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Code of Conduct


FLUVIP (hereinafter, “FLUVIP” or the “Company”) is a leading Influencer Marketing company that is part of a business group with a presence in Latin America and the Hispanic market in the United States. The group was founded in Colombia in 2013 and thanks tou technology has grown exponentially throughout the region. Today it has its own offices in Miami, Mexico, Colombia, Peru, Spain and Argentina.


Integrity and honesty have always been the pillars on which our company was built. Both pillars are part of our corporate culture, and unite us across all our divisions, sections and regions around the world. 


FLUVIP's success depends on the Company's reputation locally and globally. Each of our employees should strive to conduct our business with integrity and honesty. Our future success depends on the trust in the environment where we carry out our activity.


We are aware that the vast majority of our employees, shareholders and influencers operate ethically and in accordance with the laws and regulations. This Code of Conduct is nothing more than the reaffirmation of our daily work and the confirmation of our commitment to our principles and values. This Code of Conduct establishes clear ethical standards so that our employees, shareholders and influencers have the necessary guidance in the development of daily activities and in decision-making.


This Code of Conduct is mandatory for all FLUVIP employees, shareholders and influencers.


Each is responsible for reading and understanding this Code of Conduct as well as all laws and regulations relating to Company activities. Failure to comply could result in sanctions that even imply the termination of the employment and/or contractual relationship.


This Code of Conduct is not intended to replace laws, regulations, or governmental and/or control body guidelines. In the event of any point of divergence between this Code of Conduct and local laws or obligations, the dictates of local laws and regulations will prevail.




Compliance with Laws and Government Regulations

All employees, shareholders and influencers are obliged to fully comply with all laws and any government regulations that are applicable to the activity carried out by FLUVIP. 


In cases where Company policies differ from local law or custom, the most restrictive policy should be followed. 


If any employee, shareholder and influencer becomes aware of or suspects a violation by an employee or the Company of any law or government regulation, they must immediately notify their superior or the FLUVIP contact person._cc781905- 5cde-3194-bb3b-136bad5cf58d_


corruption and bribery

Employees, shareholders and influencers must comply with the applicable legal provisions for the prevention and fight against corruption in force.


In no case may employees, shareholders and influencers carry out any action that implies payment, offer, promise, directly or indirectly, to any public official (whether it is municipal, state or federal) that is not based on a legal obligation. and legitimate.


Gifts to public officials will only be allowed if they are a common business practice and are ethical, as long as they are not made with the aim of inducing that official to use his influence against the government and/or any body, company, political party, public authority with the purpose of influencing a future decision or obtaining business advantages.


If any employee, shareholder or influencer becomes aware of any information that may indicate that there has been or exists any type of action, payment, offer, promise, directly or indirectly, to any public official with the aforementioned objective, they must communicate that fact in immediately to your superior or to the contact person of FLUVIP. 



Fraud can be defined as any intentional act or practice designed to obtain an illegal economic benefit using deception or taking advantage of another, or to cause property damage to a person even if no profit is obtained for himself or a third party._cc781905-5cde- 3194-bb3b-136bad5cf58d_


FLUVIP's objective is to detect, prevent and investigate fraud, which is why internal controls designed to detect, prevent and respond to fraud cases must be carried out. 


Employees, shareholders, influencers, and especially FLUVIP senior managers, must be alert to possible fraudulent activities within the Company, particularly in those activities that are related to their specific responsibilities. 


If any employee, shareholder or influencer becomes aware of any information that may indicate that fraud has existed or exists, they must immediately notify their superior or the FLUVIP contact person. 




FLUVIP is committed to its occupational health and safety policies, and must promote the physical and psychological well-being of employees.



The workplace provided by FLUVIP must be safe and hygienic. Employees must be aware of the safety and health rules in order to apply them at all times, collaborating to maintain a contamination-free environment. Security risks and incidents must be reported and controlled immediately.


FLUVIP prohibits its employees and third parties unrelated to the Company, from entering a  Company facilities carrying illegal drugs, weapons, and other devices and tools that could endanger the health and safety of employees .


Employees are prohibited from working under the influence of illegal drugs, alcohol or other substances that have not been prescribed by a physician. Only in those events that by their nature involve the consumption of alcohol will the consumption of alcoholic beverages be allowed at tolerable levels.



All relationships between employees, shareholders and influencers must be based on mutual respect, being a fundamental pillar in work relationships. For this reason, efforts must be made to create a work environment of trust, respect and free from harassment (be it verbal, physical, psychological, etc.).


In turn, the work environment must be diverse and inclusive, and be free of any discrimination. In this sense, the Company repudiates and discourages actions and/or conducts that ridicule, intimidate, threaten, degrade and/or affect any person and/or the work environment.


If any employee becomes aware of any discriminatory, degrading, harassing or intimidating act, they must immediately notify their superior.




All information, whether business or related to clients or employees, must be treated confidentially unless its disclosure is authorized by FLUVIP or must be revealed  by virtue of a law, decree, resolution, regulation or order issued by a court or competent governmental or administrative body.


FLUVIP implements and has in force appropriate measures to prevent unauthorized disclosure and/or use of confidential information of the Company and/or its customers, suppliers and employees. 


Employees have been instructed to take special precautions when transmitting information via email, fax, Internet or other means, and they are prohibited from duplicating or copying the material sent, except when strictly necessary.


Personal information

FLUVIP protects the personal data of its customers, suppliers and employees and uses this data only for legitimate and authorized business purposes. The employees and mainly the senior managers of FLUVIP must be clear when and how to collect, use or share personal data, and in all cases adopt the appropriate security measures to protect such data.


Conflict of interests

It is FLUVIP's policy to avoid any conflict of interest that its employees and/or managers may have with the Company. The decisions made by the Company's employees or managers regarding FLUVIP's commercial transactions cannot be influenced by their personal or private interests. 


R.resources and assets

Company employees are responsible for the proper use and care of the resources that FLUVIP makes available for work. Safeguarding computer resources is decisive since the Company relies on technology to carry out its activity on a daily basis.


The use of Company resources and assets for personal use, including office equipment, desktop and laptop computers, software, fixed and mobile telephony, Internet access and email, postal mail, equipment printing, copying and photocopying.


For the reasons stated, it is prohibited to withdraw from the Company any assets and resources for personal use without the express authorization of a superior.





FLUVIP  prepares its financial statements and maintains its accounting records in accordance with generally accepted accounting principles and the regulations of the country where it operates.


Company employees whose specific activities include having access to or managing accounting information must ensure the veracity, accuracy and authenticity of the information contained in the accounting records, since decision-making fundamentally depends on them.


If any employee, shareholder or influencer becomes aware of any information that may indicate that there have been or are violations of any law or policy in relation to the Company's accounting records or operations, they must immediately notify their superior or the person FLUVIP contact. 



In some cases, FLUVIP may be subject to internal or external accounting audits, for which reason employees are obliged to fully cooperate with all requests for information.


Employees are prohibited from attempting to influence, mislead, interfere with, manipulate, or provide inaccurate information in response to or to misrepresent the results of an audit.

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