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Code of Ethics

Table of Contents

Introduction

Visuddha Entertainment is a Company committed to the highest standards of integrity and transparency and, as part of this commitment, has a Code of Ethics.

This Code of Ethics is continually edited to update and strengthen its content. It is provided to all our new Employees as part of the induction process, leaving a written record of their reading and commitment to adopt it and honor it in their daily actions.

Additionally, annual training is carried out for all Employees. In person or online (e-learning), in which the principles established in the code are explained and reinforced, any questions are answered, feedback is received and an evaluation is applied to ensure that the principles were understood and that the knowledge necessary for the practical application of the code was acquired. At the end of each training session, each employee certifies the following:

  • Attendance and participation
  • Reading and understanding of the information provided
  • That all questions were answered
  • Their commitment to adopt it and honor it in their daily actions
  • Complies with each of the guidelines described
  • Is not aware of any non-compliance or violation and, if this is not the case, undertakes to report it as soon as possible to the Compliance Officer, the Ethics Committee, or the communication channel “Visuddha – Integrity” (website: https://visuddhaentertainment.com/ethics-and-compliance)

As part of Visuddha Entertainment’s commitment, the Ethics Committee follows-up training and questions, ensuring that all employees are trained and certified annually without exception. Promotes and ensures the awareness of the Code of Ethics and its principles in different internal communication channels of the Company.

Sincerely,

The Ethics Committee

Board of Directors Message

At Visuddha Entertainment we are committed to fulfilling our Mission and achieving our Vision in the proper way, under the highest standards of professionalism as part of our daily actions, putting our Values ​​into practice at all times and always honoring our Code of Ethics.

It is essential that all our members of the Board of Directors and its Subsidiary Bodies, Management Committee, Ethics Committee, Compliance Officer, Employees and Service Providers ensure that they carry out their activities and interactions related to Visuddha Entertainment in accordance with the highest standards of professionalism, honor this Code of Ethics and respect and conduct themselves in accordance with the laws of the country where we operate.

In our Company we do not tolerate unfair business practices (unfair competition, corruption, money laundering, etc.); on the contrary, we are convinced that there must be strict respect for commercial practices, laws and regulations in each business and country where we operate.

Likewise, we promote a healthy work environment and an efficient and productive work life cycle that gives perspective to the development and growth of our team, without losing sight of the Customer-Company-Team balance.

Complying with our Code of Ethics not only strengthens us as a Company of corporate responsibility and integrity, but also generates certainty for everyone around us, our employees, customers, business partners and environment.

We are sure that we can count on all of our stakeholders to commit to and honor this Code of Ethics.

Sincerely,

Board of Directors and Owners

Vision, Mission, Values

Vision

To create the most successful Mexican entertainment and audiovisual services company for the hotel industry in its luxury and ultra-luxury segment in Mexico, with a strategic approach and excellence to offer unique experiences to our customers.

Mission

Acquisition of a portfolio of clients (hotel properties) and management of entertainment and audiovisual services that create memorable experiences, committing ourselves to our team, clients, business partners and the environment.

Values

Integrity
Conducting ourselves with integrity is the paramount rule to carry out our activities: act with integrity, adherence to the truth, respect for the commitments made and honesty in all our actions.
At Visuddha Entertainment we will always choose to do the right thing, since we are aware that the activities we carry out have an impact on the lives of others and the ecosystem in which we develop our projects and businesses, as well as on the operations of our business partners and their own customers and employees.

Innovation
At Visuddha Entertainment we constantly question everything we do, seeking to innovate in all our activities, no matter how routine, in order to improve day by day and be the benchmark company in our sector. Innovation is essential in the service we provide to our clients, introducing and bringing unique experiences to them so that they last in their memories.

Excellence
We always work to exceed expectations and raise our performance standards, taking care of every detail in what we do on a daily basis with the aim of offering exceptional quality experiences to our clients.

Value creation
The creation of value is the engine of Visuddha Entertainment and the fundamental commitment of all of us who are part of the Company. We work hard to identify and to continue generating opportunities and creating value for our clients, team and environment.

Sustainability
We are committed and always act with environmental, social and corporate responsibility. Aware of the impact that our projects and business have on the places where we operate, we are focused on lasting in the long term without compromising the resources of future generations.

