Acting with Integrity

Worldwide

Date: May 15th, 2016

CODE OF CONDUCT

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1. Our ethical principles

2. Our ethical conduct and anti-

corruption principles

3. Acting with integrity and mysticism

4. Integrity in the company

5. Integrity in dealing with third parties

6. Privacy policy

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Our ethical principles

Employment is freely chosen

We respect freedom of association and the

right to collective negotiation

We provide safe and hygienic working

conditions

We work regularly, without excess and with

dignity

We do not employ child labor

We do not discriminate or treat in a cruel or

inhuman way

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Mudanzas Internacionales Global bases its business practices

on sound ethical principles in benefit of and in order to, ensure

in each of the workers and members of the organization a fair

and secure environment, conducive to the growth of everyone. In

this sense, we guarantee that:

The staff working in the company enters freely and

voluntarily, likewise, they have the same freedom to

terminate the employment relationship whenever they

deem appropriate. In Mudanzas Internacionales Global

there is no forced prison labor or servitude.

All workers have the right to join or form unions and

develop organizational activities, associations and

collective negotiations freely and without discrimination.

The staff carries out its activities in a safe and hygienic

environment where all appropriate measures to safeguard

their physical integrity are considered in order to minimize

the risks to which they may be exposed.

Our workers receive safety training and health services

with the required regularity, as well as all those basic

services such as clean sanitation and potable drinking

water.

Our workers enjoy fair wages consistent with current

national legislation as well as working conditions aimed

at improving their quality of life, based on employment

contracts and payment receipts that guarantee the

transparency of their employment benefits. In no case we

affect their wages with deductions as disciplinary actions,

for any reason not justified in national legislation.

Our workers, if they so decide voluntarily, could work extra

hours as long as they do not exceed the maximum set by

national legislation in force. Overtime is paid meeting and

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exceeding the provisions of the law and, likewise, workers

break time is respected, always protecting their health and

safety.

We do not hire child labor and all work performed by the

company is done by mature staff, according to current

legislation.

Under no circumstances discrimination will be permitted

in any of the processes and operations of the company,

including recruitment activities, compensation, training

and staff movements. Discrimination is conceived from all

areas, covering the grounds of race, religion, age,

disability, gender, marital status and sexual or political

orientation.

Under no circumstances inhuman or cruel treatment will

be allowed by, or for, any individual or member of the

organization. Mudanzas Internacionales Global ensures

that no situations of physical, sexual or other type of abuse

are generated and strictly prohibits harassment, verbal

abuse or any other forms of intimidation.

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Our ethical conduct and anti-corruption

principles

In Mudanzas Internacionales Global, we

maintain an ethical conduct and anti-

corruption principles, ensuring that our

operations and activities are transparent

throughout our business model. In that

sense, we believe and ensure compliance with

the following principles:

We never participate in any form of bribery,

either directly or through third parties.

We never offer, make or authorize an

improper payment (cash or otherwise) to any

individual, including any local or foreign

officials to anywhere in the world.

We never try to induce an individual, or a

local or foreign official to act illegally or

incorrectly.

We never offer or accept money or anything of

value, such as gifts or commissions with the

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intention of obtaining business or the awarding of a

contract.

We never offer or give any gifts or show hospitality to

any employee, public official or representative, if there

is any expectation or implication for a favor to be

returned.

We never accept gifts of a business partner if there is

any suggestion or implied or implicit expectation for a

favor to be returned.

We never facilitate payments to obtain a level of service

that would not normally be performed.

We never ignore or fail to report any indication of

improper payments to the appropriate authorities.

We never induce or help another individual or third

parties to break any applicable law or regulation.

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Acting with integrity and mysticism

o What is expected from every one?

o What is expected from managers?

o When is written approval required?

o Who should follow the code?

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Integrity is essential for Mudanzas Internacionales Global C.A.,

along with our other values of leadership, passion,

accountability, collaboration, diversity and quality, it is a

column of our organization.

Integrity means doing the right thing. By acting with integrity,

we reflect positively the righteousness and reputation of the

company.

The Code of Conduct will help to guide us. The code defines how

employees should conduct themselves as representatives of

Mudanzas Internacionales Global C.A.

The code addresses our responsibilities to the company, with

each of us, with customers, suppliers and governments.

We must follow the law, act with integrity and honesty in all

aspects and be responsible for our actions.

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What is expected of every one?

Compliance with the code and the law.

Understand the code. Comply with the code and the law wherever

you are.

Use good judgment and even prevent misconduct.

Consider your actions and ask for advice.

If you ever have a doubt about a behaviour, ask yourself:

• Is it consistent with the code?

• Is it ethical?

• Is it legal?

• Will it reflect well my image and the Company’s?

• Would I like to read about this in the newspaper?

If the answer is "No" to any of these questions, do not do it.

If you still have doubts, ask for advice. The code tries to capture

many of the situations that employees will face, but it can not

consider all the circumstances. You can seek help from:

• Your management division.

• The legal adviser or senior management personnel that supports

company business.

What is expected of managers?

Promote a culture of ethics and compliance.

