Stronger Together / Qualfon-Dialog Direct

Qualfon and Dialog Direct

e r h t ! e g o t r e g stron

Sharing the mission

to be the best BPO and Make People’s

Version Update December 2017

To our newest colleagues at Dialog Direct, Along with the entire Qualfon team, we would all like to welcome you to the new Qualfon!

After visiting your sites and meeting such wonderful people, we are certain that Dialog Direct is the perfect complement to the vision and mission of Qualfon.

In 1995, Qualfon’s founder, Alfonso Gonzalez, along with an extraordinary team, embarked on a journey to build a world-class BPO from the ground up with our first clients —IBM and AT&T. We have been growing ever since and today we have operations in Guyana, India, Mexico, Phillipines and the USA to service an expanding list of global clients. The combination of Dialog Direct and Qualfon positions us to be one of the most capable, competitive companies to provide marketing and customer engagement solutions focused on helping brands connect and engage with their customers to generate leads, increase sales and deliver high quality, remarkable customer experiences.

Qualfon recognizes the unique contributions Dialog Direct brings with more than 37 years in the contact center and direct marketing industry. We value Dialog Direct’s emphasis on service and personal and professional growth.

I am very happy to report that Doug Kearney, CEO, will become a president at Qualfon and along with his team will continue to operate the Dialog Direct business as a group of Qualfon.

I believe that employees of Dialog Direct and Qualfon, who together now form the new Qualfon, are part of an organization that will do amazing things. Together, we are a unique company in the BPO-Marketing Solutions world.

Dialog Direct, with Qualfon, provides a number of strategic opportunities, including the following: 1. More opportunities for all employees in all locations 2. Ability to have a positive impact on families and communities 3. Expanded global coverage to better serve current and future clients 4. Expanded portfolio of skills and services to provide current and future clients I am quite certain that we offer one of the strongest, most comprehensive onshore/offshore solutions for current and future clients. This presents opportunities for everyone who is part of the new organization. I can’t wait to meet everyone and talk about our collective future.

I invite you to embrace the mission and values that are at the core of Qualfon and vibes of Dialog Direct: a.) focus on treating people with dignity, courtesy, and respect, b.) fostering collaboration and c.) helping each individual reach their full potential.

It is through our mission and core values that we strive to be the best partner for our clients and to make lives better for our employees, their families and the communities in which we work.

I am thrilled that we have the opportunity to share in the great adventure together. I hope you find it exciting.

Again, welcome to Qualfon!

Sincerely Yours, Mike Marrow Chief Executive Officer

Be the best BPO, Make people’s

www.qualfon.com

Qualfon and Dialog Direct Strategic Global Footprint

Serving International Markets North America Latin America Asia

Qualfon Near Shore

Mexico City, Mexico Georgetown, Guyana (3)

Offshore Cebu, Philippines Dumaguete, Philippines Manila, Philippines India

Qualfon

Dialog Direct

Coeur d’Alene, Idaho Fort Collins, Colorado Harlingen, Texas Hayden, Idaho Idaho Falls, Idaho Johnstown, Pennsylvania Orangeburg, South Carolina West Chester, Pennsylvania San Antonio, Texas (2)

Highland Park, Michigan Holland, Michigan Troy, Michigan Billings, Montana Fort Worth, Texas Denison, Texas Waukesha, Wisconsin Piscataway, New Jersey Robbinsville, New Jersey Orlando, Florida San Jose, Costa Rica

The bringing together of the two companies is good for our respective clients and employees: Qualfon will keep Dialog Direct intact with all its people. It will become one of Qualfon’s operating business units which will provide stability for its clients and employees.

Dialog Direct’s brings to Qualfon a new end-to-end integrated marketing solution that combines inbound and outbound channels for direct mail, contact center, SMS Text, PURLs, website, and video.

Qualfon’s global footprint now offers Dialog Direct clients the option for offshore locations while expanding its current onshore and near-shore delivery capabilities.

“This is truly a transformational event. Dialog Direct is a company nearly the size of Qualfon and is highly complementary to what we do today. Most exciting of all, this acquisition positions Qualfon for continued growth and provides a bigger opportunity to make a positive impact on many more clients and many more Qualfon family members, as we strive to achieve our mission to best BPO and make people’s lives better.” -Mike Marrow, CEO of Qualfon

Qualfon History Qualfon has been serving clients in the Business Process Outsourcing (BPO) industry since we were founded in 1995. We began partnering with worldwide Fortune 100 companies to provide sales and customer support for ISP services and, soon after, we provided IVR services for clients-including a global stock exchange and television company. From the beginning, we have always focused on taking care of our employees who, in turn, take good care of their customers and our clients.

Qualfon’s history is a beautiful one, full of sacrifices and difficulties, full of prayer and work, and also full of much joy and happiness. It is the history of a united family. In 2006, Alfonso Gonzalez and Abelardo Cruz were on their way to open a new facility in Cebu, Philippines. On the plane, while they were praying, the decision was made to use the opportunity of opening a new facility to publicly consecrate Qualfon to honor God; acting as a family that takes care of each other.

