Code of Conduct and Business Ethics

1. Objective Implement standards of conduct for all personnel and third parties that responsibly permeate all stakeholders defined by the impact and influence generated by the development of our activities.

It is important to mention that the language used in this document does not seek to create any distinction or mark any difference between men and women; therefore, references or allusions derived from the wording towards a gender in all cases represent both sexes.

2. Scope This Code is generally applicable to all company personnel or third parties, applying to all our actions, labor and commercial relationships with clients, colleagues, competitors, suppliers, personnel, third parties, and other stakeholders, in order to maintain high ethical standards, acting fairly and honestly.

3. Definitions

No.	Concept	Definition
1	Activities	Execution of professional, commercial, administrative, and daily tasks.
2	Conflict of Interests	Any situation in which a person is involved in two or more activities or relationships that may create interests or responsibilities that may not be compatible. These situations include activities, conduct, or investments that may conflict with their duty in the company or adversely affect their judgment or work performance.
3	Members	Partners, shareholders, and directors who are part of the company.
4	Compliance Officer	The person responsible for monitoring the proper implementation and functioning of the applicable normative and legal framework documentation of the organization, as well as managing the complaint channel regarding conduct, activities, or behaviors carried out by personnel, suppliers, shareholders that cause them to incur an infraction.
5	Stakeholders	Any person, group, or organization that may legitimately be impacted by our decision-making and activities and has the right to express their opinion and be attended to in their demands.
6	Personnel	All employees who provide subordinate services to the company.
7	Third Parties	All executives, external advisory personnel, audit personnel, or personnel hired on a fee basis, suppliers, and any natural or legal person providing any service to the company.

4. Confidentiality Period Personnel and third parties providing services to any affiliated companies, subsidiaries, business partners, and any other entity forming part of the company are obliged to keep, maintain, and preserve as confidential information, including but not limited to, information, software, hardware, network systems, documents, intellectual property, tangible and intangible assets owned by the company, maintaining complete confidentiality and not disclosing, publishing to any third party, in whole or in part, nor using for personal benefit or for any use other than related to the performance of their duties the confidential information described above to which they have or will have access during their time working at the company, while there is a labor relationship and for a period of five (5) years from the termination of said labor relationship.

5. Responsibility and Authority All stakeholders mentioned in the scope of this Code are responsible for strictly adhering to this document, applicable laws, norms, rules, and regulations, and the company’s policies and procedures, having the duty to report improper conduct by others through appropriate channels and to collaborate to prevent and correct these issues.

Senior Management, in coordination with leaders and the Human Resources department, is responsible for ensuring that personnel know that the company’s basic principle is to conduct business with the highest level of integrity, honesty, and ethical standards.

In this way, the company aligns compliance actions within its internal sphere but also manages its responsibility in repairing damages that may be generated by the development of our activities.

6. Description of Guidelines

6.1 General Guidelines

6.1.1 Conflict of Interests Personnel must not prioritize their personal, financial, or any other interests to the detriment of the legitimate interests of the company. We cannot allow our personal interests to conflict or appear to conflict with those of the company.

The presence of a conflict of interests can damage the trust and security on which the company’s reputation is based, so it must be avoided. We must conduct our private affairs and personal activities in such a way that they do not cause any conflict, nor appear to do so, with or within the company and its clients or suppliers. If you believe you have a real or potential conflict of interests, consult the Compliance Officer or the Integrity Committee.

6.1.2 External Activities Directly Linked to the Right to Personal Growth and Legitimate Advancement in Received Perceptions Non-competition – No employee may be employed or participate in any company that competes with the company or operates in the industrial or commercial sectors where it operates.

Personnel also cannot accept temporary employment, such as advisor, contractor, or any other remunerated form where their performance and compliance affect or could affect their ability to attend to and fulfill their responsibilities within the company.

Personnel must not engage in external activities, accept extra work, or provide external services in exchange for remuneration, including fees received for consulting, speaking, or authoring, if the activity can generate criticism towards the company or be unfavorable for themselves, if it constitutes a real or apparent conflict of interests, if it takes time away from work, if it interferes with their responsibilities, or if it requires so much time that it can affect their physical or mental efficiency as a member or employee of the company. If they wish to engage in such activities, they must report it through the AX-GCH-01 Conduct and Conflict of Interests Questionnaire, prior to acting in said activity, for analysis and approval if deemed appropriate.

