Sagrilaft

SAGRILAFT INFORMATION

DETAILS

It is that operation that, due to its number, quantity or characteristics, does not fall within the system and normal practices of the business, of an industry or of a determined sector and, furthermore, in accordance with the uses and customs of the activity in question, does not could have been reasonably justified.

A Suspicious Operation Report (ROS) is not a complaint. Unlike the complaint, the ROS is completely anonymous, they are reserved, it constitutes a guiding criterion and not a judicial test for the Office of the Attorney General of the Nation (FGN), it is not a testimony and does not generate any type of responsibility. Additionally, a STR does not represent a criminal sentence.

Items

1. Design and approval
2. Audit and compliance
3. Outreach and training
4. Assignment of functions to those responsible In this sense, the company must be clear that for the correct functioning, compliance and effectiveness of SAGRILAFT, the participation of various subjects is necessary and the interaction between them is essential. Roles such as the following should be considered:

Board of directors or highest corporate body
Legal representative, Compliance Officer, Control Bodies, Statutory Auditor and Internal Audit.

SAGRILAFT POLICY SYSTEM FOR SELF-CONTROL AND INTEGRAL RISK MANAGEMENT OF MONEY LAUNDERING, FINANCING OF TERRORISM AND FINANCING OF THE PROLIFERATION OF WEAPONS OF MASS DESTRUCTION (LA/FT/FPWMD)

THE COMPANY AERO AGRICOLA INTEGRAL S.A.S. (hereinafter CAAISA) has as a policy for ML/TF/FPWMD risk management a series of measures and procedures to prevent the company from being used, directly or indirectly, to carry out illegal activities or their financing.

This policy is developed through the SAGRILAFT Manual, which establishes that CAAISA must, as a minimum:

• Identify and validate the identity of its associates, clients, contractors and other counterparties.
• Meet the final beneficiary
• Understand the businesses, contracts and operations of their counterparties.
• Carry out transactional monitoring, in order to detect operations or activities that deviate from normal behavior to manage their risk.

CAAISA has procedures to know its clients, suppliers, collaborators and other counterparts by obtaining, registering and verifying their information. It also performs periodic updates.

"Due Diligence" is the fundamental element for the development of this policy. CAAISA has due diligence procedures for its clients, suppliers, collaborators, shareholders and other counterparties in order to protect the interests, businesses, contracts and operations of the company.

CAAISA has a more exhaustive due diligence procedure for direct or indirect relationships with Politically Exposed Persons (PEP). Likewise, CAAISA carries out an intensified due diligence process for those clients, suppliers, collaborators and other counterparties that it considers to be of greater risk, as well as those considered DNFBPs (Designated Non-Financial Activities and Professions), in accordance with local regulations and international standards. .

In accordance with the characteristics of the business and CAAISA's operations with its counterparties, no operations are carried out with cash derived from its commercial transactions.

CAAISA reports to the UIAF (Financial Information and Analysis Unit) all operations that it determines to be suspicious, without prejudice to informing the competent authorities of other situations that are known within the normal development of the business. In addition, any link that is identified with those counterparties that appear on the binding lists is immediately reported to the UIAF and competent authorities.

CAAISA keeps all the documents related to the operation of SAGRILAFT for a term of not less than ten (10) years, in accordance with the legal regulations on the matter.

Finally, CAAISA has a code of ethics and good governance, the Shareholders' Assembly and with the support of the legal representative, committed to the prevention and control of ML/TF/FPWMD risk, supported by the appointment of a compliance officer, who ensures the effective, efficient and timely operation of SAGRILAFT.

Policy adopted by the shareholders of CAAISA, through the Minutes of the Shareholders' Meeting.

PTEE

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The PTEE program is embodied in an easily accessible document for Directors, Employees, Associates, Contractors and Third Parties where the policy and procedures to combat transnational bribery are precisely found.

In this sense, the preparation of the PTEE regulates the following aspects:

The identification and evaluation of risks related to corruption and transnational bribery (C/ST).
General policies and procedures for C/ST risk management.
The delivery and offering of gifts to third parties.
The policy regarding remuneration and payment of commissions to Employees, Associates and Contractors.
Political contributions of any nature.
The donations.
Adequate and effective sanctioning procedures, de compliance with labor and disciplinary regulations, regarding
violations of the Business Ethics Program committed byanyEmployee or manager.
The obligation to report acts of corruption by la Obligated Entity, its administrators, Associates or Employees, de internally and externally, and the applicable procedure.

PTEE policy

comunicacion@caaisa.com

Disclosure of SAGRILAFT and PTEE

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The CAAISA Shareholders Assembly, aware of the relevance and importance of the fight against the crime of money laundering (ML), the financing of terrorism (FT) and the proliferation of weapons of mass destruction (PADM) in Colombia.

It reaffirms its commitment to implement and maintain effective controls that allow the prevention of the risk of Money Laundering, Terrorist Financing and Financing of the Proliferation of Weapons of Mass Destruction. As well as the prevention of the crime of corruption and transnational bribery against the public administration, so that CAAISA can carry out its business in a safe, ethical, transparent and honest manner, that is, in the context of the Law and other Colombian regulations issued by the Superintendence of Companies.

Due to the above and complying with the applicable legal provisions regarding the risks of ML/FT/FPWMD, corruption and transnational bribery. CAAISA, has included in its Integrated Management System - GIS, the following guidelines:

I. Implementation of SAGRILAFT – Through Chapter X of Basic Legal Circular No. 100-000005 of 2017, fully modified by External Circular No. 100-000016 of December 24, 2020, the Superintendence of Companies established the Regime Self-control and Comprehensive ML/FT/FPADM Risk Management and reporting of suspicious transactions to the UIAF, made up of the ML/FT/FPADM Self-control and Risk Management System – SAGRILAFT.

II. Adopt the Transparency and Business Ethics Program - PTEE as an obligated entity in accordance with external Circular 100-000011 of 2021.

Thus, the SAGRILAFT and the PTEE are structured as follows:

1. LA/FT/FPWMD and C/ST prevention policies

2. Due diligence procedure of the counterparties.

3. Administration and Risk Management of LA/FT/FPADM and C/ST.

4. Training Program addressed to its counterparts.

5. Monitoring, control and compliance audit.

6. Communication to interested parties.

7. Reservation and Confidentiality of information.

In this sense, the due diligence procedure and intensified due diligence for the knowledge of our counterparties and their final beneficiaries is of vital importance.

For this reason, CAAISA will be updating the data of its counterparts: (Customers, Suppliers, Contractors, Collaborators and Partners). The information requested by the company for this purpose will be treated in accordance with its Personal Data Treatment Policy available and published at www.caaisa.com

The Compliance officers designated as responsible for SAGRILAFT and PTEE supported by the Legal Representative, will address the requests or concerns received in this regard by email:

o.duarte@caaisa.com