Perfecto. Aquí tienes la versión ajustada: sustituyo "Omnipro3d" por Omnipro3d LLC donde se refiere a la entidad estadounidense, y sustituyo las referencias específicas al Código Penal español por menciones genéricas al marco normativo aplicable en Estados Unidos donde no había un equivalente claro y directo. Sigue aplicando la misma advertencia: esto requiere revisión de un abogado antes de publicarse, ya que el marco legal de fondo (no solo las palabras) necesita validación experta.

Compliance Policy

Section

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1. SCOPE OF APPLICATION

This Policy applies to all employees, governing bodies, and functional areas of Omnipro3d LLC, and to all cases in which the matter concerned relates to a crime, violation, breach, or improper application of the internal policies and procedures that make up Omnipro3d LLC's Compliance System.

This Policy may also apply, in whole or in part, to third parties who interact with Omnipro3d LLC (clients, suppliers, creditors, collaborators, etc.), provided that Omnipro3d LLC has carried out due diligence in selecting such third parties, in order to ensure compliance with applicable U.S. law—including the general framework governing corporate and organizational liability in the United States, which establishes Omnipro3d LLC's obligation to monitor the conduct of those under the authority of the company's legal representatives and officers, where such individuals may have engaged in unlawful conduct as a result of a serious failure of supervision, oversight, or control, taking into account the specific circumstances of each case, regardless of whether they are members of Omnipro3d LLC or third parties interacting with the company.

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AFFECTED ACTIVITIES

In addition to this Policy, Omnipro3d LLC maintains a risk matrix of legal violations and sensitive activities, approved by the company's Corporate Compliance Body, identifying the types of conduct for which the company could face liability under applicable U.S. law for offenses committed on behalf of, or for the benefit of, the company—whether direct or indirect—(i) by its legal representatives and officers, or (ii) by individuals under their authority, where the offense results from a failure of adequate oversight, given the specific circumstances of the case.

This risk matrix not only summarizes the relevant categories of legal violations but also describes, for each one, the main sensitive activities that could give rise to legal risk, so that Omnipro3d LLC professionals remain alert to situations that could expose them to such risks in the course of their work.

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2. LIST OF OFFENSES

Omnipro3d LLC's risk matrix summarizes the categories of conduct that may give rise to liability, based on the specific activities carried out by the company, in accordance with applicable U.S. federal and state law.

Every Omnipro3d LLC professional is required to stay informed about applicable laws and their compliance obligations. It should also be noted that benefits derived from unlawful activity may be direct or indirect, and particular caution must be exercised regarding any conduct that, while unlawful, could end up irregularly or unlawfully benefiting Omnipro3d LLC.

If any Omnipro3d LLC professional has questions regarding the content of this section or wishes to obtain further information, they may contact the Compliance Function and/or consult applicable legal resources.

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3. CORPORATE GOVERNANCE

To ensure the effective implementation of the Compliance System, and to allow for its continuous updating and improvement, Omnipro3d LLC firmly believes that all governing bodies and responsible functional areas must oversee its compliance and proper operational effectiveness.

The governing bodies and functional areas responsible for decision-making within the Compliance System are detailed below.

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3.1 Board of Directors / Managing Members

The Board of Directors (or Managing Members, as applicable to Omnipro3d LLC's governance structure), as the company's highest governing and representative body, and consequently the ultimate authority responsible for oversight and control over any legal act or transaction, is committed to demonstrating leadership and firm commitment to the Compliance System by:

Establishing and upholding, as one of Omnipro3d LLC's core values, that the actions of all members of the organization must always comply with applicable law in general, and with applicable regulatory and organizational liability standards in particular, fostering an appropriate culture of compliance throughout the organization;

Adopting, implementing, maintaining, and continuously improving the Compliance System to prevent and detect violations or to significantly reduce the risk of their occurrence;

Providing the Compliance System, and specifically the Corporate Compliance Body, with adequate and sufficient financial, material, and human resources for its effective operation;

Periodically reviewing the effectiveness of the Compliance System, modifying it as necessary when serious violations are detected, or when changes occur in the organization, its control structure, its activities, or applicable legislation.

