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Code of Ethics

TABLE OF CONTENTS

I. INTRODUCTION

Article 1: Purpose

  1. This document contains the Code of Ethics (the "Code of Ethics") of STRONG LAW / INCWELL, and was approved by its Management Body on September 1, 2024, following a report by the Professional Practice Committee, as established by its bylaws.
  2. The Code of Ethics contains the values and principles that inspire the firm's identity, as well as the rules and conduct guidelines required of STRONG LAW / INCWELL members in their relationships with the firm, other members, clients, and third parties in general.
  3. The Code of Ethics has been developed considering the principles of social responsibility assumed by the firm for its adherence by all persons who are part of STRONG LAW / INCWELL.
  4. These values, principles, rules, and conduct guidelines constitute the ethical behavior model that must always inspire and guide the actions of the members of the firm, aimed at promoting ethical and responsible behavior by all, and reflects STRONG LAW / INCWELL's commitment to business ethics and transparency in all areas of action.
  5. This Code of Ethics is part of the Internal Regulatory System of STRONG LAW / INCWELL, which includes policies, procedures, programs, regulations, codes, and rules approved by the firm's competent bodies, and is mandatory for all STRONG LAW / INCWELL members.
  6. Any violation of the provisions of this Code of Ethics or other provisions of the firm's Internal Regulatory System will be sanctioned by STRONG LAW / INCWELL in accordance with applicable regulations, including but no limited to employees termination.

Article 2: Scope of Application

  1. The values, principles, rules, and conduct guidelines contained in the Code of Ethics apply to and must be followed by all members of STRONG LAW / INCWELL, regardless of their hierarchical level, geographic location, or functional position, who, by virtue of their membership, commit to comply with it and cooperate loyally in its implementation and application.
  2. For the purposes of this Code of Ethics, members of STRONG LAW / INCWELL include partners, employees, collaborators (counsels, etc.), and interns of all companies and entities within the STRONG LAW / INCWELL Group.

Article 3.- Acceptance and Compliance

  1. All members of STRONG LAW / INCWELL accept, by virtue of their membership, the values, principles, rules, and conduct guidelines established in this Code of Ethics, which they freely and voluntarily commit to knowing, complying with, and enforcing.
  2. Individuals who join STRONG LAW / INCWELL in the future will expressly accept the values, principles, rules, and conduct guidelines established in this Code of Ethics, which will be attached to their respective contracts.
  3. The adoption by STRONG LAW / INCWELL members of the vision, values, and rules of conduct established in this Code, and the commitment to know, comply with, and enforce them, constitutes an essential element of their relationship with the firm.

II. VALUES AND PRINCIPLES

Article 4.- Non-Negotiable Values and Fundamental Ethical Principles

  1. STRONG LAW / INCWELL has a clearly established identity that is projected both internally within the firm and among its members, and externally in relationships with clients and society in general, based on excellence in client service, commitment to individuals, and professional ethics and independence.
  2. The values and principles that inspire this identity include:

    Non-Negotiable Values:

    • Commitment to client service
    • Commitment to quality and equality
    • Commitment to the firm and its members
    • Commitment to ethical conduct

    Fundamental Ethical Principles:

    • Integrity
    • Loyalty
    • Independence
    • Continuous training
    • Dignity and respect
    • Professional secrecy

Article 5.- Commitment to Client Service

  1. The firm's activity is oriented towards satisfying clients' legitimate interests and needs, which requires not only technical rigor in performance but also:
    • A constant dedication to the client, response immediate or a maximum of 24 hours;
    • Understanding the client's objectives and needs fully and providing the most appropriate solutions;
    • Commitment to the client's interests and defense, without compromising the necessary independence.

Article 6.- Commitment to Quality

  1. The provision of professional services must be guided by the highest levels of quality, ensuring that the client always receives the most appropriate and effective solution to the entrusted matter.
  2. This quality requirement involves continuous training for all members of the firm in their respective specialties, both personally and in the supervision of less experienced colleagues.

Article 7.- Commitment to the Firm and its Members

  1. All members of STRONG LAW / INCWELL recognize the firm's value as a collective institution, both internally and in relation to clients and the provision of professional services.
  2. Internally, this quality requires:
    • Sharing professional knowledge and experience generously for the benefit of all
    • Avoiding internal competition among members, always prioritizing the firm's interests over individual ones.

