1. INTRODUCTION
At INCALPACA TPX, we recognize the existence of risks related to the offenses established in Law No. 30424 and its amendments (including Law No. 31740). Therefore, we accept that, based on the regulations that include the bylaws of Law No. 30424, a crime prevention system must be developed and maintained in order to foster a culture of trust, ethics, integrity, and regulatory compliance.
For this reason, as part of INCALPACA TPX's Crime Prevention Model and in accordance with the Internal Work Regulations and the Criminal Risk Matrix, this Crime Prevention Model Policy has been adopted.
2. OBJECTIVE
The main objective of this document is the implementation of the crime prevention model, in accordance with the provisions of Law No. 30424 - Law on Administrative Liability of Legal Entities, its regulations (Supreme Decree No. 002-2019-JUS) and its amendments; as well as the resolution published by the SMV No. 006-2021-SMV/01 - Guidelines for the implementation and operation of the prevention model.
Through this policy, INCALPACA TPX promotes the categorical rejection of any criminal regulatory breach that could generate criminal liability, as well as deteriorate the company's value, including its image and reputation.
3. SCOPE
The application of this policy is mandatory for all members of INCALPACA TPX, as well as for third parties who are linked to or act on behalf of it, regardless of the nature of their contractual relationship, whether employment or civil, as well as for its suppliers, contractors, clients, intermediaries, representatives, among other business partners.
Likewise, senior management is required to promote "the tone at the top" for leadership and commitment in the design, implementation, and monitoring of the prevention model. Failure to comply with the policy exposes INCALPACA TPX to civil, criminal, and/or administrative sanctions, as well as to risks to its reputation and public image.
4. RESPONSIBILITIES
- General Shareholders' Meeting: Must approve this document and comply with its provisions, with the objective of supporting the work of the Prevention Officer regarding the Crime Prevention Model adopted.
- Prevention Officer: Must carry out dissemination and monitoring activities regarding compliance with this policy, as well as report violations thereof, acting with autonomy and oversight capacity that extends to Senior Management. This function may be performed by the Compliance Officer.
- Employees: It is the responsibility of each employee to respect and comply with the provisions of the policy.
5. OUR COMMITMENTS
At INCALPACA TPX, we reject all crimes classified in Law 30424, its regulations (Supreme Decree No. 002-2019-JUS) and its amendments, applying a ZERO TOLERANCE criterion regarding any breach of this policy.
Likewise, in order to prevent these crimes, at INCALPACA TPX we carry out all activities in accordance with current legislation in all areas of operation, and we commit to:
▪ Not tolerate under any circumstances the commission of crimes by the directors and/or employees of INCALPACA TPX or by any of its representatives.
▪ Support all efforts to prevent and detect the commission of criminal acts and have a firm commitment to eradicate them in all areas of the company's activity in which its directors, employees, and all relationships it maintains with third parties are involved.
▪ Generate an environment of transparency, integrating the different processes established for crime prevention and maintaining adequate communication channels to encourage the reporting of possible irregularities.
▪ Respect the general principles of risk management for crime prevention included in the crime prevention system.
▪ Incorporate the crime prevention system into the organizational culture.
▪ Support, maintain, uphold, and disseminate the crime prevention system at strategic, tactical, and operational levels.
▪ Allocate economic and logistical resources for the establishment, implementation, maintenance, and improvement of the system.
▪ Establish the need and commitment to carry out continuous improvement and evolution of the system, adapting to both internal and external changes.
▪ Communicate to all personnel their responsibilities and procedures that concern them, within the framework of the system, through awareness and training activities.
6. COMPLIANCE
Consistent compliance with this policy is mandatory and essential for its effectiveness. INCALPACA TPX in general, the third parties with which it is linked, and in particular the employees must adhere to this policy and follow it consistently and permanently.
Likewise, employees have the obligation to report any act that violates this policy, through the reporting channels that INCALPACA TPX has implemented.
7. INQUIRIES AND REPORTS
If we have doubts about any situation that arises in our daily activities, the following questions can help us clarify it:
▪ Is the purpose honest? ▪ Is it legal? ▪ Am I violating any INCALPACA TPX policy? ▪ Could it be misinterpreted? ▪ Have I consulted with the right people within INCALPACA TPX?
If doubts persist, it is better to consult with our direct supervisor or the Prevention Officer before making a decision or taking action. No person at INCALPACA TPX will suffer retaliation for refusing to participate in acts of corruption, even if this means the loss of business opportunities.
Likewise, if we are aware of or suspect in good faith a possible violation of the law or this policy, we must report it through our direct supervisor, the Prevention Officer, or by using our Reporting Channel.
Arequipa, June 2, 2025
