Code of Conduct

1. Scope

All employees, volunteers, members of the Board of Directors, business partners of the Wiese Foundation, and any other entities with which it maintains commercial or collaborative relationships are committed to complying with this Code of Conduct. This Code does not encompass all rules or regulations applicable to every situation. Its content must be considered in conjunction with applicable legislation, policies, codes, regulations, practices, and procedures of the Wiese Foundation, as well as legal requirements.

2. Approval, Monitoring, and Non-Compliance

Managers, employees, volunteers, members of the Board of Directors, suppliers and strategic partners may report any violation of the Code of Conduct through the Reporting Channel designated for this purpose. They must be able to do so without fear of retaliation and with trust in the confidential handling and investigation. It is important to emphasize that the Reporting Channel is intended exclusively for raising serious and sensitive concerns related to potential irregularities and breaches of this Code of Conduct and the Anti-Corruption Policy.

The Code of Conduct will be approved by the General Management. Compliance with the Code of Conduct is supervised by the Compliance Officer, who will report any breaches of its provisions to the General Management.

Project departments will implement training plans at least once a year to raise awareness and encourage compliance with the Code among employees, volunteers,
and key suppliers of the Foundation as approved by the General Management.

In the event of a breach of this Code, the General Management will appoint the most suitable person or team to investigate and propose sanctions as appropriate for each case. If the Compliance Officer is involved in the reported issue, the matter must be reported, with supporting documentation to the Board of Directors.

If the General Manager is in breach of the Code of Conduct, the violation must be reported directly to the Board of Directors, including the supporting documentation. The Board of Directors will either conduct or delegate the investigation to the most suitable personnel and apply the corresponding sanctions as deemed necessary.

If a member of the Board of Directors is involved in a complaint, the situation must be reported directly to the Chair of the Board, including all relevant supporting documents.

The Chair of the Board of Directors will determine the investigation process to be followed, and the conclusions and resulting actions will be recorded in the Board
meeting minutes.

3. Values

Identity: Understood as the historical awareness that revalues Peruvians, embraces our diversity, and is a source of development.

Solidarity: Defined by the Foundation as the intervention capable of transforming the destiny of people and communities.

Equity: The equal valuing of every Peruvian and the commitment to provide equal access to opportunities.

4. Prohibited Conduct

In accordance with the values that inspire it, in its relationship with society, the Wiese Foundation has the responsibility to carry out each of its projects with integrity. In this sense, employees, volunteers, members of the Board of Directors, service providers, and, in general, any third party linked to the Wiese Foundation must conduct themselves with honesty, strict respect for the law, and integrity. The following behaviors are prohibited:

Sexual Harassment: A sexual harassment-free environment is promoted, where respectful treatment among all employees, volunteers, and service providers is ensured, regardless of sex or sexual orientation. Sexual or sexist behaviors that may cause discomfort or humiliation, or any suggestive attitudes of any nature, will not be tolerated.
Abuse of Alcohol and Drug Use: The consumption of alcohol is prohibited during working hours unless it is an activity communicated and approved by the Project Directorate and the Administration Directorate, as appropriate (such as celebrations for national holidays, Christmas, the Foundation’s anniversary, among others). The use of narcotics is always prohibited in any situation. It is forbidden to come to work under the influence of alcohol or narcotic substances, as well as to consume them during the time involved in providing services for the Foundation. Only substances that are part of a medically supported treatment may be consumed.
Discrimination: Any act of discrimination motivated by ethnic or national origin, socioeconomic status, sex, gender, sexual orientation, culture, physical characteristics, or other prohibited reasons is forbidden.
Embezzlement and Fraud: Any theft or fraud committed will be fully investigated and appropriate measures will be taken. Theft or misuse of assets owned or provided by the Wiese Foundation is not allowed, regardless of the amount or nature of the asset. In doubtful situations, employees must request written authorization from their direct supervisor. This prohibition extends to the removal of assets owned by other employees without proper authorization.
Misuse of Assets: The assets provided by the Wiese Foundation are intended to enable employees to perform their duties under the best conditions and must be used solely to develop the products and services offered by the Foundation. Using Foundation assets for other purposes or causing damage beyond normal wear and tear will entail responsibility, including misuse of work time.
Romantic Relationships: Romantic relationships are permitted as long as they are consensual and do not interfere with work or create conflicts of interest. It is unacceptable to have or maintain romantic relationships with a colleague over whom one has hierarchical authority. In such cases, Management must be informed and reassignment requested to eliminate the hierarchical relationship.
Hiring of Relatives: Hiring relatives in positions with direct hierarchical relationships or under the same supervisor is prohibited. In areas with labor shortages, hiring relatives will be analyzed case by case by Compliance. New employees must declare any family ties with other Foundation employees.
Undesirable Situations: Employees are urged to separate personal religious, political, or other activities from their professional responsibilities and commit not to engage in situations that could compromise the Foundation’s reputation, integrity, or ethics.
Relationship with Counterparts: To preserve the relationship the Foundation establishes with the public accessing its projects and foster a culture of respect and tolerance, the Foundation rejects any behavior that disrupts communication harmony or generates rumors, discord, or confrontation among employees, volunteers, service providers, or the public.

