Artificial Dynamics Code of Ethics

I. PRESENTATION

It is a great challenge to remain as one of the leaders in technological development in Mexico and Latin America, so this involves several aspects, a fundamental one is the confidence that our organization instills in our customers, as well as in our shareholders. The former must be pleased with the products, services and attention we provide, and the latter must see us as a safe investment.

That is why it is of vital importance that we, as the human capital, as the agent that gives life to Artificial Dynamics companies, do the right thing in the performance of our activities and functions, within the ethical and legal framework.

In this sense, our success is closely related to our acting with integrity and professionalism, each of us is responsible for ensuring that our own actions on behalf of the organization comply with the law, policies and guidelines. And it is our responsibility to demand the same of all external parties with whom we do business.

We must keep the Code at hand and refer to it as often as we need it. When in doubt, it is best to seek advice from your immediate supervisor or Human Resources. With our help, we will ensure that the reputation of a solid organization that delivers good results will be a permanent asset. Thank you in advance for your support and personal commitment.

II. OBJECTIVES OF THE CODE OF ETHICS

Our Code of Ethics represents the company's commitment to maintain the highest ethical standards in the performance of those who are part of it. It also recognizes and attaches importance to compliance with the laws of the countries in which we operate, policies and guidelines applicable to our organization. In this sense, the dissemination of the Code takes on a fundamental role that we must all assume, as well as prevent and report any violation of the same, following the corresponding policy.

It also provides the basic guidelines according to which we as employees of Artificial Dynamics companies must act and make ethical decisions.

III. VALUES

To orient the group towards competitiveness and profitability. To satisfy with efficiency, quality and service the needs of our customers. Promote the professional development of our personnel, in accordance with the needs of the company. To recognize individual and team achievements, as a stimulus to productivity and progress. Respect and care for the well-being of the communities and the ecological environment where we operate.

IV. ETHICAL BUSINESS PRINCIPLES

Ensure our leadership in the markets in which we participate. To constantly monitor the profitability of our lines of business, observing what we use and spend in order not to waste resources. What we use must be used efficiently, that is, with the highest possible productivity. Maintain our competitiveness in the market through price, quality and service, as fundamental factors in satisfying our customers' needs. Optimize synergies within and between Artificial Dynamics companies. Prevent possible incidents derived from our business management that could affect the environment, damage our assets or the community in which we operate.

V. PRINCIPLES OF CONDUCT

All activities must be carried out in accordance with established rules, laws, regulations, policies and procedures. Everyone deserves to be treated with dignity, regardless of gender, age, hierarchical level or any other characteristic or personal conviction. All our actions must be oriented with rectitude and honesty; this is an indispensable principle as a company and as individuals. We must assume the consequences of the decisions we make and be accountable for our actions, which makes us reliable in our actions.

VI. COMPLIANCE WITH THE LAW

Employees of Artificial Dynamics companies will fully comply with applicable laws, regulations and standards wherever we operate and do business. Similarly, it is our responsibility to keep ourselves informed and up to date in the above areas. We will also ensure that external personnel with whom we have business relationships do so.

VII. USE AND HANDLING OF INFORMATION

We must be mindful of safeguarding proprietary and privileged information. It is expected conduct to keep it secure and limit its access to those who have a need to know it to perform their work, in accordance with established policies.

Privacy of information within the company: We will maintain the confidentiality of information that gives us an advantage over our competitors or may expose us to damages if disclosed prematurely or improperly, such as formulas, patents, trademarks, proprietary technology and processes, internal calculations of unit prices, internal information on bids, process alternatives to propose to customers, financial, strategic and corporate information, and confidential information on relationships with customers and suppliers.

We will also protect privileged information, i.e., strategic information, cost and revenue results, employee files, salaries, internal processes and procedures, product prices, customer lists, changes in dividend distribution policies, new product development, merger, acquisition or spin-off plans, and any other information that may be useful to competitors.

On the other hand, information considered as confidential, non-public information of the company, to which all of us as collaborators have access, must not be reproduced without the express authorization of the area responsible for its generation and custody. Company administrators must ensure that external personnel with access to this information comply with the policies and procedures, establishing control measures that preserve the interests of our organization.

Therefore, one of the measures we will take is not to discuss confidential information in public places, family circles and with third parties.

