I. Introduction

Article 1.- Purpose.

1. This document contains the Code of Ethics of Villar & Villar Abogados, S.C., and/or any other of the companies of the Group VILLAR^® (hereinafter, VILLAR & VILLAR, the Firm or the Group) and was approved by the Board of Administration on January 4, 2021, prior report from the Committee of Professional Practice.
2. The Code of Ethics contains the values and principles that inspire the identity of the Law Firm, as well as the rules and behavior patterns that are requested to the members of VILLAR^® in its relations both with the Firm and the other members, as with clients and third parties in general.
3. The Code of Ethics has been prepared taking into account the principles of social responsibility assumed by the Law Firm for its follow-up by the Firm and by each and every one of the people who are part of it.
4. The group of these values, principles, standards and guidelines for behavior constitutes the ethical model of behavior that should inspire and preside, at all times, the actions of the members of the Law Firm, aimed at promoting ethical and responsible behavior and reflects the commitment of VILLAR^® with principles of business ethics and transparency in all its fields.
5. This Code of Ethics is part of the Internal Regulatory System of VILLAR^®, which is the group of policies, process, programs, rules, codes and regulations approved by the competent organs of the Firm, of internal character and of obligatory compliance for all of the members of VILLAR^®.
6. Without prejudice to any other responsibilities in which it would have incurred, the violation of provisions in this Code of Ethics or of other provisions of the Internal Regulatory System of the Firm shall be punished, by VILLAR & VILLAR, pursuant to the applicable regulation.

Article 2.- Area of application.

1. The values, principles, standards and guidelines of conduct contained in the Code of Ethics are applied, and must be met by all members of VILLAR^®, regardless of their hierarchical level, geographical or functional location or society of the Group for which they provide their services, who assume, in this condition, the commitment to comply with it as well as their loyal collaboration in its implementation and application. All references to VILLAR^®, the Law Firm, the Firm or the Group and its members in this Code of Ethics should be understood as made to all the companies of the Group and its respective members.
2. For effects of this Code of Ethics, shall be considered as members of VILLAR^® partners, associates, employees, collaborators, paralegals and interns of all companies and entities that integrate the Group, as well as other people whose activity is expressly subject to the Code of Ethics.
3. Compliance with the Code of Ethics is understood without prejudice to the strict compliance with the applicable rules, ethical standards and other provisions of the Internal Regulatory System of VILLAR^® that result from its application.
4. In the case of partners, this Code of Ethics complements the statutory obligations that link to partners as a result of their participation in VILLAR^® and the Partner’s Code of Conduct.
5. Any questions that may arise, to the members of the Law Firm, regarding the application or the interpretation of this Code of Ethics or of the rest of the provisions of the Internal Regulatory System of the Firm, may consult, in its case, with the immediate hierarchical superior or through the e-mail address: contacto@villarabogados.com.mx, being these taken care and solved by the Senior Partner which will have help by the Committee of Professional Practice.

Article 3.- Acceptance and compliance.

1. All members of VILLAR^®, by the mere condition of such, accept through the annual signature of a responsible statement, values, principles, regulations and guidelines of conduct established in this Code of Ethics, which free and voluntarily commit themselves to know, comply with and enforce.
2. People who, in the future, join VILLAR^® will expressly accept the values, principles, regulations and guidelines of conduct established in this Code of Ethics, which will be attached to their respective contracts.
3. The acknowledgment by the members of VILLAR^® of the vision, the values and regulations stated in this Code of Ethics and the commitment of knowing them, complying with them and enforcing them, together with the rest of the provisions of the Internal Regulatory System of VILLAR^®, constituting an essential element of their relationship with the Law Firm.

II. Values and Principles

Article 4.- Fundamental Values And Ethical Principles..

1. VILLAR^®, as a Law Firm, has a clear and firmly established identity projected both in the internal area of the Firm and among its members, as in the relationship with customers and to society in general and which are based on excellence in customer’s service, commitment to people and professional ethics and independence.
2. The values and principles that inspire this identity are summed up, most prominently in the following:
   Fundamental Values:
   1. Commitment to customer service.
   2. Commitment with quality
   3. Commitment with the Firm and its members.
   4. Commitment with ethical behavior.
   Ethical Principles:
   1. Integrity.
   2. Loyalty.
   3. Independence.
   4. Permanent formation.
   5. Dignity and respect.
   6. Professional secrets.
3. These values and principles are linked together in an inseparable way and all the members of the Law Firm have the duty to comply with them and to preserve them and responsibility to transmit them in its activity at the Firm, always with full respect for the applicable regulations.

