The Company’s mission is to carry out the provision of a first-rate service, within a framework of social respect for its clients and third parties that allows it to be a model of excellence in the market, for the quality of its management and integrity.

The purpose of this Program is to establish ethical behavior, based on Blinker’s mission and vision. Likewise, it seeks to reduce the subjectivity of the interpretations of each of the Achieved Subjects on moral and ethical principles.

The Program includes policies that must be read and understood by all employees or service providers to the Company.

Compliance with the Program is mandatory, and in the event that someone does not comply with it, it will constitute sufficient and immediate justification to terminate the employment or other relationship with the Company. Complying with the terms of the Program is a condition of employment and business relationship with Blinker.

Blinker favors ethical conduct, which prioritizes the assurance of the provision of a digital marketing service and any other activity that it may eventually carry out, with a level of quality, effectiveness, and efficiency that meets the expectations of customers, shareholders and employees, preserving compliance with legal regulations.

Finally, the present considers that Blinker’s corporate management must be carried out with integrity and social responsibility, strengthening the image of the Company in relation to its stakeholders. To this end, as a general rule, common sense, good judgment and integrity should be applied to the business problems you face in order to ensure that your decisions align with this Program.

This Program is applicable to all Blinker employees, including its Board of Directors, as well as those who are carrying out tasks with the Company for a specific time or specific job, regardless of their geographical location (hereinafter, the “Subjects Achieved ”).

4.1 Obligations of the Subjects Achieved

4.1.1. Observe conduct and decorum towards collaborators and / or employees.

4.1.2. Fully carry out their functions and / or activities, endorsing the mission, objectives and policies established by the Board of Directors, putting their best effort into achieving them in a professional and responsible manner.

4.1.3. Observe professional, impartial and honest conduct, respecting internally established procedures, and they will be responsible for achieving the necessary training for the best performance of their duties.

4.1.4. In the event of maintaining relationships or accepting situations in which your personal, labor, economic and / or financial interests may conflict with the fulfillment of the duties and / or functions, due compliance with the obligations must be put before the aforementioned self-interest. .

4.1.5. Refrain from obtaining or seeking undue benefits or advantages, for himself or for others, through the use of his position, authority or influence.

4.1.5.1. The Achieved Subjects may accept gifts or courtesies, only when they are of little value, and an impartial observer cannot interpret that they are destined to obtain undue advantages. Under no circumstances may gifts in money or goods easily convertible into money be accepted. The restrictions for the reception of gifts or services include the relatives of the Reached Subjects, consanguineous until the fourth degree and by affinity until the second degree.

4.1.6. Refrain from exerting pressure, threats or harassment of any kind against other employees and / or officials, which may affect the dignity and integrity of people or induce them to carry out malicious actions.

4.1.7. Ensure at all times the absence of situations of discrimination based on sex or sexual orientation, race, religion, origin, marital status or social status.

4.1.8. Observe the rules related to safety and hygiene at work, in order to prevent and minimize occupational risks.

4.1.9. Use the Company’s resources and facilities only for business purposes and for the development of its tasks.

4.1.10. Provide your cooperation to the internal and external auditors, revealing all necessary or relevant information for the purpose of their review.

4.1.11. The Employee acknowledges and consents to their personal data being processed through computer processes for purposes strictly related to their employment.

a. Information transparency

Blinker considers transparency in information as a basic principle that should govern its performance. In particular, it guarantees that the information communicated is truthful, complete, adequately reflects the situation of the Company, as well as the result of its operations and is communicated in compliance with the deadlines and other requirements established in the applicable regulations and general principles of operation and good governance that society has assumed.

This principle of transparency and veracity of information will also be applied in internal communication.

The Reached Subjects must communicate both internal and external information truthfully. In no case will they deliver incorrect, incomplete or inaccurate information that could confuse the recipient.

b. Reserved and confidential information

The Company understands that information is one of its main assets, essential for the management of its activities.

All information owned or guarded by Blinker, of a non-public nature, is considered reserved and confidential. Therefore, all Reached Subjects are obliged to keep the strictest confidentiality regarding the information they access as a consequence of the performance of their professional activity.

The Reached Subjects shall not make fraudulent use of said information, avoiding personally benefiting from a profit opportunity of which they were aware while carrying out their tasks.

They must also refrain from using Blinker’s computer system to send or receive messages or files that are illegal, as well as any type of software that is not authorized for this purpose or that does not have the corresponding licenses.

Revealing, disseminating and using reserved and confidential information for private uses constitutes a lack of loyalty, when it is done without due authorization.

c. Personal data protection

The Company encourages the application of new technologies, being aware of the effects derived from their inadequate use.

