Equality, Non-Discrimination, and Prevention of Sexual and Workplace Harassment Policy

1. Purpose

To set out the principles and mechanisms through which Acople Digital, Ltd. (hereinafter, "the Company") guarantees equal opportunity, prohibits discrimination, and prevents, handles, and corrects sexual and workplace harassment within the scope of its activities.

2. Scope

This policy applies to staff, interns, contractors, suppliers, candidates for a position with the Company, clients, and any other person who interacts professionally with the Company, within the context of that interaction.

3. Principles

• Professional decisions (hiring, project assignment, evaluation, termination of the relationship) are based on competence, conduct, performance, and the legitimate needs of the work.
• Sexual or workplace harassment is not tolerated in any professional relationship connected to the Company.
• Reports are handled with confidentiality, impartiality, and respect for due process for everyone involved.

4. Equal opportunity

The Company offers equal opportunity in its hiring, project-assignment, evaluation, and professional-development processes. The corresponding decisions are based on competence, conduct, performance, and the legitimate needs of the work, without distinction based on the grounds listed in the following section.

5. Prohibition of discrimination

The Company prohibits any form of discrimination, in particular on the grounds of:

• Sex
• Gender
• Gender identity or expression
• Sexual orientation
• Age
• Disability
• Nationality
• Ethnic origin
• Socioeconomic status
• Religion
• Opinion
• Marital status
• Pregnancy
• Family responsibilities
• Health condition
• Any other condition protected under Costa Rican law

6. Prevention of sexual harassment

Sexual harassment is not tolerated in any professional relationship connected to the Company. It is understood as any unwanted conduct of a sexual nature that affects a person’s dignity or creates an intimidating, hostile, or offensive environment, including — without limitation — the conduct described in section 8.

7. Prevention of workplace harassment

Workplace harassment is likewise not tolerated. It is understood as repeated conduct, by one or more persons against another, in a professional setting, intended or resulting in intimidating, degrading, humiliating, or isolating the affected person, including — without limitation — the conduct described in section 8.

8. Prohibited conduct

Without this list being exhaustive, the following are considered conduct prohibited under this policy:

• Unwanted comments, jokes, insinuations, or gestures of a sexual nature.
• Non-consensual physical contact of a sexual nature.
• Requests for sexual favors, explicit or implicit, tied to a professional decision.
• Displaying or sending unsolicited sexual content, including through digital means.
• Insults, humiliation, ridicule, or repeated belittling directed at a person.
• Deliberate isolation, unjustified exclusion, or task assignment intended to undermine a person.
• Disproportionate surveillance, pressure, or control without a work-related justification.
• Any unjustified differential treatment based on the grounds listed in section 5.

9. Reporting channel

Anyone within the scope of this policy may report a situation of discrimination or harassment through:

Email

info@acopledigital.com

Contact form

acopledigital.com/en/contacto

10. Confidentiality

Information related to a report is handled confidentially, limiting its disclosure to the people strictly necessary to address and resolve it.

11. Prohibition of retaliation

Any form of retaliation against a person who files a report in good faith, participates in its review, or provides related information is prohibited. Retaliation is itself a breach of this policy.

12. Handling and review of reports

Every report received is reviewed by General Management with impartiality and respect for the due process of everyone involved. Filing a report does not, by itself, imply the guilt of the person named.

13. Corrective measures

When a report's review confirms conduct contrary to this policy, the Company adopts corrective measures proportional to the facts and consistent with Costa Rican law and with the nature of the applicable contractual relationship (employment, contractor, or supplier, as applicable).

14. Responsibilities

General Management is responsible for approving, communicating, and keeping this policy in force, and for handling reports filed under it. Each staff member and contractor is responsible for knowing and observing this policy in their professional relationship with the Company, with colleagues, and with third parties.

15. Communication and awareness

This policy is communicated to staff and contractors when they begin their relationship with the Company and remains publicly available on this website. The Company promotes periodic awareness of its content within its operation.

16. Periodic review

This policy is reviewed at least once a year, or sooner if a significant legal or operational change makes it necessary. Each review is documented with its date and outcome.

17. Approval, version, and effective date

This is version 1.0 of Acople Digital, Ltd.'s Equality, Non-Discrimination, and Prevention of Sexual and Workplace Harassment Policy, approved by General Management on September 3, 2026, effective as of that same date. Its next ordinary review is scheduled for September 2027, without prejudice to an earlier review under the previous section. See the document record at the top of this page for full approval and traceability details.