Article 5.- Commitment to customer service

1. The Firm’s activity is oriented to the satisfaction of the legitimate interest and needs of the clients, which implies not only a technical request but also unavoidable:
   1. Constant dedication to the client;
   2. Know and understand, in a complete way the objectives and needs of the client, facilitating at each moment , the appropriate solutions; and
   3. Commitment –without loss due to the independence- with the interests of the client with their defense.
2. Ultimately, the goal of all the members of the firm must be not only the achievement of professional excellence, with all that they imply, but also and in particular, the customer satisfaction as to the valuation and perception of our professional services are concerned.
3. This vocation of service demands, in turn, always to maintain an open and sensitive attitude to suggestions that the client transmits (either by their own initiative, or as result of the measures and actions promoted by the Firm to know their opinion about the quality of the work carried out and their degree of satisfaction) and a permanent willingness to adopt actions were accurate to correct any deficiencies or errors and to introduce permanent improvements in the professional activity.

Article 6.- Commitment with quality.

1. The provision of professional services must be presided over by the highest levels of quality, to the object that the client obtains, at all times, the most appropriate and effective solution in the entrusted case.
2. This demand of quality requires that all members of the Firm pay the most attention to the permanent formation in the areas of their specialties, both in the strictly personal level, with the appropriate supervision of those colleagues that with less professional experience, collaborate with them, this being in a regular manner or carrying out a specific professional task.
3. Also, this commitment with quality implies always having available for the client and all the members of the Firm the most advanced technological instruments that make possible a fluid communication and that facilitate a more agile and efficient provision of required services.
4. VILLAR^® will have the rules and internal processes appropriate for securing maximum quality in the provision of their services and will be of cutting edge in the acceptance of standards that contribute to improve their own internal controls of quality.

Article 7.- Commitment with Firm and its members.

1. All members of VILLAR^® recognize the value of the Firm as a collective institution, both in its internal aspect and the relationship with the client and professional services to this.
2. In the internal area, this quality implies and requests:
   1. Sharing with the rest of the members of the Firm, with generosity and interest of all, professional knowledge and experience;
   2. Avoid internal competitions among the members of VILLAR^®, giving preference at all times the interests of the Firm, as a collective, the particulars of each Member or the group they are part of, though, among other measures, the promotion and respect to the specialization of teams;
   3. Commit to future generations, according to their merits and abilities, have the necessary means and appropriate opportunities for the development of their career at the Law Firm; and
   4. Enable the appropriate course of communication, in order to facilitate the access to training of young people, the close relationship with the other members and analyzed and fair evaluation of the professional merits of each and every one of them.
   In the external area, this quality implies and requests:
   1. The ability to perform and coordinate teamwork in a harmonious and proportionate way;
   2. The need to offer the client an integral service and, at the same time, specialized, resorting to it professionals who have the appropriate preparation and experience in the type of case, the client on each occasion entrusts; and
   3. The fair, objective and examined conduct in the analysis and resolution of potential situations of conflict of interests that may arise, as well as the acceptance or refusal, in its case, of new cases, all from the joint perspective of the Law Firm with strict observance of ethical standards and in the best interest of the clients

Article 8.- Commitment with ethical action.

1. VILLAR^®’s professional activity lies in the field of Law - in its broadest sense and in its various manifestations, with special incidence in the field of Business Law.
2. The Law Firm is firmly committed to the ethical performance in the provision of their services. VILLAR^® members not only have to act, in the development of their work, with strict compliance with the law, but in any case, they must refrain from doing any action or, advice that, while respecting the law, could - by the circumstances of the specific case – be considered as objectionable or questionable from an ethical or deontological perspective.
3. In particular, all members of the Law Firm assume the commitment to adopt the measures necessary to detect and correct any actions contrary to this rule of conduct.

Article 9.- Integrity.