Scope, reporting of violations and attention to doubts

Scope
The Code of Ethics applies to all members of the Board of Directors and its Subsidiary Bodies, Management Committee, Ethics Committee, Compliance Officer, Employees of Visuddha Entertainment and its Service Providers. It is everyone’s responsibility to conduct themselves in strict adherence to the content of this code, our policies and procedures, and the local and international laws of the country where we operate.

The members of the Management Committee, with the support and supervision of the Compliance Officer and the Ethics Committee, are responsible for offering guidance and answering questions so that the Employees and Service Providers understand the content of the Code of Ethics, and can become ambassadors of it.

All Employees, Service Providers and company bodies (Board of Directors and Committees) are obliged to receive, read, become familiar with, commit to and honor the content and scope of this Code of Ethics.

Reporting of violations
All those who make up the Company undertake to report directly to the Compliance Officer, the Ethics Committee or through the communication channel “Visuddha – Integrity” (website: https://visuddhaentertainment.com/ethics-and-compliance), any possible violation known, suspected or observed to this Code of Ethics or to the local and international legislation of the countries where we operate.

The “Visuddha – Integrity” communication channel is managed directly by the Ethics Committee and an external legal advisory team with extensive experience in managing compliance lines and advising on ethical issues. A specialist will collect the information, analyze each case and generate a report to the Compliance Officer to carry out the respective confidential investigation (if applicable) in coordination with the Ethics Committee. Once the investigation has been carried out and a conclusion has been obtained, corrective and preventive actions are defined. The Ethics Committee is responsible for evaluating the escalation of cases to the Audit and Corporate Practices Committee.

All information received through the “Visuddha – Integrity” communication channel or by any means, either by the Compliance Officer or by the Ethics Committee, will be treated confidentially, respecting the provisions of the Federal Law on Protection of Personal Data Held by Private Individuals and other applicable laws.

In no case will the person or Employee who makes a report be subject to retaliation. Any threat or act of retaliation will in itself be considered a serious violation of this Code. The Compliance Officer and/or the Ethics Committee will protect the person or Employee who has made the report to avoid retaliation.

The inappropriate use of the communication channel “Visuddha – Integrity” will be considered a violation of this Code, likewise unfounded and bad faith reports will not be tolerated.

Violations of what is established in this Code of Ethics, as well as the local and international legislation of the countries where we operate, will be investigated, and disciplinary action may be applied if necessary, and if applicable, a complaint of offence involving criminal action filed to the competent authorities. Disciplinary actions may consist of training courses, verbal or written reprimand and even termination of the employment contract (if applicable) or partial or definitive termination of the business relationship with the Service Providers, depending on the circumstances of each case.

Regardless of the actions taken internally in the Company, other penalties may be applicable in the case of violations of local and international regulations or laws of the countries where we operate.

Attention to doubts
The Code of Ethics cannot cover all the situations that could arise on a day-to-day basis, however, every person or Employee must be guided by good customs, good faith and the values ​​of the Company to take the correct action.

When in doubt about how to act, we should ask ourselves the following:

  • Does the decision I will make or the action I will take respects the Code of Ethics?
  • Am I aware of the risk and possible implications of the decision and/or action I will take?
  • Am I aware of the possible damage to my reputation and/or that of the Company?
  • Am I acting with integrity and adherence to the values ​​of my Company?
  • Am I exercising leadership by example and/or positive leadership?
  • Have I evaluated the implications if my action becomes public (internet, social networks, radio, etc.)?

In addition to the previous recommendation, if any doubt about the Interpretation of the Code persists, it should be consulted with any of the following:

  • Area Director including the General Manager
  • Human Resources Director
  • Head of Internal Control
  • Compliance Officer
  • Ethics Committee
  • Communication channel of “Visuddha – Integrity”

The Ethics Committee will have the last word regarding said doubts about the interpretation of the Code.

In no case will the person or Employee who expresses any doubt about a possible breach or interpretation be subject to retaliation. Any threat or act of retaliation will in itself be considered a serious violation of this Code.

For more information related to Corporate Governance, our Governing Bodies and the different Committees, it is recommended to consult the Company’s website.

