Anti-corruption statement.

Executive Summary.

This document sets out INEFAM's Compliance, Anti-Corruption and Business Code of Ethics policies. INEFAM is a market research, specialized training and business consulting company specializing in the healthcare sector. The main objective of these policies is to promote integrity, transparency and compliance with the applicable laws and regulations in all our business activities.

The Introduction and Ethical Commitment section sets out the scope of these policies, which cover the INEFAM companies established in Mexico and Brazil, as well as our common trade name, INEFAM® or INEFAM-LATAM®.

The Compliance Policy section establishes the importance of complying with the applicable laws, regulations and rules in all our business operations. It covers areas such as legal compliance, data protection and privacy, risk management, and employee training and awareness.

The Anti-Corruption Policy section defines corruption and sets the guidelines for preventing and fighting it in all its forms. Bribery, corruption and any form of misconduct are strictly prohibited. It also covers topics such as relations with public officials, gifts and hospitality, and accurate recording and documentation.

The Business Code of Ethics section defines the ethical values and principles that guide our business actions and decisions. It sets standards of professional and ethical conduct and covers topics such as respect, honesty, non-discrimination and the protection of intellectual property.

The Implementation and Monitoring section describes how these policies will be implemented, including employee training and awareness, the establishment of a confidential reporting procedure and periodic monitoring and auditing. It also sets out the sanctions and consequences of violating the policies.

The Evaluation and Continuous Improvement section highlights the importance of periodically evaluating compliance with the policies and constantly looking for ways to improve them. It emphasizes effective communication and dissemination of the policies, as well as collaboration with stakeholders to foster a culture of compliance and business ethics.

The Reporting Channels section sets out the different channels through which reports can be submitted on activities that breach any policy or rule established in this document.

The Compliance, Anti-Corruption and Business Code of Ethics policies are fundamental to INEFAM's success and reputation. They will be reviewed and updated periodically to keep up with best practices and the highest standards in a changing business environment.

Section 1: Introduction and Ethical Commitment.

1.1 Scope:

The codes and policies established in this document apply to the following companies established in Mexico: INSTITUTO FARMACÉUTICO, S DE RL DE CV, INSTITUTO DE INVESTIGACIÓN E INNOVACIÓN FARMACÉUTICA, AC, as well as to our legal entity in Sao Paulo, Brazil: INEFAM DO BRASIL SERVICOS DE MERCADO LTDA.

1.2 Trade names:

All the legal entities, jointly or separately, operate under the name INEFAM® or INEFAM-LATAM®.

1.3 Business purpose:

At INEFAM we provide market research, specialized training and business consulting services specializing in the healthcare sector.

1.4 Compliance, Anti-Corruption and Code of Ethics:

We recognize the importance of maintaining the highest ethical standards and complying with the applicable laws and regulations in every aspect of our operations. This document sets out our Compliance, Anti-Corruption and Business Code of Ethics policies to guide our employees' conduct and promote integrity in all our business activities.

1.5 Ethical Commitment:

At INEFAM, we are committed to honesty, transparency and accountability in all our business interactions. We undertake to comply with all relevant laws and regulations and to act ethically and professionally at all times. As part of our commitment, we establish the following Compliance, Anti-Corruption and Business Code of Ethics policies:

Section 2: Compliance Policy

2.1 Definition of Compliance:

The term "compliance" refers to adherence to the laws, regulations, policies and standards that apply to an organization. It is a set of practices and procedures designed to ensure that a company operates ethically, legally and responsibly in all its business activities. The scope of compliance covers various areas and aspects of an organization, including:

• Legal compliance: respecting and adhering to all the laws and regulations in force in the countries where the company operates. This may include labor, tax, consumer protection, environmental and data protection laws, among others.
• Internal policies and procedures: establishing and maintaining internal policies and procedures aligned with legal and ethical requirements and with industry standards. These may cover areas such as risk management, information security, anti-money laundering and fair competition, among others.
• Business ethics and conduct: promoting an ethical culture within the organization that fosters values such as honesty, transparency, integrity and respect. This involves setting standards of professional and ethical conduct for employees, as well as mechanisms to report and address any ethical concern or violation.
• Corruption prevention: establishing policies and controls to prevent corruption and bribery, both within the organization and in interactions with third parties such as suppliers, clients and public officials. This may include implementing training programs, reviewing gift and hospitality policies, and adopting supervision and control measures.

The main objective of compliance is to ensure that the company operates ethically and legally, protecting its reputation and minimizing legal and financial risks. Compliance can also help build strong relationships with clients, suppliers, regulators and other stakeholders by demonstrating a firm commitment to integrity and corporate responsibility.