1. VILLAR^® is based on strict and continuous observance of fair, reasonable and honest behavior by its members, in the exercise of their work both in the field of personal performance.
2. There’s no place for deception and unfair advantage. Opinions should be expressed clearly, respecting any other that doesn’t coincide and professional advice should be based not only on technical knowledge, but also good judgment and prudence of the professional who issues it.
3. VILLAR^® aspires, through their line of conduct, to deserve as a Firm total confidence from their clients, of colleagues, the business community they serve and society where they are integrated.

Article 10.- Loyalty.

1. The principle of loyalty presides in the group of reciprocal relations, rights and obligations where VILLAR^® builds their identity as a Firm.
2. Externally, the main expression of this principle is constituted by predominance of the legitimate interests of the client over any other type of purpose.
3. From the internal perspective, openness, solidarity, honesty, friendship and mutual respect are the basic pillars upon which the relations between the members of the Firm are based.

Article 11.- Independence.

1. Independence constitutes the basic principle of the effective right of defending the client and the quality of professional advice, at the same time an ethical requirement of essential character.
2. Only in a situation of total independence of judgment and action is available to guide fully, on behalf of the client, the professional capacity (without elements that limit, modify or restrict it), all this without prejudice to the necessary coordination of a legal opinion of the Law Firm on complex legal issues, and in order to avoid discrepancies that may confuse the client.
3. Consistent with the expressed, all professionals of the Firm will abstain in participating in any way, in all matters that in an indirect or direct way may be affected by their personal, family interests or of those belonging to a circle of close friends or when the independence may be affected or harmed by any other reason or circumstance.
4. Also, and in the institutional area, the Firm will excuse any participation of any type of matter that entails a conflict or collision of interests with one that is already accepted, unless waived by the concerned client or clients.
5. The professionals of VILLAR^® will apply and follow, without exception, the processes established by the Firm that allows analyzing the situation of independence before proceeding to the acceptance of a new task or professional case.

Article 12.- Permanent Training.

1. VILLAR^® grants the maximum importance of permanent formation to their members, not only as essential budget to achieve technical quality required by the provided advice, but also as necessary and ineludible instrument for the full development and promotion of the professionals.
2. From this perspective, the formation not only constitutes a basic principle in the management and organization of the Firm, as an institution, but also a personal obligation of each and every one of its members, who should aspire to specialization, to delve in technical knowledge, to increase their experiences and reveal to others: of the veterans to the youngest, from offices to others, and from the Law Firm to the clients and society in general.
3. To facilitate such purposes, VILLAR^® (continuously and periodically) promoting the organization of courses and seminars of formation, update and specialization; it broadcasts many regulatory, scientific and legal precedents are released; coordinates, after the corresponding analysis between their experts, legal complexities to form an authoritative opinion and offers to its members the most advanced technological instruments in the various fields of its activity.

Article 13.- Dignity And Respect.

1. The behavior of the members of the firm with clients, opposing parties, courts, public authorities and third parties in general, should be presided by the principles of honesty, righteousness, loyalty, dignity, respect and diligence, thereby honoring the name of VILLAR^® and their public image as an institution.
2. In addition, members of VILLAR^®, in the internal area of the Firm, will act at all times under the principles of honesty, righteousness, loyalty, dignity, respect and diligence.
3. In the same way, the behavior with colleagues, both with those who do not belong to the same, both members of the firm must be always worthy and be guided at all times by the friendship and respect, avoiding unnecessary conflicts and facilitating harmony and cordiality.

Article 14.- Professional Secrecy.

1. The secrecy and confidentiality are, at the time that rights, inalienable duties of members of VILLAR^® and reach all the facts or news that they have knowledge of by reason of any of the modalities of its action.
2. This should comprehend both issues where each member as well as the rest of the members of the Law Firm they intervene personally, who must respect this ethical principle to all members of VILLAR^® who collaborate in the professional activity.
3. Internal communication, for strictly educational purposes, prevention of conflicts of interest, or for the compliance of obligations (prevention or other) legally established is permitted, although it is also subject to professional secrecy, in the terms established in the laws and Internal Regulatory System of VILLAR^®.

III. Adhesion To The Global Compact

Article 15.- Adhesion To The Global Compact.