It is for this reason that it takes special care to ensure the right to privacy, protecting the personal data entrusted to it by its customers, suppliers, employees, institutions and the general public. The Reached Subjects will not reveal personal data obtained from clients, suppliers, employees, public administrations and the general public so that, in accordance with applicable laws, the privacy and trust placed in the organization is ensured. The Reached Subjects will observe the personal data protection regulations established by national laws such as No. 25,326 and international conventions.

d. Public statements

All communication to the media must be provided exclusively by those who are expressly authorized by the Board of Directors. There should be no seminars, public presentations, etc. -on matters related to the Company- without the express authorization of the Board of Directors.

a. Conflict of interests

The Reached Subjects must avoid situations that could give rise to a conflict between personal interests and those of the Company and will refrain from representing the organization and intervening or influencing decision-making in any situation in which, directly or indirectly, the same or a close relative, had personal interest.

They must always act in the fulfillment of their responsibilities, with loyalty and in defense of the interests of the Company.

Those who could be affected by a conflict of interest, will formally communicate it to the Compliance Officer, prior to carrying out the operation or conclusion of the business in question, in order to adopt the appropriate decisions in each specific circumstance and thus avoid that their impartial performance may be compromised.

The following cases or situations will be considered as typical conflicts of interest between Staff members and the Company, without such enumeration being exhaustive:

Work for a competitor, customer or supplier in any role.
Compete with the Company for the purchase or sale of properties, products or services.
Having vested interests in transactions involving the Company or clients (except for the purchase of shares of companies that are listed on the stock exchange).
Receive loans, guarantees or discounts higher than those offered to the general public from clients.

b. Personal relationships with clients

The Reached Subjects should not have social or other relationships with clients, if the relationship generated the perception that influence is being exerted to favor someone. Customer relationships must be based on efficient, fair and legal practices. For their part, the Company and the Reached Subjects will treat them with respect, honesty and fairness.

c. Measures against bribery and corruption

The Reached Subjects may not make or offer, by themselves or by third parties, any payment in money, in kind or any other benefit, to any person / service of any public or private entity, political party or candidate for public office, with the intention to unlawfully obtain or maintain business or other advantages.

Neither will they be able to make facilitation or streamlining payments for procedures, consisting of the delivery of money or anything of value, whatever their amount, in exchange for assuring or expediting the course of a procedure or action before any judicial body, public administration or body. official.

Blinker is committed to complying with and enforcing all applicable anti-money laundering laws.

In addition to the consequences of the violation of this provision, and other consequences unrelated to the labor order, failure to comply with the provisions of this section may cause considerable damage to the reputation and good name of the Company, so it will be punishable from Applicable legal sanctions.

d. Relations with the Public Sector

Our responsibility observes honesty and integrity in all contacts with officials, administrators and employees of the public sector, always avoiding that their conduct is inappropriate.

In the context of business ethics and assumed corporate responsibility, it is Blinker’s internal policy to create an environment of prior control and during the term of public procurement, in charge of the area manager who is working with the Public Sector, and must comply with the following guidelines:

• Observe the integrity of contacts with officials representing the public sector, paying special attention to conduct that is inappropriate.
• Prohibit, in accordance with the provisions of this Code, the delivery or receipt of any type of value made for the purpose of influencing any act or decision generated so that Blinker obtains or retains a contract for its benefit.
• Prohibit any type of agreement between companies to distort due competition in public procurement.
• Prohibit the use of Blinker funds, goods or services for political contributions, directly or indirectly, or to support or oppose public referendums or voting unless the applicable laws allow it, and that it is previously approved by the Board of Directors Company.

e. Financial integrity

In order not to damage Blinker’s reputation, it is essential that written records and oral statements made during the financial reporting process are made with transparency and accuracy, and that their content is clear and understandable.

Maintaining and preparing accurate records and transparent financial statements is not only essential for the Company’s decision-making, but also a requirement under the laws of the Argentine Republic.

Maintaining the financial integrity of the Company is not the sole responsibility of our professionals who are responsible for recording transactions; it is also the responsibility of each and every one of those who contribute to supporting and preparing the Company’s records, reports and statements.

It is absolutely essential that all Blinker reports and documents presented to the competent authorities of the Argentine Republic and / or any other applicable jurisdiction, as well as to its shareholders, suppliers and customers, and any public document related to Blinker, be presented in Complete, exact, timely and transparent form.

All the books, records and financial accounts of the companies must reflect the operations in a clear and exact way, complying with the spirit and letter of the generally accepted accounting principles.

The personnel that fulfill supervisory functions will be responsible for establishing and maintaining a system of controls in their respective areas of responsibility.

The principle of collaboration and access to information should prevail over reviews that are carried out by personnel authorized by the Company, and answer clearly and on time all questions that are asked in the framework of said review. Coercing or deceiving those authorized to conduct reviews (eg, employees, external auditors, etc.) is in contravention of Blinker’s policies.

a. Communication

This Program will be communicated to all the Subjects Achieved. In no case may ignorance of the principles established in it be invoked, nor can ethically inappropriate behavior be justified based on instructions received from a hierarchical superior.