Ethics Committee

The objective of the Ethics Committee is to promote and support the strengthening of the commitment so that all the business activities of those who are part of the Company, Owners, Members of the Board of Directors, Executive Committee, Management Committee, Employees and Service Providers and all interactions with business partners, authorities and with society in general, are governed by ethics, best practices and the principles contained in this Code of Ethics, as well as ensuring that relevant investigations are carried out that may represent a potential violation of our code, until its conclusion.

The Ethics Committee is made up as follows:

  • Board of Directors
  • Owners
Commitment to our environment

Prevention of environmental impact
At Visuddha Entertainment we are committed at preventing and minimizing any impact that our activities and projects could have on the environment.

During the development of our activities, we adhere to local and international guidelines in environmental matters with the objective of us complying at all times with the legislation on the matter, minimizing to the maximum the environmental and ecological footprint of our operations and maximizing the benefits of our activities to the stakeholders involved.

Collaboration with the community
At Visuddha Entertainment we are committed to collaborating with the communities where we operate, seeking to carry out activities aimed at improving the quality of life, creating sources of employment, making contributions or other activities that add value.

No initiative, activity or social contribution will have the purpose of having, directly or indirectly, an undue benefit in favor of Visuddha Entertainment.

Any initiative, activity or social contribution must be submitted to the Compliance Officer and the Ethics Committee for analysis, approved by them and by the General Management and registered by the Finance area to ensure transparency and correct accounting records.

Information about the Company, our activities and projects

At Visuddha Entertainment we comply with the highest standards of integrity and transparency when providing information about our Company, our activities and projects upon pertinent and formal request for it. Said information must be clear, transparent and authorized by the Company.

The dissemination of all information provided to third parties and/or authorities must be subject to the provisions of this Code of Ethics and/or any complementary policy of the Company, always respecting the obligation of confidentiality when appropriate and preserving at all times industrial and commercial secrets, know-how and, in general, any confidential information owned by Visuddha Entertainment.

Preservation of accounting and records

All of us who are part of the Company are obliged to maintain the accounting and records of Visuddha Entertainment properly and in accordance with the law, always in compliance with and in accordance with the applicable legislation. Records include contracts, accounts, research and development data, batch records, and financial and non-financial documents.

The accounts, books, records and financial statements must faithfully reflect all the transactions carried out on behalf of the company and meet the requirements established by the applicable regulations (Mexican Federal Tax Code, Income Tax Law, VAT Law, etc.). The expenses must have the necessary support and it is forbidden to distort the nature of any transaction or falsify documentation. In the event of an audit, truthful, reliable and complete information must be provided.

Protection of privileged or confidential information

All members of the Board of Directors and its Subsidiary Bodies, Management Committee, Ethics Committee, Compliance Officer, Employees and Service Providers of Visuddha Entertainment, are responsible for protecting the confidential information of the Company, as well as not disseminate its projects and strategic plans.

We all commit to:

  • Never disclose privileged or confidential information.
  • Never use privileged or confidential information to influence business, financial or asset purchase/sale decisions.
  • Take all security measures and protection of privileged or confidential information that are available.

The obligation of secrecy in the event of privileged or confidential information will continue even when the member of the Board of Directors and its Subsidiary Bodies, Management Committee, Employees or Service Providers have stopped working or terminated their relationship with the Company, being obliged to compensate to it for any failure to preserve reserved, privileged and/or confidential information owned by Visuddha Entertainment.

As a general rule, all of us who work at Visuddha Entertainment are responsible for protecting the Company’s information, taking care of the following, among other aspects:

  • Do not discuss company information in public spaces either inside or outside the facilities or with family and friends.
  • Be careful not to leave confidential information on the desk, in meeting rooms, printers or public areas, as well as ensure the correct protection of both physical and digital information.
  • Be alert to the dangers and inherent insecurity of social media. External social media should not be used to post or transfer information.
  • Protect sensitive information with passwords to lock files and computer access, as well as physical files.
  • Comply with the security rules established by the IT area (Information Technology) regarding cyber-attacks through email, malware, fraud techniques, identity theft and fake web pages.
  • Avoid reading company information on mobile devices and in public areas where it is visible to other people.

