Founded in 1971Soluciones S.A.Ferretería Forero S.A. 

Integrated Risk Self-Control and Management System for Money Laundering, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction; and Business Transparency and Ethics Program The contracting parties have freely and voluntarily agreed to attach the obligations set forth in this document to the main contract, understanding that these obligations arise from the law and the Basic Legal Circular issued by the Superintendence of Companies, specifically Chapters X and XIII thereof. The parties shall be identified as follows: FF SOLUCIONES S.A., as the obligated entity, and the CONTRACTUAL COUNTERPART, in accordance with the definitions contained in Chapter X of the Basic Legal Circular of the Superintendence of Companies. 

FF SOLUCIONES S.A., its directors, representatives, shareholders, and members of the board of directors, declare their commitment to preventing and punishing criminal, illegal, and fraudulent acts related to the contracts or legal transactions entered into by the company. Consequently, all activities carried out by the company, its employees, contractors, suppliers, customers, and other business partners must adhere to the highest standards of ethical and moral conduct. This implies full compliance with all applicable regulations regarding the prevention and punishment of Money Laundering, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction (ML/TF/PWMD), corruption, transnational bribery, and any activity deemed criminal, fraudulent, or contrary to the principles of good faith, ethics, morality, and transparency. 

FF SOLUCIONES S.A. declares that it is an entity required by the SUPERINTENDENCE OF COMPANIES to establish and operate an Integrated Risk Self-Control and Management System (SAGRILAFT) for Money Laundering, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction (ML/TF/PWMD). Accordingly, the CONTRACTUAL COUNTERPART undertakes to understand, comply with, and apply the standards established in the SAGRILAFT policy and manual, as well as national legislation regarding these offenses, including provisions of the Penal Code, Law 222 of 1995, Law 526 of 1999, Law 1121 of 2006, Law 1186 of 2009, Decree 1068 of 2015, Decree 1736 of 2020, Chapter X of the Basic Legal Circular of the Superintendence of Companies, and External Circular 100-000016 dated December 24, 2020. 

The CONTRACTUAL COUNTERPART declares under oath as follows:a) All activities carried out by the entity, its shareholders, beneficial owners, parent companies, branches, subsidiaries, affiliates, customers, employees, and suppliers are lawful and conducted within the framework of the legal system.b) That the personal resources of directors, partners, and administrators, as well as the assets of the legal entity, do not originate from any illegal activity classified under Colombian criminal law — including ML/TF/PWMD — and derive exclusively from the development of the entity’s core business activities and corporate purpose.c) That all documentation and information provided for the execution and performance of the contract or legal transaction is true and accurate; accordingly, FF SOLUCIONES S.A. is authorized to conduct any necessary verifications.d) That corporate resources allocated for the performance of this contract do not originate from any illegal activity classified under Colombian criminal law — including ML/TF/PWMD — and derive exclusively from the development of the entity’s core business activities and corporate purpose.e) That all payments made under the contractual relationship are executed directly using the entity’s own funds, and not through or with resources belonging to third parties.f) That neither the CONTRACTUAL COUNTERPART, its legal representative, administrators, partners, nor shareholders holding directly or indirectly more than 5% of the share capital, contributions, or ownership interest are included in mandatory binding or precautionary watchlists in Colombia.g) That I understand and accept that FF SOLUCIONES S.A. is legally required to request any clarifications it deems necessary as part of its counterparty due diligence process — including standard and enhanced due diligence — and in such cases, all required documentation shall be provided. Any breach or violation of these declarations shall entitle FF SOLUCIONES S.A. to terminate the contract with just cause, demand payment of the penalty clause, and claim compensation for all damages and losses incurred. 

The CONTRACTUAL COUNTERPART acknowledges that FF SOLUCIONES S.A., as an obligated entity, is responsible for reporting suspicious transactions to the Financial Information and Analysis Unit (UIAF). Accordingly, the CONTRACTUAL COUNTERPART agrees to provide all information necessary to enable appropriate clarifications, particularly during due diligence procedures or when alert indicators are identified. In any case, and in accordance with applicable regulations, the reporting of a suspicious transaction does not imply liability on the part of FF SOLUCIONES S.A.; all responsibility for the report, related investigations, and corresponding clarifications shall rest exclusively with the CONTRACTUAL COUNTERPART. 

FF SOLUCIONES S.A. declares that it is an entity required by the Superintendence of Companies to establish and operate a Business Transparency and Ethics Program (PTEE) to mitigate risks of corruption and transnational bribery. Accordingly, the CONTRACTUAL COUNTERPART undertakes to understand, comply with, and apply the standards established in the PTEE Compliance Manual, as well as national legislation regarding these offenses — including provisions of the Penal Code, Law 1778 of 2016, and Chapter XIII of the Basic Legal Circular of the Superintendence of Companies. 

In the event that the CONTRACTUAL COUNTERPART modifies its shareholding structure by more than 5%, such change must be notified in writing to FF SOLUCIONES S.A. via certified mail or to the email address for service of legal notices as registered in the certificate of existence and legal representation. This requirement shall not apply to publicly traded companies, entities governed by public law, entities with public participation, or other entities exempted by law from due diligence procedures. 

FF SOLUCIONES S.A. declares that during the contracting process, it complied with all obligations established in applicable regulations related to the prevention and control of ML/TF/PWMD risks, as well as with the standards set forth in its PTEE and internal procedures established in this regard — including due diligence, where required or applicable. Consequently, the execution of this contract was carried out with the highest degree of diligence established in applicable regulations and internal procedures set out in the SAGRILAFT Policy and PTEE Manual, developed in accordance with the guidelines issued by the SUPERINTENDENCE OF COMPANIES. 

The following shall constitute grounds for unilateral termination of the contract by FF SOLUCIONES S.A., without any right to compensation:a) If the CONTRACTUAL COUNTERPART, its shareholders, associates, partners, legal representatives, and/or members of its board of directors are subject to an investigation, formal accusation, or final judicial conviction for the crimes of transnational bribery, corruption, or ML/TF/PWMD; or if they are linked to criminal, civil, or administrative investigations or proceedings related to such offenses; or if public or generally known information regarding such individuals could expose FF SOLUCIONES S.A. to legal or reputational risk.b) If the CONTRACTUAL COUNTERPART, its shareholders, partners, representatives, administrators, or related parties holding, owning, or controlling, directly or indirectly, at least 5% of the ownership interest, are included in mandatory binding or precautionary watchlists in Colombia.c) If the CONTRACTUAL COUNTERPART, its representatives, partners, administrators, shareholders, or contractors violate the principles and standards contained in the PTEE Compliance Manual, as well as those set forth in Chapter XIII of the Basic Legal Circular and Law 1778 of 2016. 

FF SOLUCIONES S.A. has established digital and in-person channels for submitting complaints — either identified or anonymous — regarding violations of national regulations, including standards related to ML/TF/PWMD and corruption and transnational bribery. Information about these channels is available directly from the company. 

The CONTRACTUAL COUNTERPART undertakes to report or disclose any conflict of interest that the legal entity, its partners, members of the board of directors, representatives, or employees may have when entering into any legal transaction with FF SOLUCIONES S.A. The term conflict of interest shall be understood in its broadest sense, always in furtherance of transparency and fair commercial benefit within the contractual relationship. The CONTRACTUAL COUNTERPART is prohibited from offering gifts, favors, donations, or covering entertainment expenses for illegal or unlawful purposes to any employee, contractor, administrator, representative, board member, or partner of FF SOLUCIONES S.A.