1. VILLAR^® fits to the United Nations Global Compact and devotes its best efforts to materialize this commitment.
2. This international initiative proposed by the United Nations aims to achieve a voluntary commitment of the institutions of social responsibility, through the implementation of the ten principles based on human, labor, environmental and anti-corruption rights, which VILLAR^® has present at all times.

IV. Professional Behavior

Article 16.- Compliance With Regulations And Internal Rules And Policies.

In exercising their tasks, the members of VILLAR^®:

1. Must comply with the valid regulations where they carry out their work;
2. They are bound to strict compliance with ethical standards, approved by their respective boards and schools, regulate their professional practice;
3. Should know, observe and comply with the provisions of the Internal Regulatory System of the Law Firm; and
4. Should assume and recognize as their own, through their freely consented acceptance, the values and principles set forth in the Code of Ethics and in the other provisions of the Internal Regulatory System of VILLAR^®.

Article 17.- Respect of Human Rights

1. VILLAR^® practices a policy of respect for human rights that focuses, among others, in the adhesion to the previously mentioned United Nations Global Compact.
2. VILLAR^® does not allow, nor tolerate, discrimination by reason of race, color, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political views, religion or any other personal, physical or social conditions of its members, and promotes equal opportunities.
3. Particularly, the Law Firm promotes the equality of treatment between men and women and rejects any manifestation of harassment, abuse of authority, violence or any other behaviors that create intimidating or offensive work environment for the personal rights of their members.

Article 18.- Prevalence Of The Interests Of The Law Firm.

1. In their performance with the Firm and the clients, the members of the Law Firm recognize the importance and value of VILLAR^®, as a group (different and greater than the mere aggregation of individuals that integrate it), whose interests are and must be always and at all times above the interests and/or particular priorities of the members that integrate the Law Firm.
2. Therefore, members of VILLAR^®, aware of the prevalence of VILLAR^®’s interest over their own, are committed to respect and comply with this principle, to adopt it as a pattern of behavior in their relationships and decisions resulting from their competition, both external (with clients and third parties) as internal (with the rest of the members of the Law Firm) and to defend, without any reservation, the interests of the Firm for the benefit of the group always with total respect for the legal, ethical and professional standards.

Article 19.- Information processing.

1. VILLAR^® members have access to (and entrusted to them) information belonging to the Law Firm and its clients, which will be integrated, merely illustrative, by any information, document, data, products, procedures, methods, forms, models, client list or jobs and, in general, any other knowledge or information related to their work as well as any other business secrets or confidential information or of internal character and organization of the Law Firm.
2. The information is, in full extent and whatever support it’s in, will be reserved and confidential, being at all times subject to - specifically and without limitation in time –the duty of secrecy. VILLAR^® members may not directly or indirectly use the information, nor announce, disclose, provide, copy, reproduce or make it available for use, in favor of third parties or for their own use, except in cases where this is necessary for the correct compliance of their obligations and functions in the Law Firm.

Article 20.- Conflict of interests.

1. For VILLAR^® verification has a fundamental importance, always and in any case and correctly, of potential conflicts of interest that could be raised due to performance of the Firm in a case. Such verification should be made in any case (both for new clients and new cases entrusted by the preexisting) given that, for the number of clients and the diversity of professionals responsible for these, the concurrence of cases that pose a potential conflict of interest, should be detected and solved prior to accepting a case.
2. Conflict of interests should be properly verified to avoid incurring in breach of legal, ethical and professional standards that protect professional secrecy or any other duty.
3. It is of obligatory observance the internal legislation of VILLAR^® in matter of checking and resolution of conflicts of interest, which should be followed by all members of the Law Firm.

Article 21.- Gifts and invitations.

