Madero & Asociados S.A.S. (hereinafter, “Madero Law” or the “Firm”) upholds the conviction that the law is a tool for transformation. Our professional practice is governed by integrity, excellence, conscious leadership, and an active commitment to legality and the common good. This Code of Ethics, Compliance, and Transparency (hereinafter, the “Code”) sets the framework for our internal and external conduct, ensuring that every decision reflects our principles and that our behavior remains aligned with leading local and international practices.

This Code is binding on all partners, attorneys, associates, interns, administrative staff, consultants, and third parties linked to the Firm or representing its interests, in any jurisdiction in which we operate. Acceptance is presumed from the moment they are formally engaged by the Firm, without prejudice to signature or express ratification.

Madero Law is guided by the belief that legal practice has meaning only when exercised with responsibility, transparency, and respect for human dignity. The following guiding principles are the compass for all our decisions, actions, and professional relationships:

1. Integrity and Consistency: We act faithfully to our principles and never compromise in the face of wrongful conduct. The trust of our clients and society rests on upright and transparent behavior.
2. Transparency: We communicate clearly and honestly, inside and outside the organization. Truth guides our work because only then do we strengthen trust in the law and those who practice it.
3. Excellence as a Culture: Excellence is a constant practice. Every engagement is executed with legal rigor, creativity, and commitment, always seeking sustainable, high-impact results.
4. Professional Responsibility: We take seriously the consequences of our decisions, aware that our actions directly affect the rights, interests, and projects of those we serve. Compliance is not a minimum threshold but an essential principle of our professional identity.
5. Confidentiality: We protect our clients’ and partners’ information as an unshakeable duty. Professional secrecy is part of our ethics and a pillar of the trust placed in us.
6. Professional Humanity: We understand that behind every case there are people. We place the human being at the center of our practice, respecting human dignity, recognizing diversity, rejecting any form of discrimination, and acting with respect and sensitivity at all times.
7. Commitment to the Public Interest: We conceive the law as an instrument of change that transcends the individual. We contribute to the strengthening of justice, access to rights, and the development of a fairer and more equitable society.
8. Collaboration and Collective Vision: We believe in the power of networks and the integration of diverse talent. Our collaborative culture enables us to build stronger, more transformative solutions.

This section sets out clear guidelines for how we relate to each of our stakeholder groups. These rules seek to ensure trust, transparency, consistency, and responsibility in all interactions.

Madero Law undertakes the following commitments toward its clients:

1. Act with loyalty, independence, transparency, and confidentiality.
2. Provide advice that is well-founded, timely, clear, lawful, and understandable for decision-making.
3. Identify, manage, and avoid actual or potential conflicts of interest.
4. Report truthfully on the status of matters or advisory engagements.
5. Not to facilitate, promote, or participate in unlawful acts or in conduct contrary to professional ethics.
6. Address the human needs underlying legal matters with sensitivity.
7. Defend our clients’ interests as our own, within the bounds of the law.
8. Agree on fees transparently, considering complexity, value added, and time invested, in line with principles of reasonableness and fairness. 
9. Manage client funds and resources in separate accounts with full traceability and under strict fiduciary controls. 
10. Prohibit the use of client monies for purposes other than those agreed.

Madero Law undertakes to act in accordance with the following guidelines in its dealings with counterparties and third parties:

1. Treat all counterparties with respect and professional courtesy.
2. Refrain from any deceptive, hostile, or disloyal conduct.
3. Reject any offers or practices intended to improperly influence legal, administrative, or commercial decisions.

In all interactions with judges, arbitrators, public officials, and oversight bodies, we will:

1. Observe good faith, truthfulness, and institutional respect.
2. Avoid any form of undue influence or favoritism.
3. Reject corruption, bribery, or external pressure.
4. Cooperate with the administration of justice, providing truthful, complete, and timely information when required by law and professional duty.
5. Facilitate the proper course of proceedings initiated by authorities and comply with orders issued by them.

