Version 1.0

Bogotá, D.C., Colombia — 2025

1. OBJECT

The purpose of this Policy is to establish the guidelines, principles and commitments of Choco Gold Metals — CI CGM S.A.S. (hereinafter, "the Company") regarding the prevention, detection and response to conduct involving corruption, bribery, corruption, money laundering, terrorist financing and other practices contrary to transparency and integrity in business.

2. SCOPE

This Policy is mandatory for:

All members of the Board of Directors, partners and legal representatives of the Company.
All management, administrative and operational staff linked through employment contracts, service provision contracts or any other contractual modality.
Third parties acting on behalf of or for the account of the Company, including agents, brokers, advisors, distributors, business partners, suppliers and contractors.
Any natural or legal person acting as an intermediary in transactions in which the Company is a party.

3. REGULATORY FRAMEWORK

The Company bases this Policy on the following Colombian and international regulatory framework:

Political Constitution of Colombia, articles 1, 2, 23 and 209.
Law 1474 of 2011 — Anti-Corruption Statute.
Law 1778 of 2016 — Responsibility of legal entities for acts of transnational corruption.
Law 599 of 2000 (Penal Code) — Crimes against public administration.
Law 526 of 1999 and Decree 1674 of 2021 — System for the control and prevention of money laundering (SARLAFT).
External Circular 009 of 2016 of the Superintendency of Companies — Measures for anti-corruption compliance.
United Nations Convention against Corruption (UNCAC) — ratified by Colombia through Law 970 of 2005.
Foreign Corrupt Practices Act (FCPA) — by reason of relationships with investors and counterparties in the United States.
ISO 37001:2016 Standard — Anti-bribery Management Systems.

4. DEFINITIONS

For the purposes of this Policy, the following definitions are adopted:

Corruption: Abuse of power, of a position or of a function in order to obtain private benefits, whether economic or otherwise, to the detriment of the general interest or the proper functioning of public or private institutions.

Bribery: Offering, promising, giving, requesting or receiving an undue advantage, of any value (economic or non-economic), directly or indirectly, in order for the recipient to act or refrain from acting in relation to the performance of their duties.

Facilitation Payments: Minor payments made to public officials for the sole purpose of expediting or ensuring the execution of routine or legal actions. The Company expressly prohibits this type of payment.

Conflict of Interest: A situation in which the personal, financial, or other interests of an employee may influence, or be perceived as being able to influence, the Company's decision-making.

Related Third Parties (Business Associates): Natural or legal persons with whom the Company maintains or plans to establish a business relationship, including suppliers, contractors, distributors, partners and agents.

5. GUIDING PRINCIPLES

The Company operates under the following principles throughout its operations:

Integrity: Acting honestly, transparently, and ethically in all business relationships.
Legality: Comply at all times with applicable Colombian and international legislation.
Responsibility: To take responsibility for the consequences of the decisions made and to promote a culture of accountability.
Due Diligence: Implement verification and monitoring processes on counterparties, transactions, and risky operations.
Zero Tolerance: No act of corruption, bribery, or improper payment will be tolerated, justified, or covered up under any circumstances, regardless of the amount, business urgency, or local practice.
Confidentiality and No Retaliation: The confidentiality of identity is guaranteed to those who report irregularities in good faith and any act of retaliation against them is expressly prohibited.

6. EXPRESSLY PROHIBITED CONDUCT

It is strictly prohibited for all recipients of this Policy:

Offering, promising, giving, requesting, accepting or receiving, directly or indirectly, money, goods, services, benefits or advantages of any nature to public or private officials or their families, for the purpose of obtaining or retaining contracts, licenses, permits or any favorable treatment.
Making contributions, donations or sponsorships to political parties, candidates or electoral campaigns that seek to unduly influence decisions that affect the interests of the Company.
Make facilitation payments, regardless of their amount.
Using intermediaries, shell companies or front men to channel improper payments.
Falsely recording transactions in the accounting records or destroying, altering or concealing documentation in order to cover up acts of corruption.
Omitting the disclosure of conflicts of interest that may affect objectivity in decision-making.
Participating in money laundering schemes or financing of illicit activities.
Retaliate against or discriminate against any person who reports in good faith possible violations of this Policy.

