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Grupo SGL International

Business Policies

Global standards. Regional execution. International trust.

Grupo SGL International and the companies that make up its holding conduct their operations under principles of legality, security, transparency, quality, responsible profitability, and supply chain protection. These policies establish the framework under which we select clients, suppliers and partners; accept operations; manage resources; protect information; manage risks; and make business decisions.

Our model draws on internationally recognized principles of ISO quality management, risk management and supply chain security promoted by the World Customs Organization's SAFE Framework, and OECD risk-based due diligence.

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Policy 1

Legality and Compliance Policy

Grupo SGL will only conduct business that can be carried out legitimately, with proper documentation and transparency.

Every operation must comply with applicable customs, tax, labor, commercial, port, maritime, air, ground transportation, environmental, security and international trade regulations.

"No volume of business, profitability, or importance of a client will ever outweigh compliance with the law."

When an operation raises reasonable doubts about its legality, origin, destination, merchandise, documentation or participants, Grupo SGL may suspend or reject it until the corresponding verifications are completed.

Policy 2

Know Your Customer Policy — KYC

Before establishing certain business relationships, and throughout their duration, Grupo SGL may apply customer-knowledge processes proportional to risk.

These may include verification of identity and legal existence, legal representation, economic activity, tax information, beneficial ownership when applicable, references, commercial behavior, and other relevant controls.

Risk-based due diligence allows us to identify and address impacts and risks related to operations, supply chains, and business relationships.

Grupo SGL reserves the right to not establish, suspend, or terminate business relationships when the required information cannot be satisfactorily verified or when risks incompatible with our policies exist.

Policy 3

Anti-Money Laundering and Illicit Financing Prevention

We do not knowingly allow our infrastructure, services, documentation, accounts, companies, or international network to be used to conceal or move funds derived from illicit activities.

We may verify operations, payment methods, counterparties, and documentation when circumstances or our risk analysis so require.

Unusual transactions may be subject to additional review and to the actions required by applicable legislation.

Policy 4

Anti-Corruption and Anti-Bribery

Grupo SGL maintains zero tolerance toward bribery, corruption, extortion, kickbacks, and payments intended to obtain undue advantages.

No employee or third party acting on behalf of the Group is authorized to offer undue benefits to authorities, clients, suppliers, or private individuals.

Legitimate payments must be properly supported and recorded.

Policy 5

Supply Chain Security

We consider security an integral part of our service.

Our controls aim to prevent risks related to cargo contamination, drug trafficking, smuggling, theft, document manipulation, unauthorized access, internal conspiracy, and other threats.

The World Customs Organization's SAFE Framework 2025 specifically promotes a secure and resilient international chain through risk management, Customs-Business cooperation, and security and facilitation standards.

Where applicable, Grupo SGL may establish controls over facilities, transport units, containers, seals, personnel, documentation, business partners, and systems.

Policy 6

Cargo Acceptance Policy

Grupo SGL reserves the right to accept or reject merchandise according to its nature, regulation, origin, destination, risk, and operational capacity.

Dangerous, restricted, perishable, or high-value merchandise, or merchandise subject to special permits, must be declared in advance and comply with the corresponding procedures.

"Incorrect or incomplete declaration, or deliberate concealment of the nature of a merchandise, constitutes a serious violation of our policies."

Policy 7

Documentary Accuracy

Clients and suppliers are responsible for providing complete, legitimate, and accurate information.

Grupo SGL will not knowingly participate in: undervaluation of merchandise; invoice falsification; alteration of origin; false description; concealment of merchandise; improper manipulation of tariff classification; or any mechanism designed to evade controls or taxes.

When we identify material inconsistencies, we may request corrections before continuing an operation.

Policy 8

Quality Policy

Our management must be oriented toward measurable, repeatable, and improvable results.

We work under principles compatible with modern quality management systems: customer focus, leadership, engagement of people, process approach, improvement, evidence-based decision making, and relationship management.

We seek to measure aspects such as response times, operational compliance, incidents, satisfaction, profitability, productivity, and supplier performance.

"What we do not measure, we can hardly improve."

Policy 9

Customer Experience and Protection

Clients must receive clear information about the scope of the contracted service.

We will work to promptly communicate relevant events that may affect an operation, including delays, incidents, operational changes, or documentation requirements of which we become aware.

Customer focus and continuous improvement are central principles of ISO quality management systems.

However, our liability will be determined by the contracted service, applicable legislation, transport documents, commercial terms, and agreed conditions.

Policy 10

Rates and Quotations

Every quotation is subject to its validity period and particular conditions.

Prices may be affected by external factors such as freight rates, fuel, shipping line or airline surcharges, exchange rates, storage, demurrage, inspections, authorities, terminals, ports, taxes, and other third-party charges.

Any modification must be communicated accordingly before its application whenever operationally possible.

Policy 11

Credit and Financial Responsibility

Commercial credit is a facility, not an acquired right.

Its authorization will depend on financial evaluation, payment behavior, volume, risk, and internal policies.

Grupo SGL may establish limits, guarantees, advance payments, deposits, or modify credit conditions based on its risk assessment.

Failure to pay may result in credit suspension and other corresponding contractual or legal measures.

Policy 12

Supplier Selection

Shipping lines, airlines, carriers, agents, operators, warehouses, correspondents, and other suppliers must be selected considering a combination of:

"Security + compliance + capacity + quality + performance + competitiveness."

The lowest price will not necessarily be the determining criterion.

Critical suppliers may be subject to homologation processes, periodic evaluation, and due diligence.

Policy 13

Conflicts of Interest

Business decisions must be made for the legitimate benefit of the organization and without undue personal interference.

