Code of Ethics

Introduction

The Code of Ethics reflects the commitment to the highest standards of integrity, accountability and transparency. This document aims to guide the behavior of all employees, suppliers and stakeholders in the company, ensuring that operations are carried out ethically and in compliance with applicable laws and regulations. Adhering to the principles is essential to maintaining a professional, safe and ethical work environment, thus ensuring the continued success of our company and the satisfaction of our customers.

Purpose

The code establishes the fundamental principles and values that guide the company’s daily decisions and relationships with customers, suppliers, collaborators and the community in general. An environment of respect, diversity and sustainability is promoted, ensuring that each action taken is as expected, preventing potential conflicts.

Scope

This Code has mandatory rules for the behavior of all managers and employees of the Company. Likewise, this Code includes rules and principles that regulate the relationship and behavior of the Company’s managers and employees with its suppliers and customers, as well as their relations with political parties, employees and public officials.

Delver Agents expects its customers, suppliers, and contractors to comply with the standards and principles of this Code.

Mission, Vision, and Values

Mission

To be a global leader in maritime and forwarding operations logistics, providing maximum satisfaction and supporting the continuous growth of our partners and team members.

Vision

To consolidate our position as a global leader in maritime and shipping logistics, providing comprehensive and high-quality services and maintaining environmental responsibility. Leveraging our tools, knowledge, dedication and expertise, we collaborate closely with our customers and partners, anticipating their needs and creating customized solutions to ensure the success of all global operations.

Values

• Commitments and passion for everything we do
• Always operating ethically with integrity
• Focused on sustainability
• Continuously innovating to drive improvement

Commitment to Quality

Operational Excellence

We are committed to performing our work with the highest quality and professionalism, adopting best practices and industry standards.

Continuous Improvement and Innovation

We encourage continuous improvement and innovation, promoting constant training and the adoption of new technologies and methods.

Customer Relations

All company interactions are based on respect, transparency and honesty, maintaining clear and respectful communication with customers, avoiding the use of inappropriate language and any type of discrimination. Delver Agents is committed to ensuring customer satisfaction by delivering high-quality products and services that meet the highest standards in the market.

The confidentiality of customer information is rigorously protected, in strict compliance with data protection laws. Environmental awareness and education are encouraged, promoting responsible practices in operations and with stakeholders. Any form of corruption or immoral conduct in business relations is rejected. Gifts to customers will only be allowed if they are symbolic and authorized by the company, to avoid compromising the integrity of the parties.

Conduct contrary to this Code of Ethics may be reported anonymously. In all our actions, we act with transparency and responsibility, always seeking to generate trust and strengthen our relationships with the different actors that are part of our environment.

Supplier Relations

At Delver Agents, ethical and transparent relationships are maintained with suppliers, they are selected through fair processes, based on quality, performance and cost criteria. Suppliers are expected to meet the highest standards of ethics and integrity, following all applicable laws and regulations where they operate, and respecting human rights, including standards on decent work, non-discrimination, and freedom of association.

Suppliers must ensure a safe working environment, fair working conditions, and prohibit child and forced labor. In addition, they must commit to minimising their environmental impact by responsibly managing waste and emissions, using sustainable materials and promoting energy efficiency.

Any form of corruption, bribery, money laundering is prohibited, and gifts must be symbolic and not compromise the integrity of the parties. The confidentiality of Delver Agents’ information must be protected, and its use must be limited to its intended purposes.

Compliance with this Code of Conduct is mandatory in order to maintain the relationship with Delver Agents, and the company reserves the right to audit suppliers to verify that these standards are being followed. Any non-compliance can be reported through the confidential whistleblowing channel, and could result in the termination of the contract.

For more information on the relationship with suppliers, please refer to the Code of Conduct for suppliers.

Relationship with Collaborators

At Delver Agents, we aspire to create a safe, inclusive and respectful work environment, where each employee has the opportunity to fully develop. We promote diversity and non-discrimination, guaranteeing equal opportunities and rejecting any form of harassment or exclusion. All employees must comply with occupational health and safety regulations, using the necessary protective equipment and notifying any risk they identify. In addition, they must avoid having their business decisions influenced by personal interests, reporting any conflicts of interest to their superiors.