Article 8.- Commitment to Ethical Conduct

  1. STRONG LAW / INCWELL is firmly committed to ethical conduct in the provision of its services. Members must act with strict compliance with the law and abstain from any action or advice that may be ethically or morally questionable, even if legally permissible.

Article 9.- Integrity

  1. STRONG LAW / INCWELL is based on strict and continuous adherence to just, reasonable, and honest conduct by its members, both professionally and personally.
  2. Deception and unfair advantage are not acceptable. Professional advice must be based on technical knowledge, sound judgment, and prudence.

Article 10.- Loyalty

  1. The principle of loyalty governs the relationships, rights, and reciprocal obligations on which STRONG LAW / INCWELL builds its identity as a firm. All the employees must know and accept the non competition, non concurrency rules of the firm.
  2. Externally, this principle is primarily expressed through the primacy of the client's legitimate interests.

Article 11.- Independence

  1. Independence is the fundamental principle of effective client defense and the quality of professional advice, as well as an essential ethical requirement.

Article 12.- Continuous Training

  1. STRONG LAW / INCWELL places the utmost importance on the continuous training of its members, which is essential for maintaining the technical quality of the advice provided and for the professional development and promotion of its members.

Article 13.- Dignity and Respect

  1. The conduct of STRONG LAW / INCWELL members with clients, counterparts, tax officers, employment officers, courts, public administrations, and third parties in general must be guided by the principles of honesty, integrity, loyalty, dignity, respect, and diligence, upholding the firm's reputation.

Article 14.- Professional Secrecy

  1. Secrecy and confidentiality are inalienable rights and duties of STRONG LAW / INCWELL members and extend to all facts or information known as a result of their professional activities.

III. ADHERENCE TO THE UNITED NATIONS GLOBAL COMPACT AND CONTRIBUTION TO THE 2030 AGENDA FOR SUSTAINABLE DEVELOPMENT

Article 15.- Adherence to the Global Compact

  1. STRONG LAW / INCWELL is committed to the United Nations Global Compact, which seeks to promote voluntary adherence to social responsibility principles by companies, based on human rights, labor rights, environmental protection, and anti-corruption principles.
  2. STRONG LAW / INCWELL is committed to contributing to the European Union and the United Nations Sustainable Development Goals (SDGs) through its professional activities, promoting the rule of law, and fostering the conservation and enhancement of economic, social, and environmental assets.

IV. PROFESSIONAL CONDUCT

Article 16.- Compliance with the Law and Internal Policies and Regulations

  1. In their activities, STRONG LAW / INCWELL members must comply with applicable laws, professional ethics standards, and the provisions of the firm's Internal Regulatory System.

Article 17.- Respect for Human Rights

  1. STRONG LAW / INCWELL practices a policy of respect for human rights and does not tolerate discrimination based on race, color, nationality, social origin, age, gender, marital status, sexual orientation, ideology, political opinions, religion, or any other personal, physical, or social condition.

Article 18.- Prevalence of the Firm's Interests

  1. In their interactions with the firm and clients, members must recognize the importance and value of STRONG LAW / INCWELL as a collective entity and prioritize the firm's interests over individual ones.

Article 19.- Information Handling

  1. STRONG LAW / INCWELL members have access to and are entrusted with confidential and proprietary information belonging to the firm and its clients. This information is strictly confidential and must not be disclosed or used for personal gain.

Article 20.- Conflicts of Interest

  1. STRONG LAW / INCWELL places great importance on correctly verifying potential conflicts of interest before accepting any assignment, to avoid legal and ethical breaches.

Article 21.- Gifts and Invitations

  1. STRONG LAW / INCWELL members must not give or accept gifts or invitations in the course of their activities unless they are of minimal or symbolic value and conform to customary business courtesies.

Article 22.- Appropriate Use of Firm Resources

  1. STRONG LAW / INCWELL provides its members with the necessary resources for their professional activities, which must be used appropriately and in accordance with internal policies.