2.2 Legal Compliance:

At INEFAM, we are committed to complying with all the applicable laws, regulations and rules in all our business operations. We make sure that all our employees know and comply with the relevant laws and regulations related to their work. This includes, but is not limited to: the labor legal framework, data privacy laws, consumer protection laws and fair competition laws.

2.3 Data Protection and Privacy:

We recognize the importance of protecting the privacy and confidentiality of our clients' and employees' information. We are committed to complying with the applicable data protection laws and to implementing appropriate security measures to protect confidential information against unauthorized access, disclosure or misuse.

2.4 Risk Management:

At INEFAM, we understand the importance of identifying and managing the risks associated with our business operations. We have implemented appropriate procedures to assess and mitigate potential risks in key areas of our business, such as information security, legal compliance, financial management and relations with third parties.

2.5 Training and Awareness:

We provide appropriate training and resources to ensure that our employees understand and comply with our Compliance policies. We raise awareness of the importance of legal and ethical compliance, and we encourage our employees to report any concern or suspected violation of our Compliance policies.

2.6 Extension of Compliance:

At INEFAM we are committed to including within this scope all the policies and practices required by our clients, whether their scope is national, regional or global.

Section 3: Anti-Corruption Policy

3.1 Definition of Anti-Corruption Policy:

An anti-corruption policy is a set of rules and guidelines established by an organization to prevent and fight corruption in all its forms. This policy seeks to promote transparency, integrity and compliance with the laws and regulations related to corruption. It sets clear guidelines on the conduct and actions to follow to avoid bribery, extortion, embezzlement and other corrupt practices. The anti-corruption policy seeks to ensure that all of the organization's business activities are carried out fairly, ethically and legally, and establishes mechanisms to identify, report and address any suspicion or act of corruption.

3.2 Prohibition of Bribery and Corruption:

At INEFAM, we are committed to maintaining the highest standards of integrity and ethics in all our business activities. We strictly prohibit bribery, corruption and any form of misconduct. We do not allow any employee or representative of the company to offer, solicit, accept or give bribes or illegal incentives to any person or entity, whether public or private.

3.3 Relations with Public Officials:

Our company adheres to the applicable laws and regulations related to interactions with public officials. All employees must comply with anti-corruption laws and avoid any activity that could give rise to a conflict of interest or violate the relevant laws and regulations.

3.4 Gifts and Hospitality:

All employees and representatives of the INEFAM companies are prohibited from offering or accepting gifts, entertainment or hospitality in the course of our business activities. It is prohibited to offer or accept gifts, payments or benefits that are excessive, that may unduly influence decision-making or that violate the laws or policies of the company with which we have a business relationship.

3.5 Accurate Recording and Documentation:

We keep accurate and complete records and documentation of all our business transactions. It is every employee's responsibility to make sure that records accurately reflect the transactions carried out and meet legal and accounting requirements.

Section 4: Business Code of Ethics

4.1 Definition of Business Code of Ethics.

A business code of ethics is a set of principles and values that guide an organization's behavior and decisions in the business environment. This code sets standards of professional and ethical conduct for all the company's employees and defines expectations regarding integrity, honesty and respect in all business interactions. The business code of ethics provides guidance on how to treat clients, suppliers, competitors and other stakeholders fairly and equitably. It also fosters an inclusive work environment free of discrimination, promoting the organization's trust and reputation. This code is a fundamental guide to ensure that all business activities are carried out ethically and responsibly, and that the company meets the highest ethical standards in all its operations.

4.2 Ethical Values and Principles:

At INEFAM, we are governed by a set of ethical values and principles that guide our business actions and decisions. These values include honesty, transparency, accountability, respect and integrity. We are committed to acting in accordance with these values in all our business interactions.

4.3 Professional Conduct:

We require all employees to maintain high standards of professional conduct. We expect them to treat others with respect, honesty and fairness. We do not tolerate harassment, discrimination or any form of inappropriate behavior. We promote an inclusive and safe work environment for everyone.

4.4 Conflict of Interest:

It is every employee's responsibility to avoid situations that could give rise to a conflict of interest. If a potential or actual conflict of interest arises, employees must disclose it immediately to the company's management. We will work to manage conflicts of interest fairly and transparently.

4.5 Protection of Intellectual Property:

We respect and protect the intellectual property of other people and organizations. We will not use third-party information or intellectual property without proper authorization. At the same time, we will protect our own intellectual property rights and promote respect for intellectual property rights in general.

Section 5: Implementation and Monitoring

5.1 Training and Awareness:

At INEFAM we are committed to providing regular training on our Compliance, Anti-Corruption and Business Code of Ethics policies to all employees. This will include initial training upon joining and periodic updates to ensure that everyone is aware of the policies and understands their responsibilities.