Establishing a Corporate Compliance Body responsible for the ongoing oversight and review of the Compliance System, granting it the autonomous authority and control necessary to carry out its function effectively; and

Ensuring that procedures are established to define the company's decision-making and execution processes, promoting a culture of compliance that guarantees high ethical standards of conduct.

Maintaining direct communication with the bodies responsible for designing and overseeing compliance policies.

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3.2 Executive Committee / Management Committee

The Executive Committee (or Management Committee) is responsible for monitoring all matters that may affect the company's operations, preparing business plans, establishing corresponding strategy, and determining priorities to achieve that strategy, in accordance with the guidance of the Board of Directors / Managing Members.

Like the Board of Directors / Managing Members, the Management Committee must demonstrate leadership and commitment to implementing the Compliance System. To that end, it must:

Ensure that the Compliance System is properly implemented to achieve the objectives set out in the Compliance Policy and effectively address the legal risks to which Omnipro3d LLC may be most exposed;

Ensure that the requirements arising from the Compliance System are incorporated into the operational processes and procedures of Omnipro3d LLC;

Ensure the availability of adequate and sufficient resources for the effective execution of the Compliance System;

Comply with, and enforce compliance with, both internal and external Compliance Policies;

Communicate internally the importance of effective compliance management, consistent with the objectives and requirements of the policies that make up the Compliance System;

Promote continuous improvement and support the various management roles in demonstrating leadership in preventing violations and detecting legal risks within their areas of responsibility;

Encourage the use of procedures for reporting potentially unlawful conduct that may affect the company and/or its activities;

Ensure that no member of the company is subject to retaliation, discrimination, or disciplinary action for reporting in good faith violations, or reasonably suspected violations, of the Compliance Policy, or for refusing to participate in unlawful conduct, even if doing so results in a loss of business for Omnipro3d LLC.

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3.3 Corporate Compliance Body

Omnipro3d LLC maintains a Corporate Compliance Body with autonomous authority and control over all functional areas, reflecting the company's firm commitment to compliance, review, and continuous improvement of the compliance system and good corporate governance. This body is an internal, corporate collegiate body that reports to the Board of Directors / Managing Members of Omnipro3d LLC.

This body has the authority, resources, and means necessary to implement and enforce internal control measures appropriate for detecting, preventing, and avoiding violations of applicable civil, commercial, administrative, tax, and other regulatory requirements attributable to the company, as well as for responding appropriately should any such violations occur.

This body is composed of the Chief Compliance Officer, the Ethics Officer, the Deputy General Counsel, and a partner representative from Omnipro3d LLC, bringing together the appropriate expertise to properly oversee and monitor the Compliance System.

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3.4 Compliance Officers for Omnipro3d Network Standards

To ensure compliance with the requirements established under the Omnipro3d Network Standards, Omnipro3d LLC maintains a support team for each Network Standard, which has grown in both size and expertise as requirements have increased.

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3.5 Values and Ethics Committee

Omnipro3d LLC maintains a Values and Ethics Committee, chaired by Óscar Pérez-Solero as "Ethics Officer," which employees may consult regarding the conduct required under the Code of Conduct. This Committee contributes to building a culture of regulatory compliance, as its guidance carries weight in the decision-making of leaders and employees, enabling them to make decisions that best align with compliance requirements. It oversees adherence to Omnipro3d LLC's Code of Conduct.

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3.6 Compliance Function

The Compliance Function is an independent body with autonomous authority and control, led by Óscar Pérez-Solero ("Chief Compliance Officer"), supported by Daniel Hernández Rigdy as legal counsel for the Compliance Function. It reports directly to the Board of Directors / Managing Members and has sufficient resources and autonomy to carry out its responsibilities.

Its main functions include:

Identifying compliance obligations and integrating them into policies, procedures, and processes tailored to the company;

Adopting measures to maintain a culture based on ethical principles and transparency;

Providing and organizing ongoing training support to ensure all employees are regularly trained;

Developing and implementing processes to manage information, such as complaints and/or comments received through hotlines, whistleblowing channels, or other mechanisms.