Failure to comply with this obligation will be punishable in terms of any other applicable policy, regardless of civil liability for damages or criminal liability that may be applicable.

Privileged or confidential information of third parties in the possession of the Company

At Visuddha Entertainment we will never share the information of our clients’ operations with other companies, whether in the hospitality industry or any other.

Privileged and confidential information of third parties includes, but is not limited to:

  • Name of Groups and Guests staying at the hotels where we provide our services.
  • Name of the Employees and their positions of the hotels where we provide our services.
  • Designs, operating methods, number of personnel per department, schedules, transportation systems, suppliers, payment methods, etc. of the hotels where we provide our services.

The privileged and confidential information of third parties in the possession of Visuddha Entertainment will only be used for business purposes with each client/hotel and not for personal use or for any other purpose that may contravene the industrial, commercial, know-how secrets of the hotels, as well as such as the values ​​of the Company and this Code of Ethics. Likewise, at Visuddha Entertainment we are obliged not to share said information by any public means.

It is the responsibility of all of us who are part of Visuddha Entertainment, to care for and ensure the privileged and confidential information of third parties is kept safe and confidential, preventing access or disclosure by any means, whether due to carelessness, accident, abuse of trust or illegitimate action of Anyone.

Stewardship of goods and resources

The assets and resources of Visuddha Entertainment will only be used for business purposes and not for personal use or for any other purpose that may contravene the values ​​of the Company and this Code of Ethics. Likewise, at Visuddha Entertainment we are obliged to make the best use of the Company’s assets and resources.

The assets and resources of the Company include those classified as physical: computer and communication equipment, materials, stationery, cash, corporate credit cards, etc., as well as intangibles: information, software, brands, intellectual property, etc.

It is the responsibility of all of us who are part of Visuddha Entertainment, to care for and ensure that the assets and resources of the Company are kept safe, preventing unauthorized access, damage, misuse, loss, etc. either due to carelessness, accident, abuse of trust or illegitimate action of any person.

Intellectual property rights and the corporate identity manual of Visuddha Entertainment must be respected at all times, always making appropriate use in the development of professional activity.

Interactions with third parties and business gifts

At Visuddha Entertainment we adhere to the highest standards of integrity when interacting with third parties, whether they are our clients, business partners, and/or authorities.

Interactions with third parties are always carried out based on ethics and transparency, strengthening relationships of respect, trust and legality between the parties.

At Visuddha Entertainment we know that the actions of third parties (service providers) can affect the reputation and/or responsibility of our company, so it must be verified that they comply with applicable laws and the guidelines established by the company to guarantee the sustainable business development. All third parties must receive and comply with our Code of Ethics.

At Visuddha Entertainment we will always choose to do the right thing.

We will never contract a good or service that is not really necessary and we will always select, quote and negotiate in compliance with our quotation, bidding, acquisition and contracting policies and processes, seeking the best interest of the Company (taking care of its resources and always opting for the best option) in terms of quality, service and current market price, among others.

We will never request and/or receive money, illegal incentives or anything of value in order to favor the hiring of any third party as a provider of services and/or purchase of goods.

The foregoing regardless of whether said third party has the capacity to correctly supply the services and/or goods.

We will never unduly induce or reward favorable decisions about our projects and services, to third parties during our activities.

We will never give, offer or receive a gift that is or appears to be used to improperly influence business decisions or gain an unfair advantage. It is occasionally acceptable to exchange business gifts intended to generate goodwill, provided the gift:

  • Is given in good faith, without receiving any compensatory favor, improper benefit, or business advantage.
  • Provided in an open and transparent manner
  • Is given on behalf of the company, prior approval of the Ethics Committee and not in a personal capacity.
  • Be reasonable and customary and occur infrequently
  • Do not create the appearance of any wrong situation
  • Not cash or cash equivalent
  • Do not be ostentatious, sumptuous or contrary to good customs and ethics

For this purpose, the maximum amount of $75 dollars (USD) is established.

If the gift exceeds the maximum amount established, it must be returned or reported to the Compliance Officer so that he or she can determine what will be done with it.

Business hospitality, including meals and entertainment, is not prohibited, as long as the nature and frequency are reasonable and in compliance with the Company’s Travel and Premises Expense Policy.

