Karlos Enterprises SA and its subsidiaries (collectively the “Company”) have adopted this Code of Ethics and Anti-Bribery Policy (the “Code”) for all the Company’s employees, officers, or agents (“Employees”).

Our Code of Ethics affirms our commitment to upholding high moral and ethical principles and specifies the basic norms of behavior for those conducting business on its behalf. While our business practices must be consistent with the business and social practices of the communities in which we operate, we believe honesty is the essential standard of integrity in any locale. The company’s activities are to be based on honesty, integrity, respect, and compliance with all applicable laws, including those laws which prohibit bribery and corruption.

The objective of this Code is to provide guidance and procedures to ensure that the Company conducts business in an honest and ethical manner when dealing with Government Officials and all other parties, and in compliance with all applicable laws and regulations pertaining to bribery and corruption.