1. Members of VILLAR^® may not under no circumstances give or accept gifts or invitations in the performance of their tasks, except when they are of irrelevant or symbolic economic value and respond to signs of courtesy or usual commercial attentions, or when it concerns invitations that have the consideration of ordinary or usual in accordance with social uses by being within sensible and reasonable limits. In any case, gifts or invitations that are prohibited by the applicable legislation or those that may condition the professionalism and independence or influence in professional decision taking will not be accepted.
2. VILLAR^® members may not, directly or through intermediary, offer or grant, nor request or accept, not justified advantages or benefits having the immediate or mediate purpose to obtain a profit, present or future, for VILLAR^®, for themselves or a third party. In particular they may not give or receive any form of bribery, commission, coming from, or carried out by, any other party involved, as public, Mexican or foreign officials, staff from other companies, political parties, authorities, clients, providers and suppliers. Acts of bribery, expressly forbidden, include the offer or promise, directly or indirectly, any type of improper advantage, any instrument for the cover-up as well as traffic of influence.
3. Also they may not receive, by personal title, money from clients or suppliers, nor in any form of loan or advance, all regardless of loans or credits granted to the members of VILLAR^® by financial institutions that are clients or suppliers of the Law Firm and are not falling into the above mentioned activities.

Article 22.- Appropriate Use Of The Law Firm’s Resources.

1. The Law Firm offers its members resources and the appropriate and necessary means for the development of their professional activity.
2. The members of the Firm are committed to make appropriate use and in accordance with the policies and internal rules stated regarding the resources that the Law Firm puts at their disposal, using them only for the development of their professional activities and avoiding its particular use, except as exceptional and justified ways in accordance with the objective parameters and reasonableness.
3. VILLAR^® is the owner of the property and rights of use and exploitation of programs and computer systems, equipment, manuals, studies, reports, legal opinions, contracts and any other work that has been created by members of VILLAR^® in the framework of their professional activity.
4. The use of resources by the members must be responsible and adjusted to the safety criteria, avoiding any illicit use, contrary to applicable regulations, existing standards and internal policies or to this Code of Ethics.

Article 23.- Business opportunities.

1. VILLAR^® members cannot use by their own benefit, or of third parties, business opportunities which, by their nature, correspond to the Law Firm nor privileged information that they know of by reason of their relationship with clients or their activity at the Firm.
2. The members of the Firm may not use the name of VILLAR^® nor invoke their condition as members of VILLAR^® to perform operations in their own benefit or people they are linked to.

Article 24.- External activities.

1. VILLAR^® members will dedicate to the Firm all their professional capacity and personal effort for the exercise of their functions.
2. Subject to in all cases foreseen in the applicable regulations, members of VILLAR^® will perform with exclusive dedication, unless otherwise agreed or express authorization, professional activities, internal management and any other assigned by VILLAR^®, in accordance with the qualification and professional degree of each one.
3. In particular, VILLAR^® professionals may not provide, either personally or by a third party, to companies or entities other than VILLAR^®, labor or professional services similar or equivalent to those provided in VILLAR^®, or that they may constitute a conflict of interest with these.
4. As a general rule, professionals of the Law Firm can’t perform positions of management in commercial corporations or other, nor carry out functions of legal representation to these. As exceptions to this general prohibition, which in any case and except in duly justified and authorized cases by the Administration Board must be remunerated by account and in favor of the Firm, referred to as follows:
   1. The performance of positions of administration in family corporations provided that this performance is not incompatible with (nor interfere) the full-time commitment to the Firm;
   2. Cases or associations, foundations or entities when considered by Board Administration as appropriate and reasonable;
   3. The specific cases in which, by way of exception and pursuant to the coincidence of reasons and extraordinary circumstances, the Board of Administration considers appropriate prior favorable report from the Committee of Professional Practice; and
   4. Professional acting as secretary of the board of administration of commercial corporations or any similar board of another type of entities.

Article 25.- Membership To Parties, Associations, Foundations Or Institutions With Public Purposes.

1. VILLAR^® respects the performance of social and public activities by their members, provided that it does not interfere in any way in their work at the Firm nor causes or is likely to cause (with reference to their reputation or any other) prejudice to the same.
2. In any case, and without prejudice to the foregoing, any links, membership or collaboration with parties, associations, foundations or institutions of public purposes will take place in such a way that, unless it is done on behalf of the Firm pursuant to the following, it is made clear their personal character, avoiding (under the responsibility of the member of the Firm) any relationship with VILLAR^®. In particular, the reference to belonging to the Firm is strictly prohibited as either present or past, in political activities, having in any case this consideration those that are developed on the basis of, with coverage of or linked to political parties.
3. The members of the Firm, to the extent that it is appropriate and convenient for the development of the activity of VILLAR^®, can take part and be members (on their own behalf or on behalf of the Firm) of professional associations (other than professional associations) and/or foundations or similar entities (always nonprofit) related with the business world or business.
4. VILLAR^® members should inform and gather relevant authorizations in accordance with the Internal Regulatory System of the Firm.