Managers should always be models of appropriate behaviour. As a

manager, you should:

• Ensure that all subordinates understand their responsibilities

under the code as well as other company policies.

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• Seize opportunities to discuss with employees the code and

reinforce the importance of ethics and compliance.

• Create an environment where employees feel comfortable raising

concerns.

• Consider conduct in relation to the code and other company

policies when employees are evaluated.

• Never encourage or direct employees to achieve business results at

the expense of ethical conduct or compliance with the code or the

law.

• Always act to prevent violations of the code or the law by those

under your supervision.

When is written approval required?

Certain actions referenced in the code, specifically, the use of

company assets outside their workplace and some situations with

conflicts of interest, require prior written approval of the ethics

officer. This approval must be renewed annually if the situation

persists.

Your ethics officer is an employee at the group level of the business

unit with shareholding of the company, appointed to make these

determinations.

If you are in a situation that may require the approval of the ethics

officer, you can contact your ethics officer directly or may first notify

your manager, who can help you get the necessary approval. For

ethic officials themselves, approval must come from the General

Counsel and the Managing Director of Mudanzas Internacionales

Global.

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Who should follow the code?

The Code of Conduct applies to all employees of Mudanzas

Internacionales Global C.A.

“Mudanzas Internacionales Global C.A.” throughout this document

refers collectively to all of these entities.

The Code and the Law

Operations and company employees are subject to the laws of

different countries and other jurisdictions around the world. It is

expected that employees comply with the code and all applicable

laws, rules and government regulations applicable to the process of

Intercontinental Transfers.

If a procedure stipulated in the code conflicts with an applicable

law, the law will rule over the code.

Because “Mudanzas Internacionales Global C.A.” is a company

constituted in Venezuela, our employees around the world often are

subject to Venezuelan laws. Other countries may also apply their

laws outside their borders to operations and personnel of the

company. If you have doubts about which laws apply to you, or

believe there may be a conflict between different applicable laws,

consult the Company Legal Counsel before proceeding.

Research

The company takes seriously all reports of possible misconduct.

We will investigate the matter confidentially, determine whether a

violation of code or law has occurred, and take appropriate

corrective actions. If you participate in an investigation related to

the code, cooperate fully and answer all questions with integrity and

honesty.

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There will be no retaliation

The company values the help of employees who identify

potential problems that the company needs to address.

Any retaliation against an employee who presents a

problem with honesty, constitutes a code violation. That

an employee has raised a concern with honesty, or

participated in an investigation, can not be the basis of

an action that harms his/her employment, including

separation, demotion, suspension, loss of benefits, threats,

harassment or discrimination.

If you work with someone who has submited a concern or

provided information in an investigation, you should

continue to treat the person with courtesy and respect.

False accusations

The company will protect any employee who raises a

concern with honesty, but it is a violation of the code

make knowingly a false accusation, lie to investigators, or

interfere or refuse to cooperate with an investigation

related to the code. Honest reporting does not mean that

you have to be right when you raise a concern, simply

make sure that the information provided is accurate.

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Integrity in the company

Acting with integrity begins within for Mudanzas

Internacionales Global C.A. It includes how we

handle records, property and company information.

Business and financial records

Company assets

Use of information

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Business and financial records

Ensure the accuracy of all commercial and financial records of the

company. These include not only financial accounts, but other

records such as quality reports, time records, expense records and

presentation of benefits claim forms and resumes.

Ensuring accurate and complete business and financial records is

everyone's responsibility, not just a function of accounting and

finance staff. Accurate record keeping and information reflects on

the reputation and credibility of the company and ensures that the

company meets its legal and regulatory obligations.

Always record and classify transactions in the relevant

accounting period and the corresponding account and department.

Do not delay or accelerate the recording of revenue or expenses to

meet budget targets.

Estimates and accrued must be supported by appropriate

documentation and based on your best judgment.

Ensure that all reports that are sent to regulatory authorities are

complete, and that they are reasonable, accurate, timely and

understandable.

Never never falsify a document.

Do not distort the true nature of a transaction.

Do not participate in someone else's efforts to evade taxes or

subvert local currency laws. For this reason, payments should

generally be made only to the person or firm that actually provides

the goods or services. Payments must be made in the supplier's home

country, where it operates or where services were provided.

Exceptions must be approved by the International Coordination

Manager and the Unity of Ethics and Compliance or by the General

Manager.

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Company assets

Protect company assets and use those assets in the manner intended.

Do not use company assets for personal gain or any other person

other than the company.

• Use your common sense. For instance, occasional phone calls or

personal emails from your workplace are acceptable. Excessive calls

or personal emails are a misuse of property.

• Company policy may allow additional personal use of certain

assets, such as a company car or a wireless communication device.

Always check the relevant policies to ensure that company assets are

used as planned.

Theft of company assets, whether physical theft, for example,

unauthorized removal of a product, equipment or company

information, or theft through embezzlement or intentional

misinformation of hours or expenses, may lead to dismissal and

criminal prosecution. The company considers theft in the workplace

of property belonging to other employees in the same way that

considers the theft of company assets.

