environment and the occupational and health of its employees.

✓ Participate in the training and training developed by FINART.

✓ FINART is open to receive the ideas, concerns and / or constructive comments of its collaborators, in order to make the processes more efficient and effective.

✓ Be recognized for the good work developed.

✓ FINART must constructively feed back the performance of its employees, so that they can improve. ✓ Be heard in disclaimers, being able to defend against the charges assigned.

Behaviors that are not accepted.

The following is a list of behaviors and are not exclusive:

✓ Report information that does not correspond to the reality of the company's operation.

✓ Illegal retention of resources of the organization.

✓ Unauthorized access to information systems.

✓ All others covered by this code and contemplate the internal regulations of the company.

ETHICS AND CARE LINE COMMITTEE


The Ethics Committee:

The company has an Ethics Committee made up of several members from the different areas of the business group to which it belongs in order to deal with all ethical issues and ethical complaints related to the operation of the company, in a transparent manner. Therefore, the Ethics Committee will meet periodically to evaluate all ethical issues within its competence and thus ensure compliance with the company's ethical commitment embodied in this document. The committee will be responsible for documenting all processes and actions related to the fulfillment of the company's ethical commitments.

Service and Report Line:

The Company has a line or channel of attention and report of all the behaviors or acts that imply a breach of any of the ethical commitments included in this Code which will be available to any collaborator, supplier or customer. The mentioned channel provided for this purpose is the following email address: porunmejorfinart@finartsa.com. The reports and requests received by this means will be attended as a priority by the Ethics Committee and its management will be carried out confidentially