Qualfon called together a team of directors in 2008 for a session of reflection about the organization’s core values. The core values have now become an important part of Qualfon’s daily operations. When we live these values, we build a deeper connection with our clients and make our company stand out in the market.

In March of 2013, Qualfon acquired Data Control Group (DCG), now called Qualfon Data Services Group (DSG). This company specializes in back-office processing.

In May of 2014,, Qualfon acquired Center Partners, a U.S.-based contact center outsourcing company that built an excellent reputation for itself over its 17 years through high-performance sales programs in communications, financial services, technology, and retail industries.

In January of 2016, Qualfon acquired InterMedi@ Marketing Solutions, an organization that has enjoyed over 33 years of prestige in the BPO industry. Founded in 1983, InterMedi@ Marketing Solutions is a trusted leader in providing customer contact management solutions in the business process outsourcing industry. It provides an array of contact center services to companies in healthcare, hospitality, communications, insurance, and financial services from three contact centers in West Chester, PA; Johnstown, PA; and Orangeburg, SC. In March 2016, Qualfon acquired Culture, Service, Growth (CSG). Founded in 2010, CSG is a trusted leader providing customer contact management solutions. Based in San Antonio, Texas, CSG was named as a Top Workplace. CSG’s focus on service, authenticity, honesty, and personal and profesional growth are values that align closely with Qualfon’s Mission and Vision.

In December 2017, with the integration of Dialog Direct, Qualfon has today 16,500 employees in 28 locations across 5 countries and continues to maintain a strong financial position enabling it to invest in future growth.

Center Partners Integration, United States, May, 2014 Mexico City, Mexico June, 1995 Guyana, South America November, 2005

Costa Rica, Central America, 2003

1995

2002 2003 2004 Argentina, South America, 2004 Monterrey, Mexico November, 2002

2005

2006

2010 Cebu, Philippines May, 2006

Dumaguete, Philippines May, 2010

Manila, Philippines December, 2014

2013 DCG Acquisition, United States March, 2013 Harlingen, Texas November, 2013

2014

InterMedi@ Marketing Solutions, acquisition United States January, 2016 Qualfon Technology Support Services LLP India

2016

2017

Culture Service. Dialog Direct, Growth. (CSG) December, March, 2016 2017

Our Mission, Our Reason Our mission is to help as many people as possible to pursue their total vocation as individuals and as members of society by creating an ever-growing number of job opportunities as we strive to become the outsourcer of choice for our clients.

1. CLIENTS / CUSTOMERS

1. Outsourcer of choice Our foundation for business is client satisfaction. The exemplary service we provide results in new and existing clients resolving to make Qualfon their preferred outsourcer.

2. Job opportunities We serve the common good by creating jobs of value. Our jobs bring economic, social, and spiritual growth to our employees, clients, and communities.

3. Total vocation A vocation is the intersection between your talents and the needs of the world. The word “vocation” comes from the Latin word “vocare,” which means “calling.” As people, we find happiness when we work within our calling.

In short, our mission is: Be the best BPO, Make people’s

Our Values and Code of Ethics Our Company Values The STRIDES Shield Protects and Guides STRIDES is an acronym that stands for Qualfon’s seven company values: Service, Teamwork, Results, Integrity, Dignity, Encouragement, and Spirituality. We live by this shared belief system and use it as a decision-making framework at all levels. The various colors around the shield represent the diversity of our employees and clients. The star at the center anchors our seven values and guiding principles. The placement of our values around the shield is not arbitrary; every value is intrinsically and irrevocably connected to each of the others.

Mission Programs Toolkit Qualfon Mission Leader resource guide Be the best BPO (Business Process Outsourcing) Keep-Commitments

Qualfon

Add-Value Qualfon

We are committed to following through on our promises.

We are committed to find better ways to serve our clients and colleagues.

Use the Qualfon Operating Model

Close the gaps for which you are responsible.

Commit with an action plan and follow through

Meet or exceed client KPIs. Missing is not a success!

Start and end meetings on time.

Be efficient in the course of the meetings.

Know your client’s business as well as they do-or better.

Learn from your mistakes and be accountable for not repeating them.

Peel the onion. Don’t know just what is needed but why it is needed.

Meet your deadlines.

Help others get better at what they do.

Move-Fast Qualfon We are committed to action and accomplishing our goals.

SLAs aren’t just for operations.

Spend-Wisely Qualfon We are committed to remaining financially healthy for the sake of growing our business, and improving the lives of our employees, their families, and the communities in which we work.

Make your numbers.

Respond to client needs faster than any competitor.

Wasting time –especially other people’s time– is wasting money.

Respond just as quickly when a colleague has a need.

Always ask, “Do I really need this?”

Never put off until tomorrow what you can do today.

If you have a vendor that can’t move as fast as you need them to, find a different vendor.

Force your vendors and suppliers to compete for your business, just as we do for the business of our clients.

Avoid waste in all we do.

Mission Programs Gradually the programs will be implemented in each Site according to the needs and opportunities of each location.

Promotes an environment where people are encouraged and have the opportunity to share in the company's mission, and understand the organization's values, plans and goals.