The use of company assets beyond their responsibilities to the

company, for instance, the use of their work product in the company

for external purposes or use of materials or equipment company to

support their personal interests, requires prior written approval of

the ethics officer. You must have annual renewal of this approval if

you continue using the asset off work.

Use of information

Protect all non-public company information, including everything

from contracts and pricing information to marketing plans,

technical specifications and employee information.

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Non-public información

Do not disclose non-public information to anyone outside the

company, including family and friends, except when required for

commercial purposes. Even then, take appropriate steps, for

example, holding a confidentiality agreement to prevent misuse of

information.

Do not disclose non-public information to others inside the company

unless they have a business reason to know, and communications

have been classified in accordance with the Policy Information

Protection.

Employees are required to protect non-public business information

at all times, both outside the workplace and working hours, and

even after the end of the employment relationship.

Retain or discard company records in accordance with record

retention policies of the company. The Company Legal Counsel may

occasionally issue notices regarding retention of records in case of

actual or threatened litigation or government investigation.

Employees must observe the instructions included in these notices,

because failure to do so could expose the company and its employees

to serious legal risks.

See the protection policy information for additional guidance and

tips to protect information.

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Integrity in dealing with third parties

External relations of Mudanzas

Internacionales Global C.A. are fundamental

to our success. We must negotiate fairly and

lawfully with everyone we encounter.

Negotiations with the Government

Negotiations with customers, suppliers and

consumers

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Negotiations with the Government

The global nature of our business often requires that we interact

with officials of various governments or embassies worldwide.

Transactions with governments are covered by special legal rules

and are not the same as conducting business with private parties.

Consult Company Legal Counsel to be sure to know, understand and

observe these rules. In general, do not offer anything to a

government official, either directly or indirectly, in exchange for

favorable treatment. You must obtain prior approval from Company

Legal Counsel before providing anything of value to a government

official. Ensure that such payments are properly recorded in the

appropriate account of the company.

Anti-bribery

Penalties for violating these laws can be severe, including

significant individual and corporate fines.

Bribes are forbidden. A bribe consists of giving or offering anything

of value to a government official to influence a discretionary

decisión. Examples of bribes include payment to a government

official to encourage a decision to award or continue business

relations, to influence the outcome of a government audit or

inspection or to influence tax or other legislation. Other payments to

government officials may also constitute bribes in some

jurisdictions. Check with the Company Legal Counsel regarding

anti-bribery local laws.

Negotiations with customers, suppliers and consumers

The company values its partnerships with customers and suppliers.

Treat these partners in the same way we expect to be treated. Always

deal fairly with customers, suppliers and treat them with honesty

and respect:

• Do not engage in unfair, deceptive or misleading practices.

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• Always present company products in an honest and straight

forward manner.

We expect our suppliers not to take actions contrary to the principles

of our code. Consequently, the owner of each supplier relationship

should ensure that compliance with the Code of Conduct for

suppliers of Mudanzas Internacionales, Global is a condition of the

contract with suppliers.

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Privacy policy

Mudanzas Internacionales Global

guarantees the confidentiality of non-public

information of the company, its customers or

suppliers ensuring that its use is only for the

interest of the organization and will not be

disclosed to competitors (even likely

competitors) or others who can use this

information to injure the business.

In this regard, we guarantee compliance of:

Consent: we undertake to request all information

with the full consent of our clients, making them

understand that we would only request information

strictly necessary for management procedures and

corresponding activities.

Collection of information: personnel involved

in requesting necessary information, will request it

formally through email, such information will be

used solely for the purpose required.

Retention and disposal of information: the customer's personal information will be

retained physical and digitally for a period not

exceeding 10 years, to facilitate engagement of new

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services by them. Digitally stored information will never be

part of a database and physical information will be destroyed

and discarded ensuring that no unauthorized person can

make use of that.

Security to keep information private: we are very

careful in safeguarding information, guarding them in safe

files to which only authorized personnel have access. The

digital information is only available to staff with access

privileges and is protected with antivirus and backup

mechanisms, in order to prevent unauthorized extraction or

loss.

Quality and monitoring information: We perform

periodic reviews of records, ensuring that the information

collected is strictly necessary and properly diligence by the

staff involved. Any irregular situation should be notified

immediately through recipients of information channels.

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For any irregular situation or non-compliance to this Code of

Conduct, please notify through our receiving channels, to be

resolved immediately by the ethics authorities of the company.

Our complaints receiving channels are the enabled media for

Mudanzas Internacionales Global to receive complaints. The

following channels have been enabled: website: www.miglobal.com

Contact section through an email to miglobal@miglobal.com and

over the phone +582129528890 requesting the Ethics and Compliance

Unit.

Other receiving channels are not valid for receiving complaints and

will have to refer either to the phone number or the link on the

website.

I confirm that I have read and understand this Code of Conduct and

that I accept and agree to abide by the principles and guidelines set

forth herein.

Date: _________________

Name and Surname: ____________________________________________

Identity Card or Passport Number: _____________________________

Organization I represent -if applicable-: _______________________