Policy for the Prevention of ML/TF/FPWMD

1. Objective

To establish policies and procedures for the identification, assessment, and monitoring of transactions involving clients, suppliers, and employees, with the purpose of preventing and managing money laundering, terrorism financing, and the financing of the proliferation of weapons of mass destruction (ML/TF/FPWMD).

2. Scope

This document sets forth measures to prevent, detect, and report transactions or acts considered to be of illicit origin. Compliance with this policy is mandatory for all employees of Master Series S.A.S. (hereinafter "Master Series"), particularly those areas with direct interaction with clients, suppliers, associates, and shareholders.

3. Definitions

• Counterparty: Any natural or legal person with whom the Company maintains commercial, business, contractual, or legal relationships. Counterparties include, among others, associates, employees, clients, contractors, and product suppliers.

• Due Diligence: The process by which the Company adopts additional and more intensive measures to obtain knowledge of the Counterparty, its business, operations, products, and transaction volumes.

• Enhanced Due Diligence: The process by which the Company adopts additional and more intensive measures to obtain knowledge of the Counterparty, its business, operations, products, and transaction volumes.

• FATF: The Financial Action Task Force. An intergovernmental body established in 1989 to issue international standards for combating ML/TF/FPWMD.

• GAFILAT: The Financial Action Task Force of Latin America, a regional FATF-style body established in 2000, of which Colombia is a member.

• Terrorism Financing: The provision of funds, assets, or resources accessed by terrorist organizations or individuals to finance their activities.
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• Compliance Officer: A natural person designated by the obligated entity, responsible for promoting, developing, and ensuring compliance with ML/TF/FPWMD regulations.

• Money Laundering: A criminal offense defined under Article 332 of the Colombian Penal Code.

• ML/TF/FPWMD: Money laundering, terrorism financing, and financing of the proliferation of weapons of mass destruction.

• Guideline: A standard or norm to be followed in order to achieve a desired outcome.

• Suspicious Transaction: An unusual transaction that, in accordance with the customary practices of the relevant activity, cannot be reasonably justified. This includes attempted or rejected transactions.

• Politically Exposed Persons (PEPs): Individuals holding or having held public office under any nomenclature or classification system within national or territorial public administration, where their functions — directly or by delegation — involve general management, institutional policy formulation, or the adoption of plans, programs, and projects, as well as the direct handling of state assets, funds, or securities. This includes Foreign PEPs and PEPs from International Organizations.

• Supplier: A natural or legal person that provides a product or service.

• ML/TF/FPWMD Risk:The possibility of loss or damage that a company may sustain due to its susceptibility to being used — directly or through its operations — as an instrument for money laundering and/or the channeling of resources toward terrorist activities or the financing of the proliferation of weapons of mass destruction.

• SAGRILAFT: The Comprehensive Self-Control and Risk Management System for ML/TF/FPWMD.

• Red Flags: Atypical or suspicious transactions or behaviors that require detailed analysis and evaluation to determine whether a potential ML/TF/FPWMD event may be present.

• SIREL: The reporting system administered by the UIAF, which enables entities to report transactions deemed suspicious or unusual.

• UIAF: The Financial Information and Analysis Unit — Colombia's financial intelligence unit — responsible for intervening in the economy to prevent and detect ML/TF/FPWMD.

4. Policy

In Master Series we reaffirm the commitment to the prevention of money laundering, terrorism financing, and the financing of the proliferation of weapons of mass destruction (ML/TF/FPWMD), acting with responsibility and in full compliance with applicable laws and regulations issued by the Superintendencia de Sociedades.

This policy applies to all company employees, directors, shareholders, suppliers, contractors, clients, and all organizational processes. All parties must adhere to the guidelines established for the prevention and control of ML/TF/FPWMD risk, in order to prevent Master Series from being used — directly or indirectly — as an instrument for terrorism financing, money laundering, or the financing of the proliferation of weapons of mass destruction.

The following guidelines are established for the proper functioning of ML/TF/FPWMD Risk Management:

1. Master Series, in its commitment against ML/TF/FPWMD, rejects any criminal activity or conduct that violates applicable regulations or this policy.

All transactions and business activities shall comply with this policy and the procedures set forth in the ML/TF/FPWMD Risk Management System, taking into account the particular characteristics and dynamics of the organization.

2. Counterparty Due Diligence:

As part of its ML/TF/FPWMD risk management activities, Master Series shall conduct due diligence by obtaining timely knowledge of current and potential counterparties and their related parties, through consultation of available information sources, in accordance with organizational guidelines. This mitigates the risk of Master Series being used as a vehicle for ML/TF/FPWMD activities that could expose the company to legal, operational, reputational, or contagion risks.

Depending on the nature of the relationship, due diligence may be standard or enhanced, and always begins with a request for information on the natural or legal person in order to identify or rule out ML/TF/FPWMD risk indicators. These are analyzed and validated by the Compliance Officer to determine whether to onboard, maintain, or terminate the contractual relationship.

✓ Areas responsible for onboarding clients, employees, suppliers, and shareholders must immediately notify the Compliance Officer upon identifying any ML/TF/FPWMD risk indicator during the due diligence process.

Master Series will not maintain commercial or contractual relationships with third parties that fail or refuse to provide the documentation and information required for due diligence compliance.

3. All employees are obligated to report to the Master Series Compliance Officer any situations or transactions they consider to be in violation of these policies, or that they suspect constitute red flags, unusual transactions, or suspicious activities related to ML/TF/FPWMD.

4. Non-compliance with or violation of SAGRILAFT policies and standards constitutes a serious offense. Where applicable, the procedures and sanctions set forth in the internal work regulations shall be enforced.

5. The Compliance Officer is responsible for designing, scheduling, and conducting periodic training programs for all employees, with the objective of raising awareness of ML/TF/FPWMD risks. This includes induction for new hires and annual reinforcement across the organization.

6. Master Series cooperates with and supports judicial, administrative, and regulatory authorities by providing required information through the Compliance Officer within established timeframes. In the event that deadlines cannot be met, partial information submissions shall be made or an extension requested.

7. This ML/TF/FPWMD Prevention Policy shall be updated as necessary, in response to changes in legal and regulatory requirements or in the procedures carried out by the organization in the course of its business activities.

8. Record Retention:

All information related to SAGRILAFT must be retained for a minimum of ten (10) years, in accordance with applicable legal regulations.

5. Date of Preparation and Documentation

This document was prepared and approved on March 15, 2024.