Mission Index Report (monthly)

Chaplaincy Program (services and activities sponsored by chaplains)

MISSION INDEX

You Matter with Mike (biweekly survey)

MY

app

Entrusting the Mission & Consecration Renewal Family Chats

Physical Rehabilitation

Welcome to Qualfon & Code of Ethics (handbook)

Bereavement Support

Positive Words Powerful Results (weekly)

Mission Concierge

Anniversary Celebration (Letter & Pin) Social Media (Facebook and Youtube)

Support Local Charity Organizations (Habitat for Humanity, etc)

Interfaith Activities & Chapels/Reflection Rooms Post-Hospitalization Support

Single-Mothers / Fathers Program Day-Care Service

Transforms Qualfon into an environment full of opportunities to share common hobbies and interests, learn, and have fun.

Supporting local faith communities (local churches, missions, donations, etc)

Volunteer Recognition

MISSION CONCIERGE

Promotes an environment where people are developed to explore and apply their full vocation.

Qualfon Clubs (biking, fitness club, etc.)

STRIDES Workshop Fun Activities & Events

Emergency Programs for special needs affecting our employees

Qualfon STRIDES Global Newsletter (monthly); The Newsletter of my Site

Promotes an environment where people are involved beyond what their daily work duties require of them, and actively participate in supporting the needs of our communities.

Volunteering Activities (feed the poor, orphanages, shelters, schools, heaven for hope, etc.)

Milk Subsidy (Guyana)

Reader Boards (You Matter with Mike Video Wall)

My Qualfon App

Promotes an environment where people trust and support each other in a caring, family manner.

Birthday Bash Celebration

Qualfon Music Video Contest

Qualfon Six Sigma continuous-improvement Program Mission Leader Leadership & Readiness Certification Ged/ Highschool Diploma

Holiday parties (December)

Sacré Cœur TEFL certification in English as a second language

Special Day Celebrations (Independence Day, etc.)

Cuatro Cienegas 2040 Development Plan

Recognition Programs (employee of the month)

HIGHER EDUCATION 7 Micro degrees

Skill-Development Program Sacré Cœur MBA

Measuring Integral Results Qualfon's Mission Index is designed to hold the company management and executives accountable for enriching the lives of employees, their

MISSION INDEX

families, and their communities. The Mission Index puts metrics in place that specifically measure Qualfon's ability to create jobs, retain employees, engage employees in giving back to their communities, and satisfy employees.

Qualfon creates programs and services around what matters to people.

We have a highly-tenured and engaged workforce and that, in turn, results in better care for our clients and their customers.

When employees are happy, it is contagious. The customer experience is positive and that impacts our clients and their brands.

REVENUE / EBIT

Job Creation Our goal is to create 720 new agent positions.

Keep you at Qualfon Our goal is to have no more than 5.14% annual average voluntary attrition.

MISSION INDEX 2016

More Opportunities

Your Opinion

Our goal is to encourage at least 15% of Qualfon employees to participate in Community Service Projects and Qualfon Fun Clubs.

Our goal is to reach an average of 3.02 points or above on a scale from 1-4 on the“You Matter with Mike” survey.

“We believe in our mission to the point that it is now a very significant part of our management bonus plan. Just like financial performance and client satisfaction, if you want to earn your bonus at Qualfon, you have to be successful in helping to make people’s lives better,” Mike Marrow, CEO of Qualfon

A Qualfon Mission Leader is a results-oriented professional and a mission-driven mentor, manager, and messenger. Qualfon Mission Leaders accept responsibility for the mission that has been entrusted to them; therefore, they are good stewards. In turn, they entrust the same mission to others to support our clients’ needs in order to develop each person, family, and community.

As a Mentor

I will...

• Help others succeed in their personal goals.

• Work to improve my own skills and expertise.

As a Manager

I will...

• Ensure that we meet our responsibilities to the best of our abilities.

• Endeavor to live the STRIDES values and encourage others to do the same.

As a Messenger

I will...

• Represent Qualfon in a professional manner.

• Work to create a positive view of all things that are Qualfon.

Great STRIDES: Living Intentionally.

Code of Ethics 2017

Be the best BPO, Make people’s

Our Code of Ethics: the roadmap and compass for doing business the right way.

At Qualfon, we believe that acting responsibly is not only the right thing to do, but it is also the good thing to do for our specific mission.

Our Qualfon Code of Ethics reflects the scope of our mission and the STRIDES values. It is designed to provide our employees with specific guidance.

Credibility is a priceless asset for any business and any individual. At Qualfon, we have earned our reputation as a mission- and values-driven company. We are extremely happy to be who we are, and we are committed to improving our company every day in order to make people's lives better.

Achieving our mission is critical to our success; the way we achieve it is equally important. Our clients, vendors, employees, and governments trust us and expect us to deliver business results in a responsible manner. Violations to our values at any level in our organization can quickly destroy that trust and confidence and can have significant consequences.

This Code of Ethics sets forth certain conduct requirements for Qualfon’s employees and business partners who make decisions on Qualfon’s behalf, to ensure that we continue to meet the highest standards of our STRIDES values shield.

Please read the Code carefully and comply with its principles and procedures in your day-to-day work.

Thank you for your ongoing efforts on behalf of Qualfon. Qualfon’s fidelity to our mission and values is maintained on the basis of the good decisions we make for ourselves every day.

