Comprehensive Ethics, Compliance, and Anti-Corruption System

The Comprehensive Ethics, Compliance, and Anti-Corruption System is based on Canacol Energy's principles and values, which demonstrate the organization's commitment to maintaining the highest ethical standards in its business operations. The System is composed of i) the Comprehensive Risk Self-Control and Management System for Money Laundering, Terrorism Financing, and Financing and Proliferation of Weapons of Mass Destruction – SAGRILAFT; ii) the Transparency and Business Ethics Program – PTEE; and iii) the Code of Ethics and Anti-Corruption. This system is audited annually by an independent third party.

SAGRILAFT

The objective of the Comprehensive Risk Self-Control and Management System for Money Laundering, Terrorism Financing, and Financing and Proliferation of Weapons of Mass Destruction (hereinafter "SAGRILAFT") is to prevent and manage the risks associated with money laundering, terrorism financing, and the financing and proliferation of weapons of mass destruction to which the Company is exposed in its operations and activities.

PTEE

The Company declares its commitment to preventing fraud, bribery, and corruption and, in line with this declaration, adopts the Transparency and Business Ethics Program (PTEE). This program is part of the Comprehensive Ethics, Compliance, and Anti-Corruption System, and its principles, processes, and tools aim to strengthen the company's ethical and transparent culture and its zero-tolerance philosophy towards all forms of corrupt practices, while also complying with applicable regulations on the matter.

The Transparency and Business Ethics Program (hereinafter "PTEE") of the Company has the following objectives: a) Contribute to the fight against corruption and transnational bribery. b) Establish high standards of conduct to prevent and expressly prohibit acts of Corruption and Transnational Bribery that impact or may impact the Company's local, regional, and international operations. c) Comply with current regulations on managing the risk of corruption and transnational bribery. d) Identify, prevent, and adequately manage the risks of corruption and transnational bribery to which the Company may be exposed. e) Prevent and mitigate the occurrence of sanctions, legal proceedings, reputational and/or financial damage from being involved in an issue of corruption and/or transnational bribery.

Code of Ethics and Anti-Corruption

The Code aims to promote a culture of integrity, transparency, and responsibility among employees, managers, investors, and other stakeholders within the organization. The Code provides a framework for decision-making oriented towards achieving Canacol Energy's objectives, principles, and values.

Suppliers Code of Ethics and Conduct

The Company seeks to maintain the highest ethical and business conduct standards in all its activities. As a result, the Company expects its contractors and suppliers to align with these standards, implementing minimum policies that must be adhered to by all suppliers under any type of contract, without exception, and considering the nature and obligations of each supplier regarding control entities.

This Ethics and Conduct Policy governs all suppliers, contractors, and external collaborators of the Company and aims to serve as a behavioral guide. Therefore, all Company Suppliers, without exception, are obliged to comply with the established guidelines.

Gifts and Hospitality Policy and Instruction

This policy seeks to: i) establish guidelines and criteria for the proper exchange of gifts, hospitality, and other rewards received in the business context by or to the Company's personnel, in compliance with the Transparency and Business Ethics Program and the Company's Code of Ethics and Conduct, and applicable current regulations; ii) protect the Company's reputation and all its employees when involved in a conflict of interest or actual or potential acts of corruption associated with gifts and hospitality; iii) strengthen the corporate culture based on the value of integrity and the principle of transparency established in the Company's compliance policies.

Donations, Contributions, and Sponsorships Policy

Canacol´s corporate social responsibility extends to all situations where it can generate a positive social impact. Thus, the Company's social and environmental commitment is present in its corporate purpose development. This is concretely developed through social action activities, including donations to charitable and non-profit organizations and other community benefits.

In this sense, all donations, contributions, and sponsorships aim to collaborate with non-profit organizations and/or communities in areas of influence. Likewise, they can support human development, sustainable growth, environmental, and humanitarian response causes.

Additionally, Canacol Energy may make donations and contributions to political movements and parties, such as candidacies and electoral campaigns. For these purposes, the donation or contribution must be previously authorized by senior management and carried out following applicable laws and regulations.

Policy Against Restrictive Practices of Free Competition

Canacol rejects any practice that may undermine or limit free competition. Therefore, the Policy Against Restrictive Practices of Free Competition seeks to define the Company's guidelines and expectations in its relationships with third parties. The Policy also aims to prevent Company employees from engaging in any act that may affect free competition.

Conflict of Interest Policy

The Conflict of Interest Policy establishes the obligations of Company employees when faced with a situation that represents or may represent a conflict of interest. This policy defines: i) situations in which an employee may find themselves in a conflict of interest; ii) ways to declare a conflict of interest; iii) the procedure for declaring a conflict of interest; iv) competent instances for resolving the conflict of interest; v) criteria for determining a conflict of interest; and vi) channels for reporting a conflict of interest.

Risk Detection System

Due Diligence

Due Diligence is a decision-making tool regarding potential third parties with whom the Company interacts. It is a dynamic and continuous process that includes evaluation cycles to constantly improve its relationship standards with third parties, the efficiency of controls, and confirm or adjust counterpart profiles according to risk appetite and the challenges and objectives set.

Through the due diligence process, the company should adequately respond to possible changes in the risk profile as circumstances evolve. For example, changes in the country's regulatory framework, emerging sector risks, new business developments, or entering new jurisdictions, among others.

The Company will take reasonable Due Diligence measures with a risk-based approach and the materiality of the latter. The starting point of the process is document assurance by the responsible area or where the need arises, which consists of reviewing and analyzing the information and documentary support provided by the counterpart to start the engagement process with the Company. This will serve to make a decision regarding the relationship.

Whistleblowing Channels

Employees, counterparts, and third parties are required to report immediately if they become aware of (i) a possible act of corruption or transnational bribery within or related to the Company; (ii) any activity or indication of activity that is suspicious and related to the Company; or (iii) any activity or indication of activity that constitutes a violation of current national and international regulations related to the Company.

These reports should be made through the Ethics Hotline “Resguarda.” The means to contact the Company's Ethics Hotline are as follows:

• Toll-free line: 01-800-752-2222 Option 1 operator Option 2 voicemail

• Email: [email protected]

• Website: www.resguarda.com/canacolenergy

• Fax: toll-free number 01-800-752-2222 option 3

Likewise, the Company provides third parties with the Superintendence of Companies' Whistleblowing Channels and the Transparency Secretariat.

Superintendence of Companies' Whistleblowing Channels

In case a Company employee or any third party becomes aware of a possible act of corruption and/or transnational bribery within or related to the Company, they may inform the Company as indicated in the previous section or through the following whistleblowing lines provided by the Superintendence of Companies on its website:

• Corruption Acts Whistleblowing: https://www.supersociedades.gov.co/denuncias-por-corrupcion

• Transnational Bribery Whistleblowing: https://www.supersociedades.gov.co/web/asuntos-economicos-societarios/denuncias-soborno-trasnacional

Transparency Secretariat's Corruption Acts Whistleblowing Line

If a third party is aware of a possible act of corruption committed or involving the Company, they may inform the Transparency Secretariat through the following whistleblowing line:http://www.secretariatransparencia.gov.co/observatorio-anticorrupcion/portal-anticorrupcion

Compliance Culture

In developing the Company's commitment to its Ethics and Compliance programs, a transversal Key Performance Indicator (KPI) has been defined, which is mandatory for all employees, consisting of knowing and applying the organization's Ethics and Compliance policies. To achieve this objective, the Compliance Office periodically conducts training for employees, emphasizing the importance of the compliance and business ethics policies and programs.