In all interactions with suppliers and allied organizations, we will:

1. Select allied organizations and suppliers based on technical, ethical, and transparent criteria. 
2. Reject improper payments, favors, or hidden benefits. 
3. Ensure payment traceability and compliance with contractual and tax requirements.

Madero Law undertakes to act in accordance with the following guidelines in its dealings with the community:

1. Actively promote access to justice, legal education, and the strengthening of the rule of law. 
2. Participate in initiatives with social impact through our Pro Bono practice and in collaboration with social organizations. 
3. Generate sustainable legal opportunities for populations and organizations that cannot access quality legal services.

In compliance with Colombian law, international treaties, and industry best practices, Madero Law implements measures to ensure:

1. Due diligence mechanisms (Know Your Client – KYC) for all clients and contractors.
2. Prevention of fiscal findings, disciplinary sanctions, and reputational risks.
3. Proper record-keeping and transaction traceability.
4. Clear policies on gifts, travel, business expenses, political contributions, donations, and sponsorships, in accordance with law.

All members of Madero Law must:

1. Promote a respectful workplace free of discrimination, harassment, or abuse of power.
2. Avoid misuse of confidential information or Firm resources.
3. Respect and use institutional channels and mechanisms for resolving internal conflicts.
4. Ensure compliance with contractual and professional duties set out in internal manuals and in this Code.

Madero Law conducts its legal practice in accordance with the principles of legality, due process, transparency, and procedural fairness. Our attorneys must comply with ethical and disciplinary rules in Colombia and in any foreign jurisdiction where they are admitted and practice, as well as with international best practices governing the profession, including those applicable to international arbitration.

In particular, Firm attorneys shall act in accordance with:

1. The Disciplinary Code for Lawyers (Law 1123 of 2007) and any rule that amends or replaces it.
2. Law 1564 of 2012 (General Code of Procedure) and any rule that amends or replaces it.
3. Law 1474 of 2011 (Anti-Corruption Statute).
4. The Colombian Arbitration Statute (Law 1563 of 2012) and any rule that amends or replaces it.
5. The IBA Guidelines on Party Representation in International Arbitration (2013) and any updated or successor guidelines.
6. The IBA Rules on the Taking of Evidence in International Arbitration (2020) and any updated or successor instruments—particularly their ethical dimensions reinforcing duties of good faith, transparency, and procedural fairness.
7. Ethical rules, codes of conduct, and procedural norms governing the forum where proceedings are conducted or where the attorney is admitted.

Our attorneys must act with respect, independence, and professionalism in all interactions with judges, magistrates, arbitrators, mediators, conciliators, prosecutors, superintendencies, administrative entities, and oversight bodies. In particular, they shall:

1. Refrain from any attempt at undue pressure or extra-procedural influence.
2. Maintain composure, decorum, and respectful language in filings, hearings, and communications.
3. Facilitate the proper progress of proceedings and compliance with orders issued by authorities.

We practice technical advocacy with intellectual honesty, respect for factual truth, and loyalty to the justice system. In line with Article 28 of the Disciplinary Code for Lawyers, our procedural actions must be responsible, diligent, and in good faith.

1. Our attorneys act in good faith and with procedural fairness, avoiding dilatory, abusive, or improper conduct.
2. It is prohibited to present false evidence, conceal relevant information, or use procedural maneuvers that distort the truth or unduly delay justice.
3. Defending a client’s interests never justifies undermining the integrity of judicial or arbitral proceedings.

Madero Law does not promote or accept:

1. Frivolous actions, manifestly inadmissible claims, or filings lacking legal basis.
2. Appeals or motions used as abusive delay tactics.
3. Strategies intended to mislead, confuse, or distort the subject of the dispute.