Employees and executives must disclose potential conflicts related to clients, suppliers, competitors, family members, investments, or economic interests.

No employee may use corporate information or authority to obtain undue personal advantages.

Policy 14

Confidentiality

We protect the commercial, operational, financial, and strategic information entrusted to our companies.

Rates, manifests, documents, routes, client databases, contracts, credentials, financial information, and operational data must be used exclusively for authorized purposes.

This obligation continues even after a labor or commercial relationship ends, in accordance with applicable legislation and agreements.

Policy 15

Cybersecurity and Digital Protection

Modern logistics depends on critical digital information.

Grupo SGL will maintain reasonable controls designed to protect systems, users, credentials, documentation, and data against unauthorized access, fraud, loss, or alteration.

Every user must protect their credentials and immediately report suspicious activity.

Policy 16

Business Continuity

Our structure must be prepared to respond to disruptions affecting the logistics chain.

Congested ports, natural phenomena, technological failures, government restrictions, conflicts, transport interruptions, and other events may require alternative routes or procedures.

Trade resilience and continuity are also part of the evolution of the WCO's SAFE Framework.

Policy 17

Risk Management

Relevant decisions must consider not only commercial potential, but also their risks:

"Operational, financial, customs, legal, reputational, technological, security, and continuity risks."

A business opportunity with disproportionate risk may be rejected regardless of its potential profitability.

Policy 18

Responsible Profitability

Grupo SGL believes in financially sustainable companies.

Each business unit must pursue adequate profitability that allows investment in talent, technology, security, infrastructure, expansion, and service.

We will not promote growth based solely on volume when it compromises quality, security, or financial sustainability.

"We do not seek to move more cargo at any cost; we seek to build better businesses."

Policy 19

Fair Competition

We will compete through service, knowledge, innovation, coverage, technology, efficiency, and execution capability.

We do not tolerate illegal agreements to manipulate prices, markets, or bids, nor the unlawful acquisition of competitor information.

We respect the intellectual property and trade secrets of third parties.

Policy 20

Sustainability and Responsible Business

We seek to progressively incorporate environmental and social criteria into our business decisions.

The OECD holds that responsible business conduct must consider impacts related to workers, human rights, the environment, consumers, corruption, and corporate governance.

We promote digitalization, resource efficiency, waste reduction, and responsible business relationships.

Policy 21

Human Talent

Our people are a fundamental part of the control system.

Sensitive positions may be subject, in accordance with applicable legislation, to background checks, references, confidentiality agreements, training, and other controls proportional to the risk of the position.

Ongoing training will be particularly important in operations, customs, security, finance, technology, and customer service.

Policy 22

Zero Retaliation

Every person must be able to communicate, in good faith, a concern related to fraud, corruption, security, harassment, conflicts of interest, or non-compliance.

Grupo SGL will not tolerate retaliation against those who make legitimate good-faith reports.

Reports must be handled under principles of confidentiality, objectivity, and due process.

Policy 23

Audit and Continuous Improvement

Our policies are not static documents.

Processes may be subject to audits, performance evaluations, risk reviews, and corrective actions.

ISO specifically emphasizes performance measurement and continuous improvement as essential components of a quality management system.

"When we detect a deviation, our responsibility will be to identify it, correct it, determine its cause, and strengthen the process to reduce its recurrence."

Annex

Confidentiality and Trade Secrets — applies to clients and suppliers

Upon accepting or providing a service, product, or advisory to Grupo SGL or any of its represented companies, you accept our Trade Secrets policies, applicable to clients, service users, and/or suppliers of services or products.

  1. 01 Clients may not deliberately disclose the terms and conditions of the service with the intention of causing panic, misinformation, or material harm, without prior authorization from Grupo SGL International and its represented companies.
  2. 02 The dissemination of material owned by Grupo SGL — including logos, trade name, corporate name, employee names, written, printed, digital, or audio material — without prior authorization from Grupo SGL International, may be used as evidence against the responsible party.
  3. 03 Grounds under the two preceding clauses may be subject to legal action by our legal team.
  4. 04 If a case is being handled by our operations and/or commercial team, it may be subject to administrative hold and non-release until legal conciliation channels are exhausted, unless authorized through a Commercial Non-Aggression Agreement signed by the Legal Representative and/or Owner of the imported or exported merchandise, or the products purchased from our store.
  5. 05 You may open a claim or dispute case with our Quality Control and Claims team using the DISPUTE FORM.
  6. 06 For suppliers, only those with a service adhesion contract may open a case, provided they have rendered more than 3 services. Temporary suppliers may not file claims if they have invoiced more than 2 services without a contract and supplier code.
  7. 07 If you are a temporary supplier and have invoiced more than 2 services, you must attach an explanatory letter to open an investigation case, processed within 30 calendar days after confirmation by email with a case file assignment. All information must be sent to quality.control@gruposgl.com — these cases are not discussed through any other channel, unless authorized by the case executive.
  8. 08 If a violation of the TRADE SECRETS terms is detected, the case may be administratively closed and referred to legal channels, and the delivery of merchandise, invoice payments, refunds, and/or reimbursements or returns may be suspended.
  9. 09 Grupo SGL International and its represented companies may take legal counterclaim action for damages against clients and suppliers if deemed viable due to harm, detriment, or misinformation regarding its brands and representations.

Our Business Standard

At Grupo SGL International, we aspire to build long-term business relationships based on four commitments:

Do the right thing. Protect the chain.
Deliver on our promises. Measure to improve.

Our international growth must be backed by controls capable of growing alongside us.

GRUPO SGL INTERNATIONAL

9 companies. One vision. One global standard.

Trust is not part of our cargo. It is what sustains every operation.