Any expense in this category must be adequately reflected in the accounting books. Transparency is the general rule in this practice.

In Visuddha Entertainment it is forbidden to give gifts, pay entertainment or per diem to public officials with the intention that they perform or refrain from performing an act related to their functions or those of another public servant or abuse their real or perceived influence with the purpose of obtaining or retaining for Visuddha Entertainment or a third party, an improper benefit or advantage.

Conflicts of interest and transactions with related parties

All our business decisions and activities must focus on the interests of Visuddha Entertainment. All members of the Board of Directors and its Subsidiary Bodies, Management Committee, Ethics Committee, Compliance Officer, Employees and Service Providers of Visuddha Entertainment will be attentive to any situation of conflict of interest and related parties.

A conflict of interest is defined as the potential impairment of an individual’s impartial and objective performance of duties due to personal, family, or business interests.

Employees may not have interests in businesses that buy, sell or provide services to Visuddha Entertainment. Any transaction with related companies must be reported to the Compliance Officer or the Ethics Committee, who, if necessary, will notify the Audit and Corporate Practices Committee, which will evaluate the advisability of informing the Board of Directors.

Visuddha Entertainment Employees must refrain from making operations, purchases, adjudication of business or services with companies that are owned by relatives in the first or second degree by blood or marriage.

In case of facing a possible conflict of interest, the hierarchical superior will be informed immediately, as well as the Compliance Officer or the Ethics Committee and will refrain from making any decision. The Ethics Committee will analyze each case in particular and will establish controls or measures to mitigate, manage and/or resolve the possible conflict with the aim that the decision made is impartial and for the benefit of the Company, involving the Committee when appropriate of Audit and Corporate Practices.

The disclosure of a conflict or possible conflict of interest does not represent a breach of our Code of Ethics, however, not disclosing it in a timely manner to establish controls or measures may represent a violation of it.

Prohibition of bribery and corruption

No Owner, member of the Board of Directors and its Subsidiary Bodies, Management Committee, Ethics Committee, Compliance Officer, Employees and Service Providers of Visuddha Entertainment offers, pays or accepts bribes to or from anyone. Any act of bribery and corruption when interacting with the public or private sector that contravenes the Code of Ethics and/or any applicable law or regulation is prohibited.

In our dealings with authorities, we will never offer or give money or anything of value, either as an incentive or reward, to obtain a decision favorable to the interests of Visuddha Entertainment. Thus, we must refrain from making or authorizing payments or gifts in order to obtain or secure an improper advantage, or from allowing third parties to act on our behalf for such purpose. This includes offering such incentives to officials at all levels of government.

It is essential to ensure that no activity, attention or conduct can be interpreted as bribery or any similar practice. Just as we cannot offer bribes, we cannot request them, much less accept them.

Relationship with Government and Authorities

In our interaction with government officials at any of the three levels: federal, state and municipal, we must attend to the following:

  • Comply with the laws, regulations and current legislation in force regarding procedures, agreements, requirements, attention to requests, etc.
  • Collaborate with the competent authorities in the exercise of their powers.
  • Maintain the integrity of the information and all supporting documentation generated in compliance with regulations.
  • Offer a respectful, open and effective treatment when dealing with doubts, requests and information requirements.
  • In the event of having a representative external to Visuddha Entertainment before government officials, ensure that they are aware of the Code of Ethics and the provisions of this section.

All requests, whether verbal or written, by government authorities must be reviewed with the Finance and Corporate Legal areas, as appropriate, in order to ensure proper attention in accordance with the provisions of current laws, regulations and legislation in force.

Human Rights

At Visuddha Entertainment we are committed to the promotion and protection of human rights. Respect for human dignity and their rights are fundamental elements in our daily actions. We adhere to international standards and codes related to the right to life and liberty, not to be subjected to slavery and/or torture, freedom of speech and expression, education and work, and respect for children and the elderly among others.

At Visuddha Entertainment we are committed to fostering a healthy organizational culture and an environment of respect and equal opportunities for all.

We value diversity in all possible areas among our team, we strive to attract, develop and retain diverse talent and to guarantee an inclusive, healthy work environment that is enriched by our differences.

