✔️Anti-corruption policies

Measures and strategies aimed at preventing, detecting, and punishing corruption in the public and private sectors.

PURPOSE

CCSCEX® focuses on meeting the needs of our clients while respecting professional and ethical values to maximize the quality of our operations. To fulfill this commitment and our responsibility to act with integrity at all times, we have created an "Anti-Corruption Policy" designed to establish control measures that prevent any kind of fraud, bribery, or corruption, in compliance with national laws and the countries where we operate.

Among the key elements of CCSCEX®'s strategy to prevent fraud, bribery, and corruption is our Code of Ethics, which establishes mandatory rules of conduct that all of our employees must follow.

We are committed to ensuring that these rules are followed and that appropriate sanctions are applied in case of noncompliance. In this way, CCSCEX® seeks to foster a culture of honesty and transparency in all of its operations.

STATEMENT CCSCEX®

advocates for the importance of establishing general parameters of action that all employees must follow in order to reduce the risks associated with fraud, bribery, and corruption.

Our policy aims to establish guidelines for identifying, measuring, controlling, investigating, and correcting situations related to fraud, bribery, and corruption, promoting a culture of compliance and protecting the company's reputation, in line with the values found in our Code of Ethics.

Therefore, our "Anti-Corruption Policy" expressly prohibits bribery in all its forms.

We understand bribery to mean anything of value offered, promised, paid, authorized, or delivered to a third party in order to illegally influence a business decision or obtain an undue advantage in our operations. By emphasizing this prohibition, CCSCEX® seeks to ensure that all operations are conducted with integrity, transparency, and in accordance with applicable laws and regulations.

PRINCIPLES OF ACTION

With the primary objective of preventing corruption in all its forms in the countries where it operates, CCSCEX® strives to consistently implement best practices to combat these activities.

For this purpose

• CCSCEX® promotes and encourages an anti-fraud, anti-bribery, and anti-corruption institutional culture within the company.

• Neither CCSCEX® nor its employees influence the will or objectivity of persons outside the company to obtain any benefit through the use of unethical or illegal practices.

• CCSCEX® and its employees do not offer, promise, or deliver, directly or indirectly, any tangible or intangible item of value to any natural or legal person in order to obtain advantages for the company.

• CCSCEX® and its employees do not make payments to lower-ranking public officials in order to expedite or facilitate the performance of their duties.

• CCSCEX® and its employees do not finance or provide support, directly or indirectly, to any political party, its representatives, or candidates.

• CCSCEX®'s donations are not used to cover improper payments.

• CCSCEX® and its employees do not solicit or receive improperly, directly or indirectly, commissions, payments, or benefits from third parties in connection with the company's investment, financing, or expenditure operations.

• CCSCEX® pays special attention to cases where there are indications of lack of integrity of the people or companies with whom it does business, in order to ensure that the company establishes business relationships only with qualified people and companies with an adequate reputation.

• CCSCEX® accurately and appropriately reflects all actions, operations, and transactions of the company in its books and records.

• CCSCEX® promotes the training of its employees in the prevention and fight against corruption.

• If employees have knowledge, doubts, or suspicions regarding any form of corruption, they must immediately report it to the Compliance Officer or their immediate superior.

• CCSCEX® will not tolerate any form of retaliation against those who, in good faith, report any facts that may constitute a violation of this policy.

If an employee violates any of these provisions, CCSCEX® reserves the right to take disciplinary measures, which could include termination of the contract, as well as other possible legal sanctions. Likewise, the company reserves the right to take appropriate measures against its suppliers, partners, and associates who violate these provisions.

CCSCEX® takes its commitment to integrity and business ethics very seriously and will act vigorously and effectively against any conduct that jeopardizes its reputation and its commitment to compliance with applicable laws and regulations in the countries where it operates.

CCSCEX | CARACAS COMMODITY EXCHANGE 2023®©.

All rights reserved.