Anti-Bribery Policy

Zero Tolerance Toward Bribery

INVEST maintains a zero-tolerance position toward bribery in all its forms of expression, whether direct or indirect, active or passive.

Compliance with Applicable Legislation and Requirements

INVEST officials and employees commit to complying with and continuously improving the Anti-Bribery Management System (ABMS), based on the ISO 37001:2025 Standard, by adopting concrete actions to prevent, detect, and address bribery in all its forms in a rational, proportional, effective, and appropriate manner. INVEST also commits to complying with applicable anti-bribery laws, the requirements of the ISO 37001:2025 Standard, and other requirements applicable to the organization.

Anti-Bribery Culture

INVEST will promote and strengthen an anti-bribery culture based on integrity, transparency, ethics, accountability, and zero tolerance toward bribery, ensuring that these principles are understood, adopted, and applied at all levels of the organization. Top Management will demonstrate an active, visible, consistent, and sustained commitment to the prevention, detection, and response to bribery, promoting behaviors that support the Anti-Bribery Policy and the Anti-Bribery Management System.

Identification and Reporting of Indications of Bribery

Every INVEST official or employee has the responsibility to identify and report indications of bribery whenever circumstances allow. Such indications may include promises, offers of gifts, gratuities, or other improper advantages in exchange for performing or omitting actions that benefit a third party. INVEST personnel who witness or are victims of such situations must reject any request or offer of bribery and report the facts through the channels established by INVEST: website (Online Bribery Report Form), email [email protected], phone number +503 7071-7019, or physical reporting boxes located at INVEST, providing, whenever possible, the information or evidence available for its corresponding handling.

Anti-Bribery Function

The Anti-Bribery Function is responsible for verifying, assessing, and monitoring the effective implementation of this Policy and the Anti-Bribery Management System, in accordance with the established responsibilities and authorities, contributing to the achievement of anti-bribery objectives. The Anti-Bribery Function has the competence, status, responsibility, authority, and independence necessary to perform its functions and provide advice and guidance on the Anti-Bribery Management System.

Raising Concerns, Reporting, and Non-Retaliation

Officials, employees, suppliers, business partners, and other interested parties related to INVEST may raise concerns and file reports in good faith or on the basis of a reasonable belief regarding possible acts of bribery. INVEST will ensure that such concerns or reports can be raised in an environment of trust and without fear of retaliation, protecting the confidentiality of the information and, when applicable, the identity of individuals who report or cooperate with investigations under the Anti-Bribery Management System. INVEST expressly prohibits any form of retaliation, discrimination, or improper disciplinary action against those who raise concerns or file reports in good faith or on the basis of a reasonable belief, or who refuse to participate in acts of bribery.

Compliance with ABMS Requirements

Officials, employees, suppliers, business partners, and other interested parties related to INVEST must comply with the requirements of the Anti-Bribery Management System, this Anti-Bribery Policy, and the requirements applicable to their activities and relationships with the institution.

Investigation and Handling of Bribery Cases

INVEST authorities will conduct the relevant investigations, exhausting administrative and legal avenues based on the nature and particularities of each case, without prejudice to the administrative sanctions and legal actions that may apply to those who engage in acts of bribery, regardless of whether they are INVEST employees, taking into account the facts, nature, and severity of the violation or non-compliance.

Continual Improvement

INVEST commits to maintaining and continually improving the suitability, effectiveness, and performance of the Anti-Bribery Management System, as well as reviewing this Policy whenever necessary to ensure its alignment with the organization's purpose, context, objectives, and bribery risks.

Consequences of Non-Compliance

Non-compliance with this Anti-Bribery Policy, the Anti-Bribery Management System, or applicable requirements may result in the corresponding administrative, disciplinary, and legal measures, in accordance with the applicable legal framework, internal regulations, and procedures established by INVEST.