Both the Values and Ethics Committee and the Compliance Function carry out investigation, processing, and sanction-recommendation functions related to any conduct potentially constituting a civil, commercial, administrative, tax, or other regulatory violation (handled initially by the Compliance Function), or a violation of the Code of Conduct (handled initially by the Values and Ethics Committee), in accordance with the Code of Conduct and/or Omnipro3d LLC's internal regulations.

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3.7 Internal Audit

A key element of Omnipro3d LLC's Compliance System is the Internal Audit function, led by Juan Manuel Díaz. The Internal Audit Function has, among others, the following objectives:

Effectively and independently overseeing risk management at Omnipro3d LLC (including legal risks to which the company may be exposed);

Promoting, through findings and recommendations, the existence of adequate policies, procedures, and controls;

Reviewing the consistent and efficient application of the policies and procedures that make up the company's internal control system;

Assisting Omnipro3d LLC in achieving its strategic objectives and improving its processes.

Through all of the above, Omnipro3d LLC adopts and effectively executes an organizational and management model that incorporates appropriate oversight and control measures to prevent violations and significantly reduce the risk of their occurrence, granting these bodies sufficient independence and autonomy to carry out their functions.

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4. RESPONSIBILITY OF PROFESSIONALS

All Omnipro3d LLC professionals are required to ensure compliance with the policies and procedures that make up the Compliance System, both on their own behalf and on behalf of other professionals, and are therefore obligated to report any act or conduct that violates or may violate this Policy and/or any rules referenced within it, whether explicitly or implicitly.

Likewise, all professionals are required to report individual or collective conduct or activities occurring in the context of their work at Omnipro3d LLC that may violate this document or other Compliance System policies and procedures (including anti-bribery compliance), regardless of whether such conduct was ordered or requested by a more senior professional.

In this regard, all professionals must fully cooperate in the investigation of any matter for which they may be called upon, and must maintain absolute confidentiality regarding any aspect of the process, as well as any facts brought to their attention.

Anyone filing a report must provide all evidence or indications available to them at the time of the report. Knowingly reporting false facts or conduct may result in legal liability under applicable law and may lead to disciplinary sanctions.

No inquiry or report will be processed if it clearly appears that the reporter's intent is unrelated to compliance with Omnipro3d LLC's Compliance System.

The Compliance Function may initiate, on its own accord, a preliminary review or formal investigation upon becoming aware of any indication of non-compliance with applicable policies and procedures.

By way of illustration (not exhaustive), the following are examples of activities in which violations by professionals may occur:

Negotiation or contracting processes with clients or service providers where warning signs are identified and internal procedures are not followed.

Offering or promising any form of compensation to public officials to obtain an advantage or benefit—e.g., obtaining licenses or permits, expediting a process, or gaining a competitive advantage.

Breaching confidentiality agreements and disclosing confidential/strategic client information to third parties for direct or indirect benefit.

Trading, or advising others to trade or not trade, based on confidential client or supplier information, or material non-public information about Omnipro3d LLC obtained in the course of work.

Providing inadequate advisory services to entities in violation of applicable regulations (e.g., in preparing corporate governance reports, executive compensation reports, due diligence, or tax matters).

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5. AWARENESS AND STATEMENT OF COMPLIANCE

This Policy is available to all Omnipro3d LLC professionals on the company intranet. Additionally, as part of the Annual Compliance Confirmation (ACC), professionals annually confirm their awareness of and compliance with the regulatory and compliance requirements applicable to them.

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6. COMMITMENT TO CONFIDENTIALITY AND NON-RETALIATION

The Compliance Function is committed to maintaining absolute confidentiality regarding any facts and information provided to it, whether in the context of an inquiry or a report, from anyone not involved in the process, unless disclosure of such information is required by law or by a public or judicial authority.

The Compliance Function is likewise committed to taking all necessary measures to ensure the complete absence of retaliation against anyone who files a report.

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7. REPORTING INQUIRIES AND VIOLATIONS

For purposes of this procedure:

"Inquiry" refers to any question raised by anyone covered by this Policy regarding the interpretation or application of the policies and procedures that make up Omnipro3d LLC's Compliance System.

"Violation" refers to any act or conduct allegedly contrary to the Compliance System and/or the legal standards it references, whether explicitly or implicitly, as well as to professional ethical norms and principles.