Executive Team Alfonso Gonzalez, Chairman of the Board Christina Morris, Group President Doug Kearney, Group President Alejandro Sotelo, Chief Person Officer Robert Nachwalter, Chief Legal Officer Roberto Sanchez Mejorada, Chief Mission Officer

Be the best BPO, Make people’s

Mike Marrow, Chief Executive Officer Abelardo Cruz, Group President Marco Villarreal, Chief Financial Officer Trevor C. Allen, Chief Mergers & Acquisitions Officer/ Sales & Marketing Prashant Cherukuri, Chief Information Officer

www.qualfon.com

Great STRIDES Our Values Our STRIDES for Making people’s Our core values are an important part of everyday operations. When we live our values, we build a deeper connection with customers and help the company stand out in the market. Our values help us through even the most difficult situations, as they provide answers to tough questions and act as a beacon of light in situations of conflict. These core values are written into job descriptions and are part of our annual goals.

STRIDES is an acronym that stands for: Service, Teamwork, Results, Integrity, Dignity, Encouragement, and Spirituality.

Service: Service is living. Our customer service value enhances our clients’ experience by helping their customers. Every call we answer and every transaction we process is an opportunity to enhance the customer’s experience and make people’s lives better. Some manifestations of this value are: Helping team members and customers promptly and exceeding their expectations.

Listening to your team members and customers, and show that you care.

Teamwork: Work as a Team and Family. Although we have many different beliefs, cultures, and ethnic backgrounds, we are a family that takes care of each other; we can accomplish great things through our unity.

Manifestations of this value include: Communicating positively and respectfully to others.

Collaborating effectively with others.

Complying with the processes and policies of the company, and helping others do the same.

Setting a good example for others.

Results: Operate at High Levels of Performance.

Ensure that goals are met in an effective and efficient manner with an attitude of service. Manifestations of this value include: Working to exceed your own expectations.

Delegating responsibilities effectively to others.

Looking for your personal growth and the perfection of your skills.

Integrity: Act with Integrity. Be honest, decent, and trustworthy. Integrity means following through with our word and being impeccable in our actions. Manifestations of this value include: Being trustworthy.

Promoting respectful relationships.

Taking responsibility for your own actions.

Keeping your promises and commitments.

Dignity: Treat Others with Dignity. Treat everyone with dignity; business goals will not be advanced at the expense of anyone’s dignity. Manifestations of this value include: Respecting yourself and others.

Having a strong sense of fairness and justice in your actions.

Listening to others with openness and respect.

Treating people the way you would want to be treated.

Encouragement: Leverage actions or words to motivate others; appreciate the contributions of all members of a team. We must motivate ourselves to do our very best and, by our example, lead others to achieve their fullest potential in an exciting and engaging environment.

Manifestations of this value include: Increase confidence; help others dare to do what is difficult.

Speaking with kindness. Good words bring good feelings to the heart.

Take the time to say “thank you.”

Spirituality: Live your spirituality, and help others.

Loving and serving our neighbor is a way of honoring God. Embrace your personal beliefs, grow as an individual, and serve your family, friends, and community by “Making People’s Lives Better.”

The main manifestation of this value is: Loving your neighbor as yourself.

Code of Ethics We operate with integrity as one of our key values. Integrity means being honest, decent, and trustworthy.

By acting with integrity, we make people’s lives better for co-workers and for our company.

We look to STRIDES values as our north star; a guiding light, in the development of our Code of Ethics. Our

The Code of Ethics addresses our

Code is values-based, rather than compliance-based,

responsibilities to our company,

which means; it goes beyond simply listing what is

each other, customers, clients,

acceptable or not. As you read through it, you will see

suppliers, partners, and

that the Code of Ethics explains in detail the ethical

governments.

business practices and conduct that must govern our life here at Qualfon.

1. Role of Ethics and Morals

what is expected for everyone 1.1 Comply with the Code and the Law Understand and comply with the Code of Ethics, as well as with your local criminal and public law.

Seek to use good judgement and avoid the appearance of improper behavior.

If ever in doubt about a course of conduct, ask yourself: Is it consistent with our Qualfon values?

If the answer

Is it ethical?

is “No” to any

Is it legal?

Will it reflect well on me and Qualfon?

Would I want to see it on the news?

of these questions, do not do it.

If you are still uncertain, ask for guidance. Our STRIDES values and our Code of Ethics tries to capture many of the situations that employees will encounter, but we cannot address every circumstance. You can seek help from any of the following: Your Immediate Supervisor Human Development Office Your Local Mission Office Or you can send an email to ethics@qualfon.com or lossprevention@qualfon.com 1.2 The Code and the Law All Qualfon employees are subject to the laws of many countries and other jurisdictions around the world. Employees are expected to comply with the Code of Ethics and all applicable government laws, rules, and regulations.

2.1 Promote a Culture of Ethics and Compliance

2. What Is Expected of Managers

Managers should model appropriate conduct at all times. As a manager, you should, at a minimum: Ensure that the people you supervise understand their responsibilities under our STRIDES values and the Code of Ethics.