Article 26.- Pro Bono Actions.

1. VILLAR^® is fully aware of their responsibility and social commitment and, consequently, participates and actively promotes pro bono activities of interest to the community.
2. For this reason, the members of VILLAR^® may carry out pro bono activities as long as they are in accordance with the provisions of the Internal Regulatory System of the Firm and specific manuals relating to these actions.

Article 27.- Teaching activities.

1. The firm promotes the realization of teaching activities, by their professionals, both in public and private teaching centers, as well as participation in courses and postgraduate courses, seminars and the publication of books, articles and other types of collaborations, provided that such activities do not interfere with their performance of their normal activity for the Firm.
2. Such activities must in any case be previously notified and have the consent of the managing partner of the Firm or the corresponding department whom, in turn, shall bring it to the attention of the Administration Board of VILLAR^®. The remuneration of the regular teaching activities correspond to the professional that is providing them, while those relating to courses, seminars, publications or similar activities will be paid by account and in favor of the Firm.

Article 28.- Social networks, blogs and other social media.

1. VILLAR^® sees the use of social networks as a tool for institutional communication which, in line with the strategy and objectives of the Firm, can help enhance the identity and corporate culture of the Firm.
2. Regarding use of social networks, blogs and other social media, members of VILLAR^® will see to the established both in VILLAR^®’s policy for the use of technology resources and policy regarding social networks, blogs and other social media. Constitutes a misuse of systems and technology resources of the Firm (and is therefore expressly prohibited) the use of social networks and social media, revealing information, making statements or showing images that may result being imprudent, inappropriate, offensive, discriminatory, slanderous, that violate the duty of discretion and professional secrecy or which may affect in any way the prestige and reputation of VILLAR^®, its members and/or its customers or third parties.

V. Relationship with surroundings

Article 29.- Groups of Interest.

1. VILLAR^® defines their groups of interest as agents of society that affect, or can contribute significantly to their activity and decisions, or for which their actions and the development of their professional practice entail or may produce significant associated effects.
2. VILLAR^® has identified its groups of interest and made a special effort to promote and ensure constant communication with these groups and the ongoing identification of new communication channels, as well as the integration of their expectations and the establishment of lines of action in this regard.
3. The groups of interest identified by VILLAR^® are the following: clients, personnel, associates, partners, alliances, entities, authorities, regulators, public administration and society.

Article 30.- Clients.

1. Regarding clients, the purpose of members of VILLAR^® must be to promote the excellence of their services, the constant communication with clients, understanding their needs and overcoming expectations entrusted to VILLAR^®.
2. In addition to the direct communication with partners and professionals of the Law Firm, VILLAR^® will promote the most communication with their clients through any other means that result appropriate at each moment.

Article 31.- Personnel.

VILLAR^® assumes the following commitments regarding their personnel:

1. Compliance with legality;
2. Respect of human and labor rights;
3. Selection and recruitment with criteria of equity, transparency and non-discrimination, with objective and open requirements to the whole society;
4. Equity, transparency and non-discrimination in the evaluation processes and promotions;
5. Fair salaries, based on the degree of professional experience and contribution to the Firm’s development;
6. Promotion of greater compatibility between work and family responsibilities;
7. Valuing diversity;
8. Confidentiality of personnel’s information and privacy protection;
9. Promotion of a pleasant work environment, and
10. Development of a structured career, continuous training and favoring the dissemination of the Firm’s culture.

Article 32.- Partners.

