Anti-bribery and anti-corruption statement

Compliance Approach: Regional Agnostic (LATAM) & Global Standard
Last Updated: [12/11/2025]

PREAMBLE AND COMMITMENT

Diversidad Financiera Consultores (hereinafter, the “Company”) operates under an unwavering principle of integrity and transparency. Our policy is one of Zero Tolerance towards any form of bribery and corruption.

This statement is not merely a formality, but an operational mandate grounded in the principles of the OECD Anti-Bribery Convention, the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), and strict compliance with the Local Criminal Anti-Corruption Laws of all Latin American jurisdictions in which we operate.

I. SCOPE AND APPLICATION

This Policy is mandatory for:

Internal Personnel: All directors, executives, and employees of the Company.
Linked Third Parties: Contractors, agents, consultants, Joint Venture partners, and any representative acting on behalf of Diversidad Financiera Consultores.

Strictest Rule Principle: If the local laws of a Latin American country differ from the standards of this Policy or UK regulations, we will always apply the rule or requirement that is strictest and offers greater compliance guarantees.

II. DEFINITIONS AND KEY CONCEPTS

To ensure clear understanding within the region’s legal context and avoid interpretive ambiguities:

Bribery (Bribery/Kickback/Tip): The offering, promising, giving, requesting, or accepting of money, gifts, benefits, or any “thing of value” with the aim of unduly influencing a decision, obtaining an unfair commercial advantage, or securing business. This applies to both the public and private sectors (commercial bribery).
1. Corruption: The abuse of a position of power (public or private) to obtain an illicit personal benefit.
Public Official (PO): Defined broadly to include:
- Legislators, administrative and judicial officials.
- Executives and employees of state-owned or parastatal enterprises (e.g., oil, electric companies).
- Candidates for political office and party officials.
- People acting on behalf of Public International Organizations (e.g., World Bank, IDB).
Facilitation Payments: Small (unofficial) payments made to secure or expedite routine government action. These are strictly prohibited by the Company, without exception, regardless of local custom

III. SPECIFIC PROHIBITIONS AND RISK MANAGEMENT

Our policies are designed to prevent bribery and ensure ethical conduct. Given our investment activity in Litigious Rights and Intangible Assets, we pay special attention to the following risks:

3.1. Absolute Prohibition of Judicial Influence

The core of our business depends on the impartiality of judicial rulings. Therefore, any offering, gift, excessive hospitality, or payment to the following is strictly prohibited:

Judges, Prosecutors, Magistrates, Court Clerks, or administrative court personnel.
Arbitrators, court-appointed experts, bankruptcy trustees, or liquidators.

The objective is to avoid any perception that the Company seeks to influence official decision-making to gain advantages in enforcement, collection, or litigation proceedings.

3.2. Financial Controls and Books & Records

Financial transparency is our first line of defense.

Every expense must be recorded accurately, completely, and in a timely manner.
Making false, ambiguous, or misleading entries in accounting books is prohibited.
Unaccounted “petty cash” funds or off-the-books accounts are not permitted.
The concealment of payments will be treated as an indication of fraud.

3.3. Third-Party Due Diligence

We apply a Risk-Based Approach (RBA) for partner selection:

We conduct Customer Due Diligence (CDD) on all intermediaries (external counsel, collection agents) interacting with the Public Sector on our behalf.
“Red Flag” Monitoring: We watch for alerts such as requests for cash payments, unusual commission structures, or family ties with public officials.
Right to Audit: Our contracts include clauses allowing us to audit compliance and unilaterally terminate the relationship upon violations of this policy.

IV. COMPLIANCE, TRAINING, AND WHISTLEBLOWING CHANNEL

4.1. Training and Culture

The Company provides continuous training to key employees and associates, adjusted to the risk of their jurisdiction, to ensure they understand not only the letter but the spirit of Anti-Bribery Laws.

4.2. Reporting and Ethical Channel

We foster an environment where concerns can be raised without fear. Any employee or third party who suspects a potential, past, or ongoing violation of this Policy must report it immediately.

Compliance Contact: If you have concerns or wish to report non-compliance, contact our Compliance Officer at: info@diversidadfinanciera.com

4.3. No Retaliation and Sanctions

Whistleblower Protection: We guarantee confidentiality and strictly prohibit any retaliation against anyone reporting in good faith.
Consequences: Non-compliance with this policy will result in immediate disciplinary measures (including contract termination or dismissal) and notification to competent civil or criminal authorities as appropriate.