Evidence handling at the Firm adheres to legality, transparency, and due process. In accordance with Articles 31 and 33 of Law 1123 of 2007, all Firm attorneys are expressly prohibited from:

1. Fabricating, falsifying, altering, or concealing documents or physical evidence.
2. Inducing witnesses to lie, remain silent, or substantially alter their testimony.
3. Preventing, obstructing, or manipulating the legitimate taking of evidence ordered by a competent authority.

As an international firm, we foster a culture of transparency, fairness, and professionalism across all dispute-resolution forums. In arbitration, our attorneys must:

1. Comply with the principles of independence, loyalty, and courtesy set forth in Article 78 of Law 1123 of 2007.
2. Respect the rules of the administering arbitral institution, the applicable procedural regulations, and the tribunal’s decisions.
3. Disclose any potential or actual conflicts of interest.
4. Follow the IBA Guidelines on Party Representation in International Arbitration (2013).
5. Apply, where appropriate, the IBA Rules on the Taking of Evidence in International Arbitration (2020) as a reference framework for presentation, objection, and admissibility of evidence.

Our interaction with third parties in judicial, arbitral, or administrative proceedings—and in any dispute-resolution mechanism—must adhere to ethical standards consistent with this Code. All attorneys must observe the following:

1. Professional, transparent relations with co-counsel, opposing counsel, and other external legal advisors.
2. Engagement of qualified, impartial, and technically competent experts.
3. Respect for witness independence and their right to testify free from coercion.
4. Respect for the technical independence and objectivity of experts in their reports, including party-appointed experts.
5. Prohibition of any practice involving manipulation, bribery, co-optation, or illegitimate pressure on third parties.

Madero Law maintains zero tolerance for attempts to influence professional decisions through improper gifts or attentions. Accordingly:

1. No member of the Firm may offer, request, accept, or deliver gifts, invitations, benefits, favors, or courtesies from clients, counterparties, authorities, suppliers, or third parties that could compromise objectivity or professional integrity.
2. Institutional, low-value courtesies common to ordinary business and not creating conflicts of interest or undue expectations are excepted. If the value exceeds 25% of the monthly legal minimum wage (SMLMV), it must be reported to the Ethics Officer for approval and record. Values are cumulative from the same origin within the same calendar year.
3. All Firm members must politely but firmly reject any gift or attention that could be perceived as an attempt to influence a professional relationship, and immediately report such offers to the Ethics Officer.

The Firm will not, under any circumstances, make improper payments or commissions to employees, contractors, partners, suppliers, or public officials. All payments to contractors or third parties must be supported by contracts, service orders, or valid documentation and processed through authorized banking channels to ensure traceability. Any indirect or concealed payment constituting a bribe, irregular commission, or undue advantage—whether in Colombia or abroad—is expressly prohibited. No Firm member may authorize, process, or make payments that contravene this Code.

Business, travel, meals, transport, lodging, or event expenses must be pre-authorized by the responsible administrative employee or Managing Partner and must have documented support and reasonable justification. Firm funds may not be used for personal purposes or for activities unrelated to authorized professional or business activities. All expenses must be supported by valid invoices, receipts, or equivalent documents and will not, in any case, be considered additional remuneration or disguised salary.

Donations and sponsorships are limited to activities that contribute to the common good, have legitimate social purposes, and align with the Firm’s values. No donation may be used to obtain undue benefits or favor particular interests. All disbursements must be authorized, recorded, and justified.

Madero Law is an independent firm with no partisan or ideological affiliation. The Firm will not make contributions to political parties, movements, or organizations. Firm members are free to engage in political activity in a personal capacity but must avoid using the Firm’s name, image, or resources and must not compromise professional judgment due to ideological affiliations.

Our communications seek to inform and guide, not to mislead or take advantage of vulnerability. Firm members must ensure all public communications are truthful, objective, and respectful of professional dignity. Deceptive advertising, improper client solicitation, and promises of results that cannot be verified in law are prohibited.