The different relationships that may arise between employees should not interfere with performance within the company, nor modify their usual tasks. Mutual respect, tolerance and a positive work environment are fundamental pillars at Delver Agents. Joint problem-solving is essential to maintaining an environment of trust, openness, and respect.

Compliance with this Code of Ethics is essential to working at Delver Agents. Employees have the responsibility to report any activity that puts health, safety or the environment at risk, ensuring that our operations are ethical and safe at all times. Joint problem-solving is essential to maintaining an environment of trust and respect.

Asset and Information Protection

All employees of Delver Agents are responsible for using the company’s assets efficiently and responsibly. Company resources are provided to enable employees to perform their jobs effectively, and they must be cared for and used appropriately.

Use of Care of Company Assets

• At Delver Agents, assets such as mobile phones, vehicles, computers, and corporate emails must be used exclusively for work purposes, respecting internal policies.
• Employees are expected to use these assets as if they were their own, taking care of them, avoiding waste and preventing any abuse.
• Each employee is responsible for the assets under their control, so they must protect them from damage, misuse, loss, theft or theft, always following the internal policies and regulations in force.
• To ensure the proper use of assets, Delver Agents will implement control measures in accordance with current labor regulations, in order to monitor and protect the company’s resources.

Trade Secrets

• All the information, ideas and technology developed in the company is part of the intellectual heritage, and it is the duty of all employees to protect it and maintain confidentiality, unless it is necessary to comply with the company’s obligations.
• The data of customers, suppliers and employees held by the company are protected by the Personal Data Protection Law and are governed by secrecy and confidentiality.
• Copying, adapting, or publishing copyrighted material without proper authorization is strictly prohibited.

Conflicts of Interest

• A conflict of interest arises when an employee uses their position in the company to benefit their own interests, those of their immediate family members, or any other personal relationship.
• Employees should avoid situations that could compromise their objectivity or give the impression that they cannot act impartially for the benefit of the company.
• It is the responsibility of each employee to report any situation that may constitute a conflict of interest to their immediate supervisor or to Human Resources. The company will take the necessary measures to manage any conflict that arises.

Commitment to Caring for the Environment

The risks inherent to operations are identified to mitigate potential impacts and develop innovation opportunities aligned with sustainability principles. The company understands that these risks not only derive from its direct activity, but also from the commercial relationships within its value chain. Among the main risks identified are:

• Greenhouse gas emissions
• Management of discharges and ecological impacts
• Customer relationship management
• Employee health and safety
• Ethics and business integrity
• Management of impacts in the supply chain
• Management of supply chain impacts

All employees of Delver Agents must participate in the development and compliance of the policy elaborated that deals with the environment, health and safety, which includes compliance with all external and internal requirements applicable in the area.

Delver Agents is committed to implementing best practices to reduce emissions, properly manage waste, and promote a safe work environment. In addition, it seeks to actively collaborate with its suppliers and partners to ensure that they also adopt sustainability standards, contributing to a responsible value chain aligned with environmental and social principles.

Business Conduct

The activities of Delver Agents must not endanger the environment, health or safety of those who work within this company or use its services. Therefore, it is committed to maintaining the highest ethical standards in all its commercial and operational activities. The company expects all its employees, suppliers and partners to adhere to fundamental principles of integrity, transparency and accountability.

Inquiries and Complaints Channel: Delver Agents provides its employees with a confidential and secure whistleblowing channel to report any violation of this Code of Ethics. Employees and business partners can use this channel to make inquiries about ethical situations and report any wrongdoing. The company guarantees the confidentiality of the whistleblower’s identity, unless required by a court order.

Complaints must be sent through the company’s confidential email: asistencia@delveragents.com. Each report will be investigated impartially, and corrective action will be taken if necessary.

Training and Compliance

Delver Agents recognizes the importance of continuous training to ensure that all employees understand and comply with the principles established in this Code of Ethics. Although mandatory training varies according to the role and specific needs of each area, the company maintains a general commitment to the training and development of its employees on topics related to ethics, safety and legal regulations. All employees must sign this Code of Ethics as confirmation that they have read and understood it, and that they undertake to respect the ethical rules and principles established herein.

Exceptions to the Code

Delver Agents acknowledges that, in certain circumstances, exceptions to the Code of Ethics may be necessary. Any exceptions to the rules and principles contained in this code must be approved by the company’s senior management. Exceptions will not be granted arbitrarily, but based on a rigorous assessment of the situation.