1. VILLAR^® is a civil society, whose property belongs to the partners, who perform their activities within the Firm, in accordance with the stated in the articles of incorporation, this Code of Ethics and other provisions of the Internal Regulatory System of the Firm.
2. The status of partner of VILLAR^® is acquired after a strict and rigorous process of analysis and assessment of the professional merits of the candidates.
3. The system pursuant to which establishes the remuneration of the partners obeys objective criteria, which are known by those and is based on their level of professional experience, as well as their contribution and support to development and the good progress of the Firm.
4. VILLAR^® will put permanently for the partners the appropriate means for:
   1. Strengthen internal links to enhance a comprehensive service to clients, transferring knowledge and avoid conflicts of interest;
   2. Act always in an ethical and integral manner when providing our services;
   3. Ensure the work with the best team of people that enables excellent attention to clients and providing innovative services and of the highest quality; and
   4. Have appropriate, useful and complete information on the evolution of the Law Firm.

Article 33.- Alliances..

VILLAR^® is part of networks and alliances of legal firms and is a member of various associations, professional groups and similar entities both national and international and in the public and private sector. With this VILLAR^® aims to improve services for clients through the participation and coordination with institutions that improve our work capacity, from the respect to the ethical standards.

Article 34.- Entities.

1. The ethical responsibility of VILLAR^® extends to the fulfillment of all the commitments of the Firm with all kinds of entities and collaboration in all matters where the performance of the Law Firm can add value to institutional actions, without exerting any pressure over their actions.
2. VILLAR^® commits to act in relation to their competitors, complying at all times with professional ethics and fair competition.
3. Regarding its suppliers, VILLAR^® will encourage the recruitment of those who ensure compliance with good social and environmental practices and will favor loyalty and the signing of long-term collaboration agreements.
4. Regarding the media, VILLAR^® is committed to present rigorous and accurate information of the Law Firm and to collaborate in the publication of articles in the work areas of the Firm.

Article 35.- Authorities, Regulators and Public Administration

1. The relations with the authorities, regulators and public administrations will be raised under the principles of cooperation, good faith and transparency, with full respect of the applicable legislation in each case.
2. Except in the execution of agreements duly adopted by the Board of Administration, members of VILLAR^® shall refrain from carrying out with charged to the Law Firm contributions, even in the form of loan or advance, to political parties, authorities, organizations or public administrations.

Article 36.- Society.

1. VILLAR^®, through their activities, seeks to favor society as a whole and especially to the most disadvantaged groups, non-governmental or non-profit organizations and even other professional sectors through the development of their activity, with maximum consideration of the social and environmental aspects, good practices in all jobs and contributing to the sustainable growth of our economy.
2. In this framework lies within, among others:
   1. The promotion of pro bono work by professionals of the Law Firm, social action or corporate volunteering promoted and encouraged by the Firm.
   2. Social initiatives carried out through forums, interviews, publications and radio programs.
3. In environmental matters, VILLAR^® identifies, assesses and manages the impacts caused by their activity, especially in what refers to the reduction of emissions, the efficient and responsible use of resources and proper management of waste.

VI. Various Provisions

Article 37.- Publication.

The Code of Ethics will communicate and publish among all members of VILLAR^®. Their knowledge and compliance are part of the essential and unavoidable duties of all members of the Law Firm.

Article 38.- Follow-up.

The Committee of Professional Practice shall draw up an annual report which will reflect the incidences and the degree of compliance with the Code of Ethics, this report will be delivered to VILLAR^®’s governing boards so that they can make an assessment.

Article 39.- Application.

1. It corresponds to the Senior Partner to ensure the implementation of this Code and set the standards of interpretation in relation to the same, once heard by the Board of Partners. In addition, the Board of Administration shall adopt and will propose a few guidelines and procedures that result appropriate to develop the foreseen in the Code of Ethics, prior report of the Committee of Professional Practice of VILLAR^®.
2. Anyone, regardless of their level or position, is authorized to request that a member of VILLAR^® commits an illegal act or which contravenes the stated in this Code of Ethics or other provisions of the Internal Regulatory System of the Law Firm. At the same time, no member of VILLAR^® may justify their inappropriate, illegal behavior or which contravenes provisions in this Code of Ethics or other provisions of the Internal Regulatory System of the Law Firm under the order of a superior.

Article 40.- Update.

1. The Code of Ethics will be reviewed periodically and updated taking into consideration the annual reports made by the Committee of Professional Practice, as well as the suggestions that the members of the Law Firm provide.
2. Any update of the Code of Ethics will require the approval of VILLAR^®’s Board of Administration.