Communication and dissemination of the Program will be carried out by the Compliance Officer appointed by the Company. For its dissemination, the responsible area will use the tools it deems necessary, including specific workshops and knowledge assessments.

b. Complaints

If any of the Achieved Subjects becomes aware of the breach of any of the provisions of this Program, they must immediately notify the Compliance Officer.

a. Purpose

This document describes the policy and guidelines that must be observed by the Achieved Subjects, in relation to all the social communication channels they use, either professionally or personally.

Social media platforms help us disseminate key information about the Company. In turn, we encourage our professionals to use social media to collaborate and connect with clients, prospects and colleagues. Social media is a powerful tool to accelerate our business. However, in the same way that social media can effectively promote, our brand or individual values, when misused (even for strictly personal purposes), can adversely affect Blinker or its image and credibility.

b. objective

Our goal is to help Achieved Subjects make the appropriate decisions regarding the use of social networks, both professionally and personally. Employees using social media in connection with Blinker are required to ensure that opinions and messages reflect Blinker’s best interest and reputation.

c. Relationship with other Policies, Ethics and Conduct

Their online behavior must be consistent with the Program, with all other applicable corporate policies, with all the corresponding employee manuals and with all the specific directives that the management of the Company may issue periodically. Any action that reflects non-compliance with the Program or the policies or directives indicated above may lead to disciplinary action, including the termination of the employment relationship. This policy may be modified periodically, at Blinker’s discretion, simply by notifying the modification.

d. General disposition

The Achieved Subjects must take into account that online social media platforms are public spaces. Any online publication can continue to be public indefinitely. For this reason, the publications made by the Reached Subjects fall on them and potentially on Blinker, with which they must be consistent and professional with regard to the images, language, tone of voice and information they wish to transmit to friends, family, colleagues and clients.

The Reached Subjects are personally responsible for their words and actions in the online world and when they participate in social networks and such participation is done in their own name, unless expressly authorized by Blinker.

e. Your responsibility – Personal and Professional

The Reached Subjects should remember that when they participate in social media and speak in their personal capacity, they may still be linked to Blinker, whether or not they directly refer to Blinker or explicitly identify their relationship with Blinker, for how much other people can make this association implicitly.

Work and personal life are not always easy to distinguish online, so Achieved Subjects are expected to behave honestly and respectfully in both roles, at all times. Failure to comply with Blinker’s policies regarding social media, even when acting in a strictly personal or social sphere, may lead to disciplinary action, including termination of the employment relationship.

At a general level, each Subject Achieved:

• You are personally responsible for what you communicate on social media. As a professional who uses social networks in relation to Blinker, you must clearly identify yourself with your name and, where appropriate, your position in the Company. If you disclose your relationship as a Blinker employee in your social media messages, you must also include a disclaimer that your views do not represent the views of the Company.
• You must use common sense and remember that what you post today may be available to a mass audience (including the Company, prospective employers, and acquaintances) for a long time, even if you reconsider and delete it later.
• You should clarify that you are speaking on your own behalf. To do this, you must write in the first person and use your personal email address when communicating through social networks. You should never make anonymous posts on social media when the post could be attributed to Blinker, customers, business partners, suppliers, or other interested parties. Anonymous messages can often be forwarded to the original sender’s email address.

More specifically, the non-exhaustive list of prohibited behaviors when using social media (including on a personal basis) includes:

• The publication of any material that may harm the reputation of Blinker or any of its clients, suppliers, partners or other interested parties;
• The publication of any non-public information related to the Company (for example, undisclosed financial results or pending operations);
  Violation of any pertinent confidentiality obligation, or applicable laws regarding intellectual property or privacy;
• The publication of any material that may be considered offensive, intimidating, indicating harassment or discrimination against any person or group (based on ethnicity, race, gender, politics, etc., whether or not they are a Blinker colleague);
• The publication of any offensive, obscene, pornographic, criminal or derogatory information;
• The publication of any statement that may give rise to any civil or criminal liability, either for Blinkero for yourself;
• Any other conduct that is contrary to Blinker’s existing policies.

In the event that any of the conduct described above occurs, Blinker reserves the right to require that any offensive material be removed without delay or made inaccessible from the relevant social media platform (in addition to taking any other disciplinary action).

f. Security & Privacy

Blinker recommends that all employees regularly check their social media security / privacy settings and restrict public access to personal or professional accounts of their choice, limited to their accepted contacts.

g. Blinker social media account creation

The creation of Blinker business accounts on social networks, existing or to be created in the future, that represent the Company locally, nationally or globally is prohibited without the express authorization of the President of the Company.

h. Confidentiality, Intellectual Property and Applicable Laws

The Reached Subjects must always protect confidential information, in accordance with the applicable legislation and any existing agreement in this regard. They should also ensure that any reference to customers, suppliers or other third parties does not violate any obligation of confidentiality.