Madero Law recognizes that legal practice extends beyond private representation to include an active commitment to social transformation and improved access to justice.

Madero Law believes the law should be used to:

1. Expand real opportunities for vulnerable populations.
2. Strengthen institutional capacities in public entities.
3. Contribute to a culture of legality, inclusion, and sustainable development.

Each attorney is called to exercise knowledge with technical excellence, ethical awareness, and a sense of public service.

The Firm has an internal Pro Bono policy, based on the principles of Fundación Pro Bono Colombia and international standards. Activities include:

1. Free legal representation or advice for individuals, communities, or non-profits lacking sufficient resources.
2. Participation in strategic litigation with collective impact or in defense of fundamental rights.
3. Legal strengthening of social enterprises, grassroots organizations, and micro-businesses.

Case assignment follows criteria of priority, professional suitability, and resource availability, guaranteeing the same quality and dedication as any other engagement.

Madero Law encourages the participation of its members in:

1. Legal education programs for youth, community leaders, entrepreneurs, and students.
2. Legal literacy and civic empowerment projects.
3. Interdisciplinary activities that strengthen social fabric through the strategic use of law.

These actions are coordinated with educational institutions, international organizations, allied foundations, and public entities that share our vision.

The Firm promotes a culture in which purpose-driven legal practice is recognized and celebrated. Pro Bono work is measured and reported, forms part of the comprehensive performance evaluation, and may generate leadership and institutional participation opportunities.

Ethics is a continuous practice requiring clear tools and effective mechanisms. The Firm has defined a proportional and feasible system to implement, monitor, and update this Code.

The Firm’s Legal Representative—who currently also serves as Managing Partner and lead attorney—acts as Ethics and Compliance Officer, leading Code compliance, receiving reports of potential breaches, and ensuring they are handled objectively, confidentially, and with due process.

To enable safe, retaliation-free communication, the following confidential channel is available: info@maderolaw.com. 

This channel may be used by any person -internal or external- to:

1. Consult on interpretation or application of the Code.
2. Report in good faith potential ethical breaches, irregularities, or misconduct.
3. Suggest improvements to the Firm’s compliance system.

In managing this channel, the Firm undertakes the following commitments:

1. Communications will be treated with strict confidentiality.
2. The identity of the sender will be protected, unless disclosure is expressly authorized.
3. No reprisals will be taken against those who report in good faith.

Upon receipt of an ethics report, the following procedure shall be followed:

• The report will be documented in a confidential file.
• It will be classified according to its nature: ethics, regulatory compliance, conflict of interest, internal conduct, etc.

• It will be verified whether the report has sufficient merit to initiate a formal evaluation.
• If unfounded, it will be filed with a record and justification.

• Relevant facts will be collected and the possible breach of the Code will be analyzed.
• If necessary, additional information may be requested from the sender or related persons, always under a duty of confidentiality.

• If a breach is found, proportional measures will be proposed, such as: formal warning, corrective training, institutional apology, policy review, or—in serious cases—termination of the professional or contractual relationship.
• Any conduct that infringes this Code will be sanctioned in accordance with the provisions of Article 10.5 of this Code. In the case of employees under labor contracts, such breach may constitute just cause for termination of employment, pursuant to Article 62 of the Colombian Labor Code and other applicable regulations. In all cases, the Firm reserves the right to adopt the appropriate corrective or disciplinary measures, respecting due process and the proportionality of the sanction.
• If no breach is found, the case will be closed and the reasons communicated.

• The entire process will be recorded internally.
• Follow-up will be carried out on the implementation of measures and systemic adjustments will be reviewed as necessary.

The Firm will carry out periodic activities to strengthen the ethical culture among all its members, including:

1. To provide internal training to administrative staff.
2. To incorporate ethical principles into the induction of new members.
3. To conduct an annual review of the Code and its compliance system.
4. To participate in events or networks on ethics and professional responsibility.