5.2 Reporting Procedure and Non-Retaliation:

We foster an environment in which employees feel safe and encouraged to report any concern about possible violations of our policies. We will establish a confidential reporting procedure and ensure that there is no retaliation against those who report violations or suspected violations in good faith.

5.3 Monitoring and Auditing:

We will implement a monitoring and auditing program to evaluate and verify compliance with our Compliance, Anti-Corruption and Business Code of Ethics policies. We will carry out periodic reviews to identify possible areas for improvement and take corrective action when necessary.

5.4 Sanctions and Consequences:

In the event of a violation of our policies, we will take appropriate and proportionate measures to address the situation. This may include disciplinary action, additional training, changes to internal processes or termination of employment, as applicable. We will make sure that sanctions are consistent and applied fairly and equitably.

Section 6: Evaluation and Continuous Improvement

6.1 Compliance Evaluation:

We will carry out periodic evaluations to measure compliance with our Compliance, Anti-Corruption and Business Code of Ethics policies. We will use metrics and feedback mechanisms to identify areas for improvement and take corrective action when necessary.

6.2 Continuous Improvement:

We are committed to constantly looking for ways to improve our policies and practices related to compliance, corruption prevention and business ethics. We will keep track of changes in the relevant laws and regulations and adapt our policies accordingly, to keep up with best practices and the highest standards.

6.3 Communication and Dissemination:

We will ensure that our Compliance, Anti-Corruption and Business Code of Ethics policies are communicated clearly and effectively to all employees. We will provide easy access to the policies and offer opportunities to address questions and clear up any doubts employees may have.

6.4 Collaboration with Stakeholders:

We will promote collaboration and dialogue with our stakeholders, including clients, suppliers and business partners, to foster a culture of compliance and ethics throughout the value chain. We will work closely with them to ensure that we share the same values and ethical standards in our business interactions.

These Compliance, Anti-Corruption and Business Code of Ethics policies are fundamental to INEFAM's success and reputation. We will review and update these policies periodically to make sure they remain relevant and effective in a changing business environment.

Section 7: Reporting Channels

7.1 Confidential Reporting Channel:

At INEFAM, we value transparency and ethics in all our business activities. We recognize the importance of providing a safe and confidential channel through which employees, clients, suppliers and other stakeholders can report any concern or suspected violation of our policies or of the rules established in this document.

We have established a Confidential Reporting Channel that allows anyone to communicate, safely and confidentially, any activity that breaches any of our policies or rules established in this document. This channel is available 24 hours a day, 7 days a week, and guarantees the confidentiality and anonymity of those who wish to make a report.

7.2 Reporting Procedure:

To make a confidential report, any of the following means can be used:

• Confidential phone line: We have established a confidential phone number that can be called to make a report. This number is made available to all employees, clients and suppliers: +52-55-5432-8286To be confirmed
• Confidential email: A confidential email can also be sent to info@inefam.com. This email address guarantees the confidentiality and anonymity of the sender.

7.3 Report Handling Process:

All reports received through the Confidential Reporting Channel will be treated seriously and confidentially. A designated team within INEFAM will be responsible for evaluating and handling each report appropriately.

It will be ensured that all reported concerns or violations are investigated impartially and thoroughly. The necessary measures will be taken to address the concerns, and the corresponding corrective action will be taken if a violation is confirmed.

7.4 Protection against Retaliation:

At INEFAM, we are committed to protecting those who make reports in good faith. We do not tolerate any form of retaliation or negative consequence against those who report concerns or violations of our policies. Any form of retaliation will be treated seriously, and appropriate measures will be taken to protect whistleblowers.

7.5 Confidentiality and Anonymity:

We understand the importance of confidentiality and anonymity when making a report. All reports received through the Confidential Reporting Channel will be handled confidentially, and the whistleblower's anonymity will be guaranteed unless explicit permission is given to reveal their identity.

At INEFAM, we encourage all employees, clients, suppliers and other stakeholders to use the Confidential Reporting Channel if they have any concern or suspicion of a violation of our policies. We promote a culture of integrity and accountability, and reporting any inappropriate activity or violation of our policies is essential to maintaining high ethical standards in our company.

When using the Confidential Reporting Channel, you are expected to provide as many details and as much available evidence as possible about the reported concern or violation. This will help us investigate more effectively and take the appropriate measures to address the situation.

It is important to stress that all reports will be treated confidentially and handled with the highest level of security. Only those in charge of handling reports will have access to the information provided, and the necessary measures will be taken to protect the whistleblower's identity, should they wish to remain anonymous.

At INEFAM, we are committed to taking all concerns and reports seriously and to addressing them in a timely and appropriate manner. We value transparency, ethics and accountability, and we are committed to maintaining a safe and ethical work environment for all employees and stakeholders.