Internal information protocol

MANUAL/PROTOCOL FOR THE INTERNAL IMPLEMENTATION OF CONFIDENTIALITY OR COMPLAINTS RECEIVED REGARDING THE INAPPROPRIATE MANAGEMENT OF SARTON PUERTO RICO'S OPERATION

INDEX

1. INTRODUCTION

2. REGULATORY REGIME

3. IMPLEMENTATION REQUIREMENTS

   • Personal scope of application
   • Material scope of application
   • Objective scope
   • Procedural scope
   • Dissemination and information scope
   • Responsibility scope

4. RIGHTS OF THE WHISTLEBLOWER

5. "NON-RETALIATION" PROTOCOL

6. RIGHTS OF THE DEFENDANT

7. CONFLICT OF INTEREST

8. PROCEDURE OF MANAGEMENT AND PROCESSING OF INFORMATION

9. DESIGNATION OF THE SYSTEM ADMINISTRATOR

10. OBLIGATIONS OF THE GOVERNING BODY

11. RESOLUTIONS TO BE ADOPTED BY THE GOVERNING BODY

INTRODUCTION

The following Manual/Protocol is designed to promote the sound administration of the organization Sarton Puerto Rico, LLC ("Sarton") by addressing complaints, grievances, reports, disclosures, among others, received from employees, suppliers, contractors, etc., reporting inappropriate, harmful, abusive, illegal, fraudulent, criminal activities. Such provision or receipt of information is commonly referred to as "Whistleblower Activity." As a goal, this Manual/Protocol pursues compliance with the local (Puerto Rico) and national (United States) rule of law in the receipt and handling of such information, as well as the protection of the whistleblower (or the person who provides such information), avoiding retaliatory conduct against such person.

The goals of this manual are manifold:

• To ensure compliance with the rule of law
• To protect the whistleblower or informant
• To protect the company, its clients, and the team that makes up Sarton.

It is important to highlight that while not all sources of law contained in this manual necessarily have coverage or application to Sarton, the practices and provisions outlined promote Sarton's goals of conducting an integrated business operation by valuing its main asset: its personnel.

This manual outlines the responsibilities, obligations, and criteria of companies with responsibility under local law and those operating in interstate commerce, regarding the management and channeling of information received that would be designated as "Whistleblower Activity", and therefore "Whistleblower Protection." Likewise, this manual informs and describes the process to be followed and the protection of the whistleblower. These criteria derive from, among others, Law No. 115 of 1991 (P.R. Laws Ann. tit. 29, § 194 et seq); the Sarbanes Oxley Act (Public Law 107 – 204); Occupational Safety and Health Act (U.S.: 29 U.S.C. Ch. 15; Puerto Rico: Law No. 16 of August 5, 1975); Title 5 of the US Code (5 U.S.C. § 2302 "fraud, waste and abuse standards"); doctrines of "temporal proximity," among others.

Sarton's policy in the standards outlined in this manual is to strengthen the commitment of our work team by protecting the company from inappropriate, harmful, abusive, illegal, fraudulent, criminal, or tortious activity or conduct. Likewise, work team members must be clear that they will be protected from retaliatory action or retaliatory behavior. Such goals will be achieved through the procedural transparency and substantive protections set forth herein during investigations that are conducted upon receipt of complaints.