VIII. CONFLICT OF INTEREST

It occurs when the personal or financial interests of one of the collaborators take priority over the interests of the organization. As members of the company, we must not become involved in situations that involve or may involve a conflict of interest, and at the beginning of the employment relationship we must sign a letter of commitment in this regard, in accordance with the existing format and policy. Should any of us find ourselves in a situation that involves or may involve a conflict of interest, we must notify our immediate supervisor (using the aforementioned form), who will inform the Human Resources Department to obtain information on how to proceed.

The direct line managers will report in a timely manner any situations of conflict of interest that they detect, thus avoiding any assumption of co-responsibility. In the event that we are aware of a business in which a family member or friend who wishes to become a supplier of services or products to the company works or owns the business, we must not influence the negotiations in favor of that business. If the function we perform is directly related to the negotiations, we must excuse ourselves from participating in them, informing our immediate supervisor in writing about the relationship with the relative or friend.

If we have relatives or friends who work in the competition, we must refrain from providing information related to the organization, as well as from receiving and transmitting information from the competition within the company. We shall avoid associating with superiors, subordinates or friends to commit dishonest acts that may harm the interests of the organization.

IX. BUSINESS OPPORTUNITIES

Employees of Artificial Dynamics companies will avoid exchanging securities or any other type of property or assets based on knowledge they acquire in their work if that information has not been publicly reported. Therefore, we avoid advising others to make an investment decision based on inside information. We also consider it an improper practice to use the organization's information for personal benefit, or for the benefit of family or friends.

Likewise, we may not use the company's name to benefit ourselves, any other person or organization, as well as the benefits of any negotiation or potential investment, taking advantage of the level or performance of our position.

X. PROPRIETARY INFORMATION, SYSTEMS AND PROCEDURES

The custody and preservation of the company's assets is the responsibility of each and every one of us, so we must avoid losses, misuse, theft, damage and sabotage. Company assets are understood to be not only buildings, cars, trucks, machinery or furniture, computer equipment, but also blueprints, designs, processes, systems, computer data, electronic or telephone communications, voice mail, technology, drawings, business strategies, product launch plans, advertising and promotional campaigns, and of course our trademarks and patents, among others.

The assets and resources directly assigned to us, including computer equipment (hardware and software, e-mail, internet, voice mail), must be used responsibly and exclusively for the performance of the activities entrusted to us by the organization, respecting the guidelines given by the Operational and Systems Management, as well as the policies and procedures in force for such purpose.

XI. RESPONSIBILITY IN THE HANDLING OF ASSETS AND RECORDS

The company is obliged to make disclosures to the public and is committed to comply with all applicable requirements, therefore, those responsible for financial information to the public shall ensure that when disclosed it is full, accurate, balanced, timely, correct, complete and understandable, complying with the applicable controls, procedures and regulations.

On the other hand, to make reasonably accurate decisions, we require honest and accurate records and reporting of information. This includes business, financial, production, safety and personnel data. All books, records and financial accounts through which business assets and processes are controlled must accurately reflect transactions and events and comply with accounting principles and internal control systems.

Falsifying information by falsifying it or breaking established cycles is a very serious matter that we will avoid, as well as recording false or artificial entries, or omitting exits or dispositions.

The Directors of the Artificial Dynamics companies and the personnel involved with the recording of transactions will adopt internal control policies and guidelines to provide the company with reasonable assurance that we have complied with the requirements referred to in the preceding paragraph and that the financial statements are prepared on an accurate and reliable basis, and include the required disclosure standards.

All directors, officers and collaborators authorized to authorize transactions such as purchases, payment to suppliers, delivery and verification of travel expenses, will review what we authorize as part of our responsibilities and commitment to ensure that the movements are correct and in accordance with established policies.

Personnel who have access, authority, use or express authorization to dispose of company property, as well as its records, merchandise, securities, cash and restricted material, are personally responsible for their safekeeping.

XII. ON PERSONAL POLITICAL AND COMMUNITY ACTIVITIES

We are all free to support the community organizations, political, religious or charitable causes of our choice, as long as we make it clear that our views and actions are personal, not those of the company. As employees, we must ensure that outside activities do not interfere with job performance. No member of our company may pressure another to express a point of view contrary to his or her personal beliefs or to contribute to or support political, religious or charitable causes. Nor may they use company assets for such purposes.