In order to ensure clarity and proportionality in the application of this Code, breaches committed by members of the Firm are classified as minor or serious offenses, taking into account the nature of the conduct, its impact on the organization, clients, authorities, or the community, as well as the repetition or intent involved.

The behaviors described below are directly linked to the duties previously defined in this Code, so that each offense corresponds to the express breach of a specific provision.

Minor offenses are those behaviors which, without seriously compromising the integrity of the Firm or the practice of the profession, affect coexistence, institutional efficiency, or the fulfillment of internal duties. These include, among others:

1. Unjustified delays in the delivery of internal reports or documents, contrary to the duty of order and responsibility set forth in Article 5 of this Code.
2. Improper use of institutional resources that does not cause serious harm, in contravention of Article 5 of this Code.
3. Failure to report conflicts of interest in a timely manner, which Article 3.1 requires to be identified and managed in relation to clients.
4. Lack of diligence in communications with clients that does not result in serious harm, breaching the duty to provide clear, timely, and truthful advice set forth in Article 3.1 of this Code.
5. Failure to report low-value gifts which, although permitted, must be registered as indicated in Article 7.1 of this Code.
6. Other behaviors will also be considered minor offenses if, even though not expressly provided for in this Code, they violate the principles of coexistence, respect, and internal responsibility set forth in Article 5, provided that they do not constitute a serious offense as defined in the following section.

The sanctions applicable to minor offenses are verbal warning, written warning, or corrective training activities.

Serious offenses are those behaviors that violate the essential principles of this Code, undermine the trust placed in the Firm or its members, substantially affect the interests of clients or the administration of justice, or constitute violations of the law or professional ethics. These include, among others:

1. Mismanagement of client or Firm funds, or concealment of relevant information, in contravention of Article 3.1 of this Code.
2. Disclosure, improper use, or personal gain from confidential information, prohibited under Article 3.1 of this Code.
3. Participation in acts of corruption, bribery, money laundering, or financing of terrorism, in violation of Articles 4 and 7 of this Code.
4. Manipulation of evidence or inducement of witnesses to provide false testimony, expressly prohibited under Articles 6.2 and 6.3 of this Code.
5. Acceptance, offering, or solicitation of improper gifts, benefits, or favors, in contravention of Articles 7.1 and 7.2 of this Code.
6. Engagement in discriminatory conduct, workplace harassment, sexual harassment, or abuse of power, prohibited under Article 5 of this Code.
7. Acts of fraud or misappropriation of resources, in violation of the rules governing client funds in Article 3.1 of this Code.
8. Provision of legal advice, opinions, or communications in a negligent, reckless, or technically deficient manner, causing harm, in breach of Article 3.1 of this Code.
9. Disobedience of orders issued by judges, arbitrators, or authorities, in contravention of the procedural duties set forth in Articles 6.1 to 6.5 of this Code.
10. Misleading advertising or improper solicitation of clients, prohibited under Article 8 of this Code.
11. Recurrence of a minor offense previously sanctioned, pursuant to the disciplinary procedure in Article 10.3 of this Code.

The sanctions applicable to serious offenses are proportional disciplinary measures, which may include the suspension of professional assignments, termination of the employment or contractual relationship with just cause (Article 62 of the Colombian Labor Code), as well as referral to the competent authorities where appropriate.

This Code shall be interpreted according to principles of good faith, legality, proportionality, and professional responsibility. Where not expressly provided, applicable Colombian rules on professional ethics shall apply on a supplementary basis, along with current international standards for legal conduct, including guidelines of the American Bar Association (ABA) and the International Bar Association (IBA).

This Code will be periodically reviewed and updated to reflect the Firm’s evolution, regulatory changes, and international best practices. The entire team will be duly informed of updates and must adhere to their content.

This Code of Ethics, Compliance, and Transparency takes effect upon publication and remains in force indefinitely until modified, replaced, or repealed by express decision of the Firm.