At Visuddha Entertainment, we define “diversity” as the specific characteristics that identify each of us: personality, lifestyle, thought process, work experience, ethnicity, race, color, religion, sex, gender, gender identity, sexual orientation, pregnancy and maternity, marital status, age, nationality, disability, among others.

Visuddha Entertainment is seriously committed to granting equal opportunities, inclusion and development to all its Employees and Service Providers, treating them with fairness, respect and positive leadership. The processes of selection, hiring, remuneration, promotion, etc. are based on the aptitudes, abilities, experience and merit that each one demonstrates in the performance of their work. Thus, professional success in the Company is based on the performance and merit of each Employee and Service Providers.

It is a principle of Visuddha Entertainment, that all Employees and Service Providers perform and behave with integrity, courtesy, consideration, respect and dignity in the development of their professional activities and in the treatment and coexistence between co-workers.

Discrimination of any kind, bullying or harassment and workplace violence towards our Employees, between co-workers or other people with whom we have a professional relationship is unacceptable.

Visuddha Entertainment has zero tolerance for workplace violence.

Workplace violence includes verbal aggression, loud or offensive words, threats or any expression of hostility, intimidation or aggression (verbal or physical), as well as negative leadership, involving or affecting the Company, its Employees, visitors, hotels, suppliers or customers.

This zero-tolerance guideline for workplace violence applies to Associates’ behavior on the premises, as well as their behavior outside of Visuddha Entertainment facilities anywhere in the country or abroad.

At Visuddha Entertainment, child labor and forced labor are prohibited; we always pay attention on not to employ minors or people against their will.

Occupational safety, hygiene and stress

At Visuddha Entertainment we always promote a safe, adequate and healthy work environment for our Employees and Service Providers. We respect all guidelines, regulations and laws in this regard. We always seek to provide the best working conditions and develop our operations in compliance with all safety and hygiene regulations.

We are attentive to identify and prevent any risk in the work environment, as well as to promote the health of the Employees and a culture and environment free of work stress.

Visuddha Entertainment Employees are committed to integrate preventive measures for all types of occupational hazards into their daily professional activities. They also undertake to comply with all security measures, instructions and training courses required by the Company.

Everyone is committed to promoting physical and psychological health, safety and hygiene, and a good work environment.

We must all immediately inform the hierarchical superior, as well as the Compliance Officer or the Ethics Committee through the “Visuddha – Integrity” communication channel, about accidents, incidents of non-compliance, or any other matter that poses a threat to security, health or psychosocial risk. Safety and health includes the prevention of illness, injury, work stress and the promotion of well-being in the workplace. It is the obligation of all Employees to comply with existing laws and regulations on safety and hygiene.

Illegal substances and working under their influence

Visuddha Entertainment Employees and Service Providers must not use, ingest, buy, sell, distribute illegal substances in the workplace, either during or outside working hours.

Employees and Service Providers must not work under the influence of drugs or alcohol, avoiding any risk to themselves and/or the safety of others. Drugs include illegal drugs, controlled substances, and/or prescription drug misuse.

Visuddha Entertainment Employees and Service Providers are expected to carry out their work duties free from the influence of any substance that may affect their performance at work, as well as to avoid working under the influence of the improper use of a prescribed medication or on sale to the public.

Email, internet and information technology systems

Information technology systems are part of an essential component for the operation of Visuddha Entertainment and are provided to Visuddha Entertainment Employees for business purposes.

The use that the Employees make of these platforms and technological tools must be carried out in compliance with the information security rules and always observing the good customs and ethics hallmark of Visuddha Entertainment.

Employees may make personal use, in a reasonable and occasional manner, of the telephone, email and the Internet provided as a work tool by the Company, as long as such use does not:

  • Consumes a lot of time or resources
  • Interferes with your job performance or that of others
  • Involves illegal, sexually explicit, political, discriminatory or otherwise inappropriate material.
  • Violate this Code of Ethics or any of the policies of Visuddha Entertainment

Although the use that the Employees make of the information systems is not controlled, Visuddha Entertainment reserves the right to control, record, disclose, audit and eliminate without prior notice, the nature and content of the activity carried out by an Employee through the use of email, telephone, Internet and other systems and/or work tools provided by the Company.