In addition, our shareholders generously support various charities and community programs in the various regions where we operate. Therefore, it is not permitted for us as employees to arrange, commit or agree to donations or financing in the name and on behalf of Artificial Dynamics companies. This process needs to be applied rationally, which is why it is limited to the indications of the General Management.

XIII. COMPUTER SYSTEMS

Computer systems are essential to the daily operation of our company. It is essential that the hardware, software, as well as the access, processing and storage of data, are adequately safeguarded and used exclusively for the duly authorized purposes.

The company has installed several security systems to protect its computer systems. We must not use any program to circumvent these systems. We have an individual responsibility to safeguard the company's computer systems and are responsible for knowing and understanding the specific policies and guidelines governing the use of networks, systems and electronic information.

Automation systems and microcomputers allow data to be easily moved from offices to homes. The elements for storing information and the systems used must be physically secured, and access control must be established.

In addition, all documentation regarding the acquisition of software licenses and the use of such licenses must be kept up to date and available for verification. Any copying, appropriation or misuse of software is prohibited. Software, e-mail, internet and voice mail are company property and may only be used for company purposes.

In addition, it is important to point out the following:

• No employee may install non-institutional software on their computers, or software for which the company does not have the corresponding license for use.
• No modifications shall be made to the contracted software, except in those cases where permitted in the respective agreements, and under the supervision of the Systems Area.
• Do not develop systems or programs not authorized by the Systems Area.
• The internal development of equipment, systems and computer programs by employees for the planning and execution of the company's activities are the property of the company.

XIV. CONDUCTS THAT MAY CONSTITUTE A PATRIMONIAL CRIME

Any act or omission that may constitute a financial crime against the company must be reported, identified and investigated promptly, in order to take the corresponding legal actions. This rule shall apply to conduct that may constitute related crimes or means of preparation for the commission of a financial crime, such as the preparation or receipt of apocryphal or false documents, theft of goods or documents, irregular handling of money and securities, and so on.

XV. CONSUMPTION OF ALCOHOLIC BEVERAGES, DRUGS, AND NARCOTIC SUBSTANCES

It is essential to come to work free from the influence of substances that could prevent the safe and effective performance of activities. The use, possession, sale, attempted sale, transportation, distribution, or manufacture of drugs or any other controlled substance is not permitted while performing activities on company premises or in company vehicles.

Any employee who is under the influence of drugs, alcohol or any other controlled substance must be prepared to submit to appropriate disciplinary action.

The above applies equally to external personnel within the company's facilities.

XVI. THREATS AND VIOLENCE IN THE WORKPLACE

Abusive, hostile or offensive conduct is unacceptable, whether verbal, physical or visual. Examples include derogatory comments based on certain physical, racial or ethnic characteristics, socio-economic or cultural background, place of study or activities. Offensive gestures, comments and communications will not be accepted.

XVII. POSITION OR SEXUAL HARASSMENT

Under no circumstances may senior employees demand that a subordinate perform actions other than those for which he/she has been hired; therefore, it is not permitted to exert pressure to force us to perform a specific act that does not correspond to our functions or job description. It is forbidden to harass any employee within the company to obtain a personal relationship or favor.

XVIII. FAIR COMPETITION

With respect to our competitors, we must fully comply with all applicable laws and at all times conduct ourselves in accordance with the highest ethical standards. Our competitiveness must be based exclusively on the merit of our products and services, appropriate pricing, timely service and the added value we provide to the customer. We will never use illegal or unethical methods to obtain competitive information.

Appropriating proprietary and privileged information, possessing trade secret information, and causing such disclosures by current or former employees of other companies is prohibited. If we mistakenly obtain information that could constitute a trade secret or confidential information of another business, or if we have doubts about the legality of any information obtained, it is appropriate to consult with the legal department.

Since the company conducts business in different countries, personnel involved in commercial operations must be familiar with and respect the content of the antitrust laws in force in the country concerned.

Under these laws, corporations or persons representing them may not enter into formal or informal arrangements with other companies or engage in activities that restrict free competition. Illegal practices may include fixing prices, allocating customers or territories, illegally using a dominant market position.

We must not refuse to do business with customers whose suppliers include direct or indirect competitors of the company, since failure to comply with this policy may constitute a violation of competition or antitrust laws.

XIX. RELATIONSHIP WITH THE ENVIRONMENT

Communication with the media and authorities. To ensure professional handling, requests from the mass media should be directed to the Corporate Human Resources Department, who will channel them appropriately.