7. Gifts, Hospitality and Corporate Amenities

The Company acknowledges that the exchange of gifts and courtesies may be part of legitimate business practices; however, it establishes the following rules:

Gifts or courtesies given or received must be reasonable, proportionate and symbolic, never in cash or cash equivalents.
No gift, invitation, or benefit may be offered or accepted when its purpose is to influence a business or administrative decision.
Any gift or favor whose value exceeds the equivalent of two (2) current legal monthly minimum wages (SMLMV) must be reported to the Compliance Officer for prior approval.
It is prohibited to offer or receive gifts of any amount to Colombian or foreign public officials, except in cases expressly permitted by applicable regulations.

8. DUE DILIGENCE IN RELATED THIRD PARTIES

Before establishing business relationships with third parties, the Company will conduct a due diligence process that will include, at a minimum:

Verification of the identity and legality of the third party in official records (Chamber of Commerce, RUES, OFAC restrictive lists, UN, UIAF).
Assessment of the third party's anti-corruption and money laundering risk profile.
Review of relevant business references and judicial or disciplinary records.
Third party declaration of knowledge and acceptance of the principles of this Policy.
Inclusion of anti-corruption and anti-bribery clauses in contracts signed with third parties, with the power of unilateral termination in case of non-compliance.
Periodic monitoring during the term of the business relationship.

9. ACCOUNTING RECORDS AND FINANCIAL CONTROLS

The Company undertakes to maintain accurate, complete, and transparent accounting records that faithfully reflect all transactions. In this regard:

No payment may be made in cash for amounts exceeding the limits established by current Colombian regulations.
All payments must be properly supported by invoices, contracts or other documents that justify their nature and purpose.
The creation of secret funds, secret accounts, or any mechanism that facilitates unrecorded payments is prohibited.
The financial statements will be audited by a Statutory Auditor and, where applicable, by independent external auditors.
The Company will implement segregation of duties controls in the authorization, recording, and payment of transactions.

10. TRAINING AND COMMUNICATION

The Company will implement a continuous training program on anti-corruption and anti-bribery that will include:

Mandatory induction for all new team members upon joining.
Periodic training —at least once a year— for all staff, with emphasis on areas of greatest exposure.
Active communication of this Policy through internal channels and on the Company's corporate website.
Updating training content in response to regulatory changes or newly identified types of risk.

11. COMPLAINT AND IRREGULARITY REPORTING CHANNEL

The Company has an Ethics and Transparency Channel for receiving, managing, and monitoring reports of potential violations of this Policy. The characteristics of this channel are:

Available to collaborators, suppliers, clients and any third party who has knowledge of a possible irregularity.
Accessible through the corporate email address designated for this purpose, published on the Company's official website.
It allows anonymous or identified reporting, according to the complainant's preference.
It guarantees the confidentiality of the information received and the identity of the reporter, to the extent permitted by applicable regulations.
It expressly prohibits any form of retaliation, intimidation, or discrimination against anyone who reports in good faith.

All reports received will be investigated objectively, impartially and promptly by the Compliance Officer, who will escalate cases that warrant it to the Board of Directors or the competent authorities.

12. INVESTIGATION AND SANCTIONING REGIME

Verification of breaches of this Policy will result in the following consequences, depending on the severity of the conduct:

Internal disciplinary measures that may include a warning, suspension or termination of the employment or commercial contract for just cause.
Report to the competent judicial, administrative or control authorities, including the Attorney General's Office, the Superintendency of Companies or the UIAF.
Exercise of the corresponding civil and criminal actions in pursuit of compensation for damages caused to the Company or to third parties.
Early termination of contracts with related third parties who engage in conduct prohibited by this Policy.

Internal investigations will proceed respecting due process and the right of defense of the alleged offender.

13. COMPLIANCE OFFICER

The Company will appoint a Compliance Officer with the following functions:

Monitor the implementation, updating and effectiveness of this Policy.
Advise senior management and staff on matters of corruption risks.
Manage the Whistleblowing Channel and coordinate internal investigations.
Prepare periodic reports for the Board of Directors on the status of the compliance program.
Keep the records, procedures, and tools of the anti-bribery management system up to date.

14. REVIEW AND UPDATE

This Policy will be reviewed at least annually or whenever there are significant regulatory changes, modifications to the organizational structure, or the identification of new corruption risks. Updates will be approved by the Board of Directors or the competent governing body and published immediately on the Company's website.

15. VALIDITY AND APPROVAL

This Policy was approved by the Board of Directors of Choco Gold Metals — CI CGM S.A.S. and comes into effect from the date of its publication on the corporate website, repealing any previous internal provision that is contrary to it.

CHOCO GOLD METALS — CI CGM S.A.S.

Bogotá, D.C., Colombia

ANTI-CORRUPTION AND ANTI-BRIBERY POLICY