All Omnipro3d LLC professionals, as well as any third party with a legitimate interest, have access to their own mechanisms and channels for reporting inquiries or violations of Omnipro3d LLC's Compliance System policies and procedures.

To this end, Omnipro3d LLC maintains a whistleblowing channel ("Ethics Helpline"), available to all professionals and third parties (clients, suppliers, etc.), through which comments, reports, or questions regarding potential violations of the Code of Conduct or Compliance System requirements can be submitted confidentially.

In addition to this channel, any employee (or third party) may contact any member of the Compliance Function or the Values and Ethics Committee directly, either in person or by email, to raise any inquiry or report.

8. RECEIPT, ANALYSIS, AND RESOLUTION OF INQUIRIES AND REPORTS

The process for receiving, analyzing, and resolving inquiries and reports follows the same process used by the Values and Ethics Committee, as detailed in the "Procedure for Inquiries Regarding Omnipro3d LLC's Code of Conduct and Investigation of Reports" (see Intranet – Corporate Information – Code of Conduct).

This procedure addresses, among other matters:

Receipt, analysis, and resolution of reports

Disciplinary case files (opening, communication, and resolution)

Follow-up on resolutions

Timelines

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9. INVESTIGATION FILE

Following the preliminary review of a report, if there is reasonable indication that an Omnipro3d LLC professional's action or omission has violated the policies and procedures of the Compliance System, an Investigation File will be opened immediately. The details of the various phases of an investigation (opening, appointment of an investigator, communication to the individuals under investigation, proposed resolution, content and approval, etc.) follow the same process established by the Values and Ethics Committee, as detailed in the "Procedure for Inquiries Regarding Omnipro3d LLC's Code of Conduct and Investigation of Reports" (see Intranet – Corporate Information – Code of Conduct).

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10. DISCIPLINARY FRAMEWORK

In accordance with this Policy, all Omnipro3d LLC professionals, regardless of their professional category, geographic location, or functional area, are required to comply with all principles, policies, and procedures that make up Omnipro3d LLC's Compliance System. They are also encouraged to report any violation of these requirements, as described in Section 4 above ("Responsibility of Professionals").

Omnipro3d LLC maintains a Disciplinary Framework related to Compliance, serving as an internal guide demonstrating the effective implementation of the Compliance System at Omnipro3d LLC, providing a means to sanction, in accordance with applicable U.S. federal and state employment law, violations of the Compliance System, which includes: (i) Omnipro3d LLC's Code of Conduct; (ii) internal policies and procedures; and (iii) applicable laws and regulations.

This Disciplinary Framework is designed to satisfy applicable legal requirements for corporate compliance programs and also applies to other violations of the Compliance System. This Framework complements the procedure for inquiries regarding the Code of Conduct and investigation of reports, which also contributes to the prevention and detection of regulatory risks.

Any employment-related measures adopted will comply with applicable U.S. federal and state law, without losing their weight or proportionality relative to the seriousness of the underlying facts.

Each violation will carry a sanction based on the following framework, which establishes different levels of non-compliance, ranked from least to most serious, along with their possible consequences:

Levels of Non-Compliance

Level 1 — Minor
A purely formal violation of current Compliance policies and procedures that does not pose a risk to Omnipro3d LLC.
Possible consequences: Verbal warning. Written warning. One-day suspension without pay. Minor impact on variable compensation.

Level 2 — Serious
Violation of one or more Compliance System policies that pose a risk to Omnipro3d LLC.
Possible consequences: Suspension without pay for one to ten days. Ineligibility for promotion to a higher category for up to one year. Moderate impact on variable compensation.

Level 3 — Very Serious
Violation of one or more Compliance System policies resulting in significant risk to Omnipro3d LLC.
Possible consequences: Temporary or permanent loss of professional category. Suspension without pay for eleven days to two months. Ineligibility for promotion to another category for two years or permanently. Significant impact on variable compensation. Termination.

Repeated violations will result in escalation to the next level of severity. In this regard, note that Omnipro3d LLC's variable compensation policy establishes compliance with R&Q, Independence, and Compliance policies as one of the essential requirements for earning variable compensation.