MORE THAN 38 YEARS TRANSFORMING DIGITAL PAYMENTS AND FINANCIAL SERVICES

INFORMATION SECURITY POLICY

Our Information Security Management System preserves the confidentiality, integrity, and availability of information. Accordingly, we undertake the following commitments:

• Comply with all legal, regulatory, and contractual obligations applicable to the Company regarding information security.
• Protect information assets through a risk management methodology aligned with the Company’s objectives and applied at the strategic, tactical, and operational levels.
• Strengthen the information security culture through training and awareness programs for relevant stakeholders.
• Ensure that appropriate security controls are applied whenever changes are made to Novatronic’s business processes, infrastructure, facilities, and production environments.
• Establish coordinated strategies with relevant stakeholders to monitor and respond promptly to security events and incidents that could compromise the Company’s assets.
• Promote the continual improvement of the Information Security Management System in collaboration.

BUSINESS CONTINUITY POLICY

Novatronic S.A.C.’s Senior Management views the Business Continuity Management System as a key tool for fulfilling our commitments to our most important stakeholders.

Through our Business Continuity Management System (BCMS), we undertake the following commitments:

• Ensure the continuity of critical operations and the achievement of BCMS objectives, including compliance with recovery time objectives (RTOs) and service availability targets, while managing the risks and impacts that could affect business continuity.
• Strengthen Senior Management’s leadership by ensuring that the necessary resources are available to maintain and improve the Company’s business continuity capabilities and by promoting an organizational culture focused on resilience and continuity.
• Ensure compliance with ISO 22301:2019 requirements, as well as all applicable legal, regulatory, and contractual requirements.
• Establish, implement, and maintain business continuity and recovery strategies, solutions, and plans that enable the Company to respond promptly to disruptive events.
• Continually improve the effectiveness and capabilities of the Business Continuity Management System.

ENVIRONMENTAL, OCCUPATIONAL HEALTH AND SAFETY POLICY

At Novatronic, we are firmly committed to providing safe and healthy working conditions to prevent work-related injuries and protect the health of our employees. We identify and assess occupational risks in order to establish effective controls.

We actively promote the ongoing participation and consultation of our team on occupational health and safety matters. At the same time, we protect the environment by preventing pollution, responsibly managing waste and waste electrical and electronic equipment (WEEE), and encouraging the efficient use of resources such as energy, water, paper, and technology-related materials.

We also implement induction, training, and awareness programs on safe and environmentally responsible practices; continually improve our management practices; ensure the proper use of equipment and ergonomic furniture; promptly address incidents and unsafe conditions; prevent spills and other environmental incidents; and strictly comply with all applicable legal requirements.

ANTI-CORRUPTION POLICY

At Novatronic S.A.C., we promote a culture based on integrity, ethics, transparency, and compliance. We maintain zero tolerance for corruption, bribery, fraud, and any other improper benefit. We also prevent and manage conflicts of interest while promoting transparent and ethical relationships with our customers, suppliers, and other stakeholders.

We implement risk-based controls and due diligence measures to prevent, detect, and address potential acts of corruption, bribery, and fraud.

We provide confidential reporting channels for suspected or actual violations and promote the ongoing training of our employees in ethics, integrity, and anti-corruption matters.

We are committed to complying with all applicable legislation, including Peruvian Law No. 30424 and its amendments, where applicable, as well as with our Code of Ethics and Prevention Model.

Senior Management endorses this policy and promotes its compliance and continual improvement at all levels of the organization.

PERSONAL DATA PROTECTION POLICY

At Novatronic S.A.C., we are committed to protecting and properly processing the personal data under our responsibility. We act in accordance with the principles of lawfulness, transparency, purpose limitation, proportionality, and security, and in compliance with Peruvian Law No. 29733—the Personal Data Protection Law—its Regulations, and all other applicable requirements.

We collect and use personal data solely for authorized and legitimate purposes, while maintaining its confidentiality, accuracy, and currency. We also implement security measures intended to prevent unauthorized access, use, loss, or disclosure and promptly manage any incident that could compromise information security.

We respect the rights of personal data subjects and facilitate the exercise of those rights in accordance with applicable regulations. Our employees and third parties involved in personal data processing must comply with the established requirements and promote accountability, confidentiality, information protection, and continual improvement.

GIFTS, BUSINESS COURTESIES AND HOSPITALITY POLICY

At Novatronic, the giving or acceptance of gifts, business courtesies, and hospitality is governed by the principles of transparency, integrity, and the prevention of conflicts of interest.

Only institutional or courtesy gifts of modest value are permitted, provided that they serve a legitimate business purpose, are not connected with procurement, evaluation, or negotiation processes, and do not create or imply any obligation. All such gifts must be properly declared and recorded.

The giving or acceptance of cash or cash equivalents, including vouchers and gift cards, is strictly prohibited. High-value gifts, personal benefits such as travel or free services, and gifts offered secretly or during active procurement or audit processes are also prohibited.

Likewise, offering any personal benefit to public officials for the purpose of influencing their decisions is strictly forbidden. Only promotional materials of nominal value intended for legitimate institutional purposes may be provided.

Invitations, meals, and hospitality may be given or accepted only when they are reasonable, proportionate, and legitimately related to the business relationship. Prior authorization is required in accordance with the established limits.

In the event of any doubt or unforeseen situation, consultation with the Compliance and Security Officer is the mandatory control and institutional guidance mechanism.

CORPORATE SOCIAL RESPONSIBILITY POLICY

At Novatronic, we recognize Corporate Social Responsibility and Sustainability as fundamental pillars of our management approach. We act ethically, transparently, and responsibly for the benefit of our employees, customers, suppliers, shareholders, and the community. We actively promote integrity, accountability, and strict regulatory compliance throughout our business operations.

We place people at the heart of our strategy by promoting respect for labor rights, well-being, equal opportunities, and inclusive and safe working environments. We also encourage the development of responsible technological solutions and innovations, efficiently manage our environmental impact, and build ethical and sustainable relationships with our supply chain and business partners.

Our management model is founded on responsible corporate governance and the continual improvement of our practices, with a focus on ethical decision-making and the creation of sustainable value for society.

We reaffirm our commitment to the community by actively participating in initiatives that promote social, educational, and technological development, with particular emphasis on digital inclusion.

ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING POLICY (AML/CTF)

At Novatronic, we maintain a firm commitment to preventing money laundering and terrorist financing (ML/TF). We apply a zero-tolerance principle to ensure that our operations are conducted transparently, truthfully, and in accordance with applicable laws and regulations.

We promote an institutional culture of integrity aimed at preventing our activities, products, services, or business relationships from being used, either directly or indirectly, for unlawful purposes.

We apply a risk-based approach that includes rigorous due diligence procedures for the reasonable verification of customers, suppliers, business partners, and employees, tailored to their respective levels of exposure.

We maintain proportionate internal controls, mechanisms for the timely detection of warning signs and unusual transactions, and strict safeguards to preserve the confidentiality of documentation for a minimum period of five years, in accordance with applicable civil legislation.

This commitment is led by Senior Management and overseen by the Compliance and Security Officer, who ensure the implementation of audits and the continual improvement of the system.

Compliance with these guidelines is reinforced through ongoing training and awareness programs for all personnel. Any conduct contrary to this policy may result in disciplinary measures and legal action, as applicable.