Sometimes many well-intentioned interviewees have had their stories misinterpreted by reporters, so let the right people handle these communications. All information provided must be truthful, accurate and clear. We will not alter or destroy documents or records in response to an investigation or legal request, as we believe that business should be a contributing force in the development of good governance at all levels.

The Director of each Artificial Dynamics unit is responsible for executing programs in coordination with regional or state levels of government. No communication with any government agency, official or representative, other than legislative matters, should take place without the approval of the appropriate Directorate.

XX. WORK ENVIRONMENT

We must treat each other with respect and fairness at all times, just as we wish to be treated. We will value the differences of the various individuals involved in Artificial Dynamics's business.

Employment decisions, such as hiring, compensation, promotion and division of labor will be based on objective and measurable reasons, such as studies, talents, achievements, performance, always in compliance with internal selection policies and applicable labor laws. In no case, aspects such as race, religion, age, gender, affiliation, etc., may be factors that determine the decision making related to employees or candidates to occupy any position within the company, in order to eliminate any discrimination and promote equal treatment and opportunities.

Promoting a healthy work environment also depends on all of us complying with the internal guidelines that correspond to our area of responsibility, and in terms of the law.

XXI. HEALTH AND SAFETY

We are responsible for maintaining a safe and clean workplace in strict compliance with safety rules and regulations. Likewise, the company will provide us with facilities that have hygienic bathrooms, drinking water and, if possible, adequate areas for food consumption.

Therefore, in Artificial Dynamics companies that require it, the personnel will respond to the obligation to correctly use protective equipment, as well as to attend training courses for its use.

We must report in a timely manner unsafe acts that put us in danger, as well as situations of risk to the company's assets. Likewise, the company will provide personnel, according to their needs, with information regarding occupational health care and safety.

Those who provide services to external personnel must ensure that they also adhere to our company's health and safety regulations.

The personnel in charge of industrial safety and occupational health are committed to complying with the laws and regulations that the company has established. This includes policies, practices, systems and procedures.

Given the above, our cooperation is vital to avoid serious misconduct or recidivism that could endanger the health and life of our personnel or the company's assets.

The company seeks to maintain a safe and secure work environment and will not tolerate threats, acts of violence or physical or emotional intimidation. Our company prohibits the entry into the workplace of any type of weapon or tool that could be used to harm a person.

XXII. RESEARCH COOPERATION

We will be willing to cooperate in any investigation conducted by the Mexican government and other countries where we have such an obligation by virtue of the business we conduct.

When any of us becomes aware of a situation that could result in a material impact, and that under investigation or at the request of the government represents a significant risk to any of the company's operations, we must notify the company's General Management, providing the corresponding justification.

The company, through the Ethics Committee, will establish a program to review compliance with the contents of this Code. The managers of Artificial Dynamics companies will address in a timely manner the recommendations of this body on deviations in internal control, policies and procedures in administrative and operating areas, as well as implement necessary corrective and preventive measures.

We all share the responsibility to submit information on wrongdoings committed to the detriment of the company's interests, as well as to report serious violations of the Code of Ethics. The procedure to establish how to receive, follow up and resolve complaints of misconduct and/or violations of the Code of Ethics, policies and processes of the company, is established through our Whistleblower Policy.

Likewise, all research will be conducted with legality and respect for the laws and rights of the personnel, supporting the Ethics Committee to establish the necessary control measures in the professional and confidential management of the research process.

Disciplinary actions may be extended to the immediate supervisor of the person who violated the Code, to the extent that the company determines that he/she was involved, negligent or lacked diligence and care.

Document retention policies do not allow us to destroy or alter compromising documents, as this could obstruct the investigation process.

XXII. RESEARCH COOPERATION

In addition to the fact that each employee of the organization must be familiar with this Code of Ethics, and must submit a signed Letter of Adherence, this document is also available on the website www.artificialdynamics.ai in order to consult any content updates, as well as to invite external personnel with whom he/she interacts in the performance of his/her duties to become familiar with it and share the commitment it sets forth.

XXIV. ETHICS COMMITTEE

It is the body designated by the General Management of Artificial Dynamics, in charge of:

• Establish ethical and conduct policies and guidelines.
• Oversee due compliance with this Code of Ethics and the policies referred to herein.
• Take the corresponding actions when there is a violation of the aforementioned provisions in terms of the corresponding internal work regulations.