Article 23.- Business Opportunities

  1. STRONG LAW / INCWELL members must not use business opportunities that belong to the firm for personal or third-party gain.

Article 24.- External Activities

  1. STRONG LAW / INCWELL members must dedicate their full professional capacity to the firm and must not engage in external activities that conflict with their duties.

Article 25.- Membership in Political Parties, Associations, Foundations, or Institutions with Public Purposes

  1. STRONG LAW / INCWELL respects its members' involvement in social and public activities, provided these do not interfere with their work at the firm or cause any harm to the firm's reputation.

Article 26.- Pro Bono Activities

  1. STRONG LAW / INCWELL actively encourages and participates in pro bono activities that benefit the community.

Article 27.- Teaching Activities

  1. The firm promotes teaching activities by its professionals, provided these do not interfere with their regular duties.

Article 28.- Social Media, Blogs, and Other Social Communications

  1. STRONG LAW / INCWELL views social media as an institutional communication tool that aligns with the firm's strategy and objectives. Members must adhere to internal policies regarding the use of social media in benefit of the team and the firm social marketing.

V. RELATIONSHIP WITH THE ENVIRONMENT

Article 29.- Stakeholders

  1. STRONG LAW / INCWELL defines its stakeholders as those who significantly impact or are impacted by the firm's activities and decisions.

Article 30.- Clients

  1. The goal in client relationships is to promote service excellence, information security, and constant communication to understand and exceed client expectations.

Article 31.- Personnel

  1. STRONG LAW / INCWELL commits to:
    • Compliance with laws, security policies, and internal regulations
    • Respect for human and labor rights
    • Fair and transparent recruitment and promotion processes

Article 32.- Partners

  1. STRONG LAW / INCWELL is a limited liability company owned by its partners, who operate within the firm according to the bylaws and this Code of Ethics.

Article 33.- Alliances

  1. STRONG LAW / INCWELL is part of various legal and tax networks and alliances and is a member of numerous professional associations, aiming to improve client services through collaboration.

Article 34.- Entities

  1. STRONG LAW / INCWELL is ethically committed to fulfilling its obligations to all entities and collaborating in ways that add value to institutional actions.

Article 35.- Authorities, Regulatory Bodies, and Public Administrations

  1. STRONG LAW / INCWELL's relationships with authorities, regulatory bodies, and public administrations are based on cooperation, good faith, and transparency.

Article 36.- Society

  1. Through its activities, STRONG LAW / INCWELL seeks to benefit society, particularly disadvantaged and vulnerable groups, promoting social responsibility, environmental sustainability, and contributing to the UN's 2030 Agenda for Sustainable Development. At the time of this code financially supported: Groundbreaker, Fonkoze and Bintai bintang schools.

VI. INTERNAL INFORMATION CHANNEL

Article 37.- Internal Information Channel

  1. STRONG LAW / INCWELL provides an Internal Information Channel for reporting possible violations within a professional context, in accordance with applicable laws.

Article 38.- Communications to the Internal Information Channel

  1. Communications to the Internal Information Channel must be made in accordance with the Internal Information System (SII) Procedure.

Article 39.- Principles Governing the Internal Information Channel

  1. The Internal Information System (SII) at STRONG LAW / INCWELL is designed to ensure confidentiality, respect for data protection laws, and the rights of all involved parties.

Article 40.- Responsible for the SII

  1. The Senior Partner of STRONG LAW / INCWELL is responsible for managing the SII, ensuring its operation with independence, neutrality, honesty, and objectivity.

VII. Various Provisions

Article 41.- Dissemination

  1. The Code of Ethics will be communicated and disseminated among all members of STRONG LAW / INCWELL. Its knowledge and compliance are essential duties.

Article 42.- Monitoring

  1. The Ethics Channel Manager will prepare an annual report on the Code of Ethics' compliance, which will be presented to the firm's governing bodies.

Article 43.- Application

  1. The Senior Partner is responsible for ensuring the application of this Code and establishing interpretive criteria, with input from the Partners' Council.

Article 44.- Updates

  1. The Code of Ethics will be periodically reviewed and updated, taking into account annual reports and member suggestions. Any updates require the approval of STRONG LAW / INCWELL's Management Body.