5. Bribery, Collusion, Influence Peddling, Money Laundering, and Terrorist Financing

In compliance with Anti-Corruption regulations, the Wiese Foundation adheres to laws enacted to prevent bribery, collusion, influence peddling, money laundering, and terrorist financing. The Foundation complies with procedures established by regulations for the identification of unusual and suspicious operations.

No justification exists for attempting to alter the ethical conduct of a public official, nor of representatives and collaborators of other companies. The Wiese Foundation does not resort to acts of corruption to carry out its activities. Suppliers and strategic partners must also ensure that they refrain from practices aimed at altering the conduct of public officials.

Acts of bribery, collusion, or influence peddling are not tolerated or justified.

Bribery is understood as the offering of gifts, loans, fees, tips, or any other benefit to any person as an incentive to act contrary to the law or established procedures so that the Wiese Foundation is unduly benefited.
Collusion is understood as the agreement with public officials involved in the process of acquisition and/or contracting of the Peruvian State, whether through bribery or other direct or indirect means, to obtain an undue benefit or to influence the development of the obligations of this official.
Influence peddling is understood as the use, solicitation, or offer of influences by Wiese Foundation collaborators, their relatives, or related third parties and/or commercially related to the Foundation to intercede before an official or public servant who has to know, is knowing, or has known a judicial or administrative case.

The Wiese Foundation opposes and denounces all types of terrorist or subversive activities, as well as their financing. The Foundation prohibits all its collaborators from entering into commercial relations with companies or individuals that may be involved in bribery, collusion, influence peddling, money laundering, and terrorist financing. Likewise, the Foundation promotes among its strategic partners the rejection of any such activities. If operations of the aforementioned nature are detected, employees must communicate it to their immediate supervisor or use the Whistleblower Channel defined for this purpose.

6. Sanction Regime

Failure to comply with the provisions of this Code may result in the imposition of a sanction, which will be determined by the Ethics Committee.

7. Complaint Protocol

If a Wiese Foundation employee needs to file a report or communicate a detected situation, they may go to their immediate supervisor to present the situation, or do so through the complaints channel created for this purpose, which is the email address canaldedenuncias@fundacionwiese.org.

It is clarified that the aforementioned complaints channel and the nature of the queries that should be submitted through it include matters related to bribery, collusion, influence peddling, money laundering, terrorist financing, as well as the prohibited conduct indicated in this Code of Conduct. It will be necessary, then, to specify which specific conduct the complaint refers to.

The reports/complaints sent through this channel will be evaluated by the Wiese Foundation’s Ethics Committee, which will order the initiation of an investigation procedure, as appropriate. The deadlines for the investigation, as well as the completion of the procedure and the application of sanctions (if applicable), will observe the applicable legal provisions, depending on the complaint submitted. Complaints that are not related to the provisions of this Code of Conduct will not be processed by the Ethics Committee.