6.1.3 Interests in Other Businesses and Conflicts Personnel cannot operate or be shareholders in businesses that have a direct relationship with the company; they must not do business with third parties that are direct or indirect competitors of the company, nor act when the action is malicious, in bad faith, illegal, or take advantage for themselves, directly or indirectly, or for any third party of a business opportunity of a similar nature to that of the company, which is carried out to its detriment and uses its resources.

Personnel must not participate in a business transaction for their personal benefit, giving or using the company’s name with a client, supplier, or consultant.

A conflict of interest may exist when the client, supplier, or consultant is an organization in which the personnel or any of their family members are principal officers or have significant financial interests. If a company transaction involves people or organizations with whom you or an immediate family member have a significant connection or financial interests, you must inform the Legal Department or the Human Resources Department and withdraw from the transaction. This restriction applies to both commercial and non-profit organizations.

6.1.4 Gifts and Advantages Personnel belonging to the company or in conjunction with any third party must not accept from clients, suppliers, competitors, or external auditors any gifts, invitations, trips, or enjoy benefits, services, or any special consideration. Additionally, they must strictly adhere to guideline 6.1.6 of this Code.

Personnel who receive unauthorized gifts, services, trips, benefits in personal supplies of any kind according to this Code must inform the email [email protected] and/or the Integrity Committee for registration and, if applicable, authorization to keep or grant such gift or benefit, by notifying the email [email protected] including the date received or requested to grant hospitality, gift, or donation, description and value, as well as the reason.

Gifts related to travel, meals, events, entertainment, memberships, sponsorships, donations, hospitality, and shows will only be allowed when there is a justification for business reasons and must be notified and authorized by the Integrity Committee according to the parameters established in this section. For the Integrity Committee to grant authorization, the Committee must analyze the following factors: a maximum value, the frequency of those gifts, the time received (e.g., not during or immediately after a negotiation), reasonableness (considering location, sector, and seniority of the donor or person giving the gift), the identity of the recipient, and the legal and regulatory environment.

Regarding donations and promotional expenses that may be granted or received, they must be authorized by the Integrity Committee via email and must observe the following guidelines: prohibit payments intended to influence or that may be considered to influence or generate influence, conduct due diligence on the natural or legal person receiving or making the delivery or promotional expenses, ensure that the payment or donation is permitted by applicable legislation, and avoid making any other before, during, or after the negotiation of a contract or participating in a tender.

Personnel of the company will not be allowed to receive any type of gift that exceeds a maximum value of $1,000.00 MXN (One thousand pesos 00/100 National Currency), and if received, it must be notified to the Integrity Committee at the email [email protected] for registration and analysis to take the corresponding action on the received gift.

6.1.5 Representation Expenses A. Proposed guidelines for meetings generating representation expenses:

• The number of people attending meetings with clients should not exceed three.
• For meetings with more than three people, express authorization must be requested from the Director of the business unit to which the personnel belong, justifying the attendance of the participants.
• The reason for the meeting must be justified in writing and authorized by the Business Unit Director.

B. Proposed guidelines for controlling representation expenses:

• Standardize the credit limit of credit cards by hierarchical level.
• The maximum amount for representation expenses will be the credit limit established on the assigned corporate credit card.
• Expenses for gifts/customer attention should not exceed $2,000.00 MXN (Two thousand pesos 00/100 National Currency) per event (including shipping and wrapping costs) and a maximum of one event per month.
• If the amount exceeds the established limit in this Code, express authorization from the Integrity Committee must be obtained.

C. Proposed guidelines for expense control:

• Attach to the reimbursement request the receipt detailing the consumption and the number of attendees (to validate consumption and the number of attendees). In case of expenses for alcoholic beverages, validation from the Business Unit Director is required.
• Permitted gifts include: books, floral arrangements, pens, keychains, events, and entertainment, among others; provided prior authorization from the Integrity Committee is obtained.

6.1.6 Handling Potential Conflicts of Interest It is the obligation of every