Presence in social media and media/press

At Visuddha Entertainment we are aware of the boom that social media and electronic means of communication have acquired in all areas and therefore we encourage our Employees and Service Providers to use these means in a responsible and respectful manner:

  • Do not publish unofficial(1) and confidential information of Visuddha Entertainment and about its clients, hotels, suppliers or employees.
  • Do not publish or express opinions in an Employee role, these should always be done in your own name.
  • Do not make discriminatory or offensive comments against bosses/leaders, colleagues, customers, hotels, suppliers, or the Company in general.
  • Privilege the use of corporate tools and restrict the use of any social media to share Company information as much as possible.

It is not allowed to interact with the media/press on Company matters. Any request for an interview and external communication must be channeled to the Marketing area, reserving the representation of the Company in any means, act, authority or ceremony to the General Manager (or, otherwise, to the President of the Executive Committee) or to whomever he designates.

(1) Unofficial: Information not from sources authorized by the Company.

Interaction with public policies and political activities

Any interaction of a political nature in which it is related to Visuddha Entertainment must be in strict accordance with our values ​​and this Code of Ethics.

Public policies
Any Employee, member of the Council, Committees or third parties related to Visuddha Entertainment who, on behalf of the latter, engage in dialogue with officials at all levels of government or other public bodies, as well as with non-governmental organizations, that intend to influence public policies, you will have the responsibility to ensure that your opinions and communications are based on sustainable and supported facts, avoiding that they may cause confusion, deception or inaccuracies before government officials and always have the proper authorization of the Company.

Every Employee, member of the Council, Committees or third parties that carry out any relationship, transaction, negotiation, etc. with government officials and related third parties must adhere to the values ​​of the Company and the Code of Ethics.

Political support
Visuddha Entertainment recognizes the right of its Employees to actively participate in political activities in a personal capacity.

Employees will never act or appear to act on behalf of Visuddha Entertainment when engaging in personal political activities. In line with the foregoing, the assets, brand, resources, offices and facilities of the Company will never be used to support political interests of any kind, with any entity or political representative.

Prevention of money laundering

Visuddha Entertainment complies with all laws that prohibit money laundering or illegally-sourced funding.

Money laundering is the concealment or dissimulation of the true nature, origin, location, disposition, movement or ownership of assets or the legitimate right to them. Corruption is usually linked to money laundering, since the assets or values ​​illegally obtained by any person or organization in the public or private sector are placed, stratified and integrated into the financial system, or outside it, to be used without raising suspicion.

It is the responsibility of all Employees to ensure compliance with the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin in conducting business with our clients, ensuring that vulnerable activities are identified and giving immediate notice to the Compliance Officer or the Committee of Ethics through the communication channel “Integrity – Visuddha” of any suspicious situation.

Any activity related to resources of illicit origin or that are linked to money laundering is prohibited.

Any doubt or concern about how to comply with the legislation should be discussed with the Compliance Officer.

Responsibility for protecting personal data

At Visuddha Entertainment we continually safeguard personal data and we comply with the responsibility of collecting and managing said data in strict accordance with the Federal Law on Protection of Personal Data Held by Private Parties.

All of us in the Company are obliged to collect, process and, where appropriate, transfer the personal data of any of its Owners, members of the Board of Directors and its Subsidiary Bodies, Management Committee, Collaborators, Service Providers, clients, hotels, business partners, and suppliers in general, in accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties and other applicable laws. For this purpose, we must always have the consent of the owners of said data, through the corresponding privacy notices, in addition to strictly adhering to everything provided by the applicable legislation regarding its treatment, protection, management, secrecy, update, cancellation and other actions related to said data.

Additionally, all information must be handled responsibly for the Company’s own objectives and the necessary preventive measures must be taken to avoid unauthorized disclosure.

In case of doubt regarding the treatment, training, management, disclosure or secrecy of personal data, it is necessary to contact the Compliance Officer (mail: privacidad@visuddhaentertainment.com) or the Ethics Committee through the communication channel “Visuddha Integrity” (website: https://visuddhaentertainment.com/ethics-and-compliance).

Cooperation with audits and investigations

Visuddha Entertainment Employees fully and honestly cooperate with any request to participate in an internal audit or investigation carried out by the Internal Control area, External Auditors, the Legal area or other types of audits and/or verifications by authorities.

Should you receive a request for documents or a request to meet with regulators or attorneys in connection with a legal proceeding or government investigation related to Visuddha Entertainment, you should immediately contact the Compliance Officer for guidance and assistance.

Compliance with laws and regulations is essential. All of us who are part of Visuddha Entertainment adhere to the established policies and procedures and commit to apply them in every action carried out in the Company or on its behalf. It is the duty and responsibility of each Employee to know, understand, communicate and comply with the rules, as well as to report any violation of them.

Fraud prevention

Every Visuddha Entertainment Employee is committed to the highest standards of integrity and will never misuse the Company’s resources and assets, nor will they commit fraud against the Company or any third party.

Fraud is understood as intentionally concealing, altering, falsifying or omitting information for one’s own benefit or the benefit of others. Fraud can be motivated by the possibility of gaining something of value (for example, meeting a performance goal or obtaining a payment) or to avoid negative consequences (such as discipline). Some examples of fraud include:

  • Use of funds without proper authorization.
  • Altering figures to meet productivity goals and/or a budget.
  • Submission of false medical information to obtain disability benefits.
  • Manipulation of the pricing/mark-up(1) structure.
  • Misrepresenting financial information in the books and records of Visuddha Entertainment.
  • Entering into contracts or agreements on behalf of Visuddha Entertainment, unless authorized to do so.

Every Employee must not commit fraud or any attempted fraud against the company or a third party.

If you detect or suspect any irregular price structure on the sale price to the final customer, or non-payment of mark-up(1) to a hotel, you can make a report through the “Visuddha – Integrity” communication channel (website: https://visuddhaentertainment.com/ethics-and-compliance).

(1) Mark-up: rate predefined by an hotel property for the performance of third-party services.

Compliance with the Federal Law on Economic Competition and Antitrust Practices

The members of the Board of Directors and its Subsidiary Bodies, Management Committee and Employees of Visuddha Entertainment, commit ourselves to comply with the Federal Law of Economic Competition, its regulatory provisions and other applicable legislation.

Any intention to seek competitive advantages for our company must be in strict compliance with applicable laws and regulations.

All Employees will refrain from performing any of the behaviors considered as illegal monopolistic practices (antitrust practices), in accordance with the applicable legislation. In particular, they will refrain from entering into any contract, agreement, arrangement or combination of the foregoing with any competitor, the object or effect of which is any of the following:

  • Fix, raise, arrange or manipulate the sale or purchase price of goods or services at which they are offered or demanded in the market.
  • Establish the obligation not to produce, process, distribute, market or acquire but only a restricted or limited quantity of goods or the provision or transaction of a restricted or limited number, volume or frequency of services.
  • Dividing, distributing, assigning or imposing portions or segments of a current or potential market for goods and services, through customers, suppliers, times or determined or determinable spaces.
  • Change information with any of the objects or effects referred to in the previous points.

In case of doubt about the foregoing, the Compliance Officer should be consulted before carrying out any of the above conducts, especially with regard to the exchange of information. Acting in contravention of the economic competition legislation could generate liability for the Employee who commits a breach and be held accountable to fines and even imprisonment.

Final Message

We appreciate the time you took to read our Code of Ethics.

Despite the fact that in this Code an attempt was made to foresee most of the situations that could impact our day to day, we are not exempt from new situations, for which we invite you to consult with our Compliance Officer any questions that may arise in relation to the content of this Code of Ethics or about situations not foreseen in it.

This document is subject to revisions and updates at any time due to business needs, applicable laws and regulations that may arise in the future. The updated version will always be available on our intranet and internet pages.

Likewise, we extend the invitation to share any suggestion that helps us improve this Code through the “Visuddha – Integrity” communication channel or by sending an email to: etica@visuddhaentertainment.com

We reiterate our commitment to non-retaliation and handling each matter confidentially.

We count on your commitment to familiarize yourself with, honor our Code of Ethics and make proper use of the “Visuddha – Integrity” communication channel.

Sincerely,

The Ethics Committee

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