Offer opportunities to discuss our STRIDES values and our Code of Ethics and reinforce the importance of ethics and compliance with employees.

Create an environment where employees feel comfortable raising concerns without fear of retaliation.

Consider conduct in relation to STRIDES, the Code of Ethics, and other Qualfon policies when evaluating employees.

Never encourage or direct employees to achieve business results at the expense of ethical conduct or the law.

Always act to stop violations of the Code of Ethics or the law by those you supervise.

2.2 We are all Responsible Reinforcing the importance of living our STRIDES values and being ethically uncompromising in our actions and behaviors is our personal responsibility.

2.3 Qualfon’s Zero-Tolerance Policy For all of our protection and benefit, Qualfon does not tolerate any theft or acts of fraud against the company or any of its constituents.

2.4 We Need Your Help Qualfon has several methods and approaches in detecting violations, but we also need your assistance in preventing, identifying, and counteracting any act that may threaten or cause damage to our company assets.

2.5 Respond to Questions and Concerns If approached with a question or concern related to the Code of Ethics, listen carefully and give the employee your complete attention. Ask for clarification and additional information. Answer any questions you can, but do not feel that you must give an immediate response. Seek help if you need it. If an employee raises a concern that may require investigation under the Code of Ethics, contact the Human Development Office or the site director.

2.6 Reporting Concerns a) Anonymity and Confidentiality When you make a report, you may choose to remain anonymous, although you are encouraged to identify yourself to facilitate communication. If you make your identity known, the investigators will take every reasonable precaution to keep your identity confidential. To help maintain confidentiality, avoid discussing these issues, or any investigation, with other employees. Because we strive to maintain strict confidentiality in all investigations, we may not be able to inform you of the outcome of an investigation.

Report a concern to the Qualfon Business Ethics & Values Line +1 (312) 283.1960 or +1 (877) 283.7105

b) Investigations Qualfon takes all reports of possible misconduct seriously. We investigate the matter confidentially, determine whether the Code of Ethics or the law has been violated, and take appropriate corrective action. If you become involved in a Code of Ethics investigation, cooperate fully and answer all questions completely and honestly. c) Retaliation Qualfon’s STRIDES values the help of employees who identify potential ethics violations. Any retaliation against an employee who raises is a violation of the Code of Ethics. If an employee has raised a concern or participated in an investigation, he/she will not experience any adverse employment action due to such report or participation, including separation, demotion, suspension, loss of benefits, threats, harassment, or discrimination. If you work with someone who has raised a concern or provided information in an investigation, you should continue to treat the person with courtesy and respect. If you believe someone has retaliated against you, report it immediately. d) Making False Accusations Qualfon will protect any employee who raises a concern honestly, but it is a violation of the Code of Ethics to knowingly make a false accusation, lie to investigators, or interfere or refuse to cooperate with a Code of Ethics investigation. Honest reporting does not mean that you have to be correct when you raise a concern; you just have to reasonably believe that the information you are providing is accurate.

Qualfon will protect any employee who raises an honest concern.

3. Service 3.1 Serving Our Customers and Vendors Our partnerships with clients and customers is significant. We treat partners in the same manner we expect to be treated.

Always deal fairly with clients and customers by treating them honestly and with respect. We will not engage in unfair, deceptive, or misleading practices and we will always present Qualfon in an honest and forthright manner.

4. Teamwork 4.1 Employment Relationship Your employment is voluntary "at-will," which means that you or Qualfon may terminate the employment relationship at any time. The current labor laws in the country of your employment, along with the terms of any employment contract or agreement, govern your employment relationship.

4.2 Conflicts of Interest Act in the best interest of Qualfon while performing your job. A conflict of interest arises when your personal activities and relationships interfere, or appear to interfere, with your ability to act in the best interest of the company.

Take particular care if you are responsible for selecting or dealing with a supplier on behalf of Qualfon.

If you accept another job that has no conflict of interest or that does not interfere with your position or performance at Qualfon, you must comply with your employment; however, if that relationship is with a supplier, competitor, or customer, or if the business opportunity is similar to Qualfon, you must have the express permission of Qualfon.

In any case, you cannot create, design, develop, or sell any product or service that competes with Qualfon.

To avoid a possible conflict of interest, before taking on another job or commercial commitment, you must discuss the details with your immediate supervisor or Human Development and obtain the respective authorization.

Determining Conflicts of Interest: In any potential conflict of interest situation, ask yourself: Could my personal interests interfere with those of Qualfon?

Am I completely transparent to others, either inside or outside of Qualfon? *When unsure, seek guidance.

4.3 Political Activity a) Dealing with Governments The global nature of our business often requires that we interact with officials of various governments around the world. Transactions with governments are covered by special legal rules, and are not the same as conducting business with private parties. Consult Qualfon legal department to be certain that you are aware of, understand, and abide by these rules. Please read the Anti-Bribery Policy. b) Participation in the Political Process Qualfon maintains positive relations and legal and limited collaboration with the governments where we operate, but does not participate in national or international political issues of any kind.

5. Results 5.1 Company Assets We protect Qualfon’s assets and use those assets in the manner intended—that is, not for personal benefit or the benefit of anyone other than Qualfon.

Use common sense. For example, the occasional personal phone call or email from your workplace is acceptable. Excessive personal calls or email is a misuse of assets.

Qualfon policy may allow additional personal use of certain assets, such as a Qualfon car or wireless communication device. Always check relevant local policies to ensure that you are using Qualfon assets as intended.

Theft of Qualfon assets—whether physical theft, such as unauthorized removal of company equipment or information, or theft through embezzlement or intentional misreporting of time or expenses—may result in termination and criminal prosecution. The company treats workplace theft of assets belonging to other employees the same way it treats theft of company assets.

The use of Qualfon assets outside of your responsibilities—such as using company materials or equipment to support personal interests—requires prior, written approval from Qualfon’s director.

You must have this approval renewed annually, if you continue to use the asset outside of work.

5.2 Use of Time, Equipment, and Other Assets

Do not engage in personal activities during work hours that interfere with or prevent you from fulfilling your job responsibilities.

Do not use Qualfon computers and equipment for outside businesses or for illegal or unethical activities, such as gambling, pornography, or offensive subject matter.

Do not take for yourself any opportunity for financial gain that you learn about because of your position at Qualfon or through the use of company property or information.

5.3 Personal Use of Computers, Laptops, Email and Voice Messaging Qualfon's computers, email, and voicemail are for employment purposes. They can be used for personal purposes only occasionally and/or in extreme cases, but always in a responsible and ethical way.

However, as a governing principle, these systems and equipment are owned by Qualfon, so it is up to the company to monitor their use. Unauthorized software, data, or hardware cannot be added to a computer belonging to Qualfon without proper permission.

The abuse of email includes but is not limited to: the use of email to violate the laws or policies of Qualfon; to send offensive, suggestive, or obscene messages; or to harass another employee. The email messages are stored for a given time period, and you should not send any information by email that would be inappropriate if submitted in written form.

Computers, email, and voice messages are monitored and can be reviewed at any time by the company in accordance with legal procedures. You cannot monitor the electronic files, paper files, email, or voice messages of another employee or client without the permission of that employee or the Legal Department.

For questions, refer to the Acceptable Use of Resources Policy, the Email Use Policy, and any related policy or procedure.

Examples of Qualfon Assets: Company money Company product Employees’ time at work Computer systems and software Telephones Wireless communication devices Photocopiers Tickets to concerts or sporting events Company vehicles Proprietary information Company trademarks

6. Integrity 6.1 Gifts and Gratuities Gifts, Meals, and Entertainment Do not accept gifts, meals, entertainment, or any other favor from customers or suppliers if doing so might compromise, or appear to compromise, your ability to make objective business decisions in the best interest of Qualfon. Acceptance of gifts, meals, or entertainment that exceeds the following limitations must be approved in writing by the Human Development Office. a) Gifts Do not accept gifts in exchange for doing, or promising to do, anything for a customer or supplier.

c) Refusing Gifts, Meals

Do not ask for gifts from a customer or supplier.

and Entertainment

Do not accept gifts of cash or cash equivalents, such as gift cards.

If you are offered a gift,

Acceptable gifts include a logo pen or t-shirt, or a small gift

meal, or entertainment

basket at holiday time.

that exceeds the limits

Gifts of symbolic value, such as trophies and statues that are

noted, politely decline

inscribed in recognition of a business relationship, may be

and explain the

accepted.

company’s rules. If

Gifts or discounts offered to a large group of employees as

returning a gift would

part of an agreement between the company and a customer

offend the giver or the

or supplier may be accepted and used as intended by the

circumstances under

customer or supplier.

which it was given

b) Meals and Entertainment

preclude its return, you

Do not accept meals or entertainment in exchange for doing,

may accept the gift, but

or promising to do, anything for a customer or supplier.

you should notify your

Do not ask for meals or entertainment from a customer or

Human Development

supplier.

Office. The Human

You may accept occasional meals and entertainment from

Development Office will

customers and suppliers if the event is attended by the

work with you and the

customer or supplier and the costs involved are in line with

Mission Office to donate

local custom for business-related meals and entertainment.

the item to charity or to

For example, ordinary business meals and attendance at local

distribute or raffle the

sporting events generally are acceptable. During these

item among a large group

occasions, observe responsible use of alcohol.

of employees.

Given the value Qualfon places on the dignity of the human person, we do not entertain at or accompany clients or suppliers to establishments that exploit men or women (e.g. strip clubs).

6.2 Recording of Conversations Qualfon prohibits the recording of phone conversations without notifying all of the people involved, except in cases involving a court order or legal procedure. If your job involves telephone calls with our customers' clients, those calls may be recorded for quality control or other commercial purposes, which is public knowledge.

6.3 Employee Health and Safety Qualfon seeks to ensure that its our workplace is safe and healthy. You are also responsible for sharing this responsibility to act in a safe manner, as well as to participate in safety and/or training practice. Report immediately any unsafe conditions, risk, or injury in the workplace to your supervisor, Human Development, Facilities, Security, or the person in charge.

Qualfon also prohibits any behavior that could lead to an unsafe work environment, such as: Threatening or violent behavior Possession of weapons or other contraband items on the premises Damage to company property Damage to the property of customers partners, suppliers, or other employees

These behaviors must be reported immediately to the site director, the Human Development Office, or, if criminal, law enforcement.

6.4 Business and Financial Records Ensure the accuracy of all Qualfon’s business and financial records. These include not only financial accounts, but other records, such as quality reports, time records, expense reports, and submissions such as benefits claim forms, employment applications, and resumes. Ensuring accurate and complete business and financial records is everyone’s responsibility—not just a role for accounting and finance personnel. Accurate recordkeeping and reporting reflects on the company’s reputation and credibility and ensures that Qualfon meets our legal and regulatory obligations.

Always record and classify transactions in the proper accounting period and in the appropriate account and department. Do not delay or accelerate the recording of revenue or expenses to meet budgetary goals.

Estimates and accruals must be supported by appropriate documentation and be based on your best judgment.

Ensure that all reports to regulatory authorities are full, fair, accurate, timely, and understandable.

Never falsify any document.

Do not distort the true nature of any transaction.

Never enable another person’s efforts to evade taxes or subvert local currency laws. For this reason, payments generally must be made only to the person or firm that actually provided the goods or services. Payments should be made in the supplier’s home country, where it does business, or where the goods were sold or services provided, unless the supplier has legally assigned payment or sold its accounts receivable to another entity with evidence by proper documentation.

6.5 Company Financial Resources You are responsible for, and must maintain confidentiality regarding any company financial resources that you have been authorized to use. Purchase orders, authorizations, receipts, invoices, or other records of purchases or expenses must be authorized by the appropriate hierarchical level, according to the current policy. It is your responsibility to keep the corresponding records in cases of authorizations, purchase orders, advances on expenses, or reimbursements that have been entrusted to you under such procedures. You are also responsible for those products or services that you have been asked to order from a third party. Make sure that Qualfon receives quality products and services with the funds you use or authorize, and that they are acquired under the protection of the current purchasing policy. We urge you to become familiar with these policies and follow them accordingly. Talk to your supervisor or other authorized company representative if you have questions about the efficient use of resources.

6.6 Accuracy of Reports Qualfon regularly reports to the Board of Directors and Executive Committee.

Confidential business records include, but are not limited to: Payroll records Service reports Customer accounts Performance and measurement records Correspondence and reports to customers Financial reporting and accounting

ur Qualfon wants yo to the actions to adhere racy principle of accu work. and reliability at

Fraud and/or deception are strictly prohibited by law and by Qualfon. If you become aware or suspect that company records are inaccurate or contain omissions, or that the procedures to save or submit information have not been strictly followed, it is your obligation to notify your immediate superior.

6.7 Corporate Records Qualfon only preserves, stores, and protects business records (including emails or other computer-generated records) in accordance with applicable laws, acceptable practices, and the information retention policies of the company or contractual obligations with clients. Once the company is aware of the threat of a legal claim, we seek to preserve relevant information, including records that would

6.9 Strive for Accuracy

otherwise be disposed of in accordance with company

Employees must strive to be

policies. You must notify the Legal Department of all

accurate when preparing any

possible legal claims in order to initiate a process of fraud

information for the company,

detection or security incidents.

but honest mistakes will occasionally happen. Only

6.8 Confidential and Proprietary Information Privacy

mistakes as a result of gross

Qualfon respects the privacy of all our employees, business

negligence, reckless

partners, clients, and costumers. We must handle personal

indifference, or intentional

data responsibly and in compliance with all applicable

efforts to misrepresent,

privacy laws. Employees who handle the personal data of

improperly record transactions,

others must:

or otherwise falsify a company business record, are Code of Ethics violations.

Act in accordance with applicable law.

Act in accordance with any relevant contractual obligations.

Collect, use, and process such information only for legitimate business purposes.

Limit access to the information to those who have a legitimate business purpose for seeing the information.

Take care to prevent unauthorized disclosure.

6.10 Use of Private Information Safeguard Qualfon’s private information, which includes everything from contracts and pricing information to marketing plans, technical specifications, sensitive employee information, pricing information and Snap Shot report.

Private Information Do not disclose private information to anyone outside Qualfon, including family or friends, except when disclosure is required for business purposes or is protected by law. Even then, take appropriate steps, such as execution of a confidentiality agreement, to prevent misuse of the information. Do not disclose private information to others inside Qualfon unless they have a business reason to know, and communications have been classified according to the Information Security Policy.

Employees are obligated to protect Qualfon's private information at all times, including outside of the workplace and working hours and even after employment ends.

6.12 What Is Private Information?

It is any information that Qualfon has not disclosed or made

Retain or discard Qualfon records in accordance with Qualfon's record retention policies. Our legal counsel may occasionally issue notices regarding retention of records in the case of actual or threatened litigation or government investigation. Employees must abide by the directions contained in these notices, as failure to do so could subject Qualfon and our employees to serious legal risks.

Qualfon recognizes the rights of our employees under applicable statutes to discuss amongst each other the terms and conditions of their employment at Qualfon, and nothing in this Code is meant to restrict such employee discussion or other rights to engage in lawful concerted activities.

generally available to the public.

Examples include information related to: Employees Contracts Strategic and business plans Major management changes Mergers and acquisitions Technical specifications Pricing Proposals Financial data

6.11 Corporate Espionage and Sabotage It is essential to prevent information that is valuable to Qualfon from falling into the wrong hands: competitors, saboteurs, espionage agents, or others seeking to harm Qualfon. Such information includes, but is not limited to: Safety procedures Location of data centers Data restoration procedures Financial information Employment conditions: Job descriptions, salaries, compensation plans, contract type, employee lists, etc., is classified as confidential, and it is strictly prohibited for managers or employees to discuss such terms and conditions with competitors, customers, or partners.

Qualfon information must be carefully protected and disclosed only with proper authorization and the proper safeguards.

Protect the confidential information of our current and potential clients as you would protect our own information. Never use the trademark, name, logo, or other registered material without written permission.

When you end your employment relationship with Qualfon, you must turn in all documents, files, or other information and property belonging to the company. Even after you have finished your employment, you still have the obligation to protect and not to use or disclose such information.

7. Dignity Qualfon seeks to ensure a respectful work environment 7.1 Free of Discrimination Qualfon seeks to ensure a work environment free of discrimination. Qualfon expressly prohibits any form of discrimination or harassment based on race, color, creed, religion, national origin, citizenship, gender, age, mental or physical disability, political beliefs, sexual orientation, marital status, pregnancy, economic status, military or veteran status, or other status protected under applicable law in the applicable jurisdiction in any decision regarding employment or in the administration of policies. Qualfon seeks to do business with suppliers, partners, clients, and customers who are committed to equal employment opportunities.

7.2 Fair Treatment of Employees Qualfon prohibits discrimination in any work-related decision on the basis of race, color, national origin, religion, gender, physical or mental disability, medical condition (e.g., cancer-related or genetic characteristics), ancestry, marital status, age, sexual orientation, military or veteran status, or citizenship.

We are committed to providing equal employment opportunity and a work environment where each employee is treated with fairness, dignity, and respect.

We will make reasonable accommodations to the known physical and mental limitations of otherwise-qualified individuals with disabilities. If an individual requires accommodations or needs assistance, he or she should contact the Human Development Office.

Any form of workplace violence or sexual harassment is strictly prohibited.

Any form of workplace exhibition of sexual behavior is strictly prohibited.

For employees who observe or experience any form of discrimination, harassment, or violence, Qualfon provides a number of people to whom to report the incident to, including but not limited to the following: your supervisor, manager, the Mission Office, Legal Counsel, your Human Development manager, or your site director.

7.3 Illegal Drugs and Alcohol To ensure a safe, healthy, and productive working environment, Qualfon prohibits the possession, use, consumption, or supply, by any means, of alcohol or non-prescription drugs on company premises. Our company promotes an alcohol and drug-free environment.

7. 4 Harassment Free Qualfon prohibits any practice of harassment and does not expect you to tolerate it, whether directed at yourself or others. If you are the subject of discrimination, any other form of harassment, or other forms of offensive behavior, report it to a Human Development representative, a manager, or site director in your work unit. Any complaints of offensive behavior are seriously and rigorously analyzed and investigated, without any risk of retaliation for the person(s) reporting the harassment.

Employees may send a complaint of harassment via email to ethics@qualfon.com.

7.5 Personal Time Qualfon encourages and respects your personal hobbies and interests; however, personal interests, other jobs, or academic, religious, or social commitments cannot interfere with the performance of your work. You have an obligation to be honest with the time you commit to your job. This includes arriving at the agreed time (start of work, meetings, return from meals, etc.) and not incurring absences or late arrivals, as well as limiting personal business during work time.

8. Encouragement 8.1 Positive Communication The way we speak is a window into our hearts and minds. Our words can console, comfort, inspire, motivate, and elevate. A few kind words can boost the spirit and lighten our burden. We are committed to avoiding any verbal violence or gossip and, through our words, make people’s lives better.

8.2 Community Involvement Qualfon and our partners dedicate time and resources to improve the quality of life in the communities in which we operate around the world. This idea is accepted as one of the core values of Qualfon. Qualfon encourages our employees to be good citizens and to participate in support their communities in an active and personal way. All these initiatives are carried out on a voluntary basis and will not result in any work-related decisions that impact an employee positively or negatively.

9. Spirituality 9.1 Spiritual Diversity Qualfon is a unified family of many diverse cultures, backgrounds, ethnic groups, political opinions, and religious beliefs. We promote mutual respect and appreciation for all.

We encourage you to embrace your spirituality and moral code, so as to find transcendence and meaning in your life.

By doing so, we will achieve the common good. We are all equal; therefore, we have the right to be respected equally, to have a religious belief of our choice, or to have none at all.

Qualfon prohibits discrimination in any work-related decision on the basis of religion or lack thereof.

10. Compliance All employees are required to understand and act in accordance with this Code of Ethics and the policies of Qualfon. We also expect you to act with integrity in all areas not mentioned in this Code.

In accordance with applicable laws and policies, a violation of this Code of Ethics will result in disciplinary action, including possible termination of employment.

4401 Innovation Dr, Fort Collins, CO 80525

www.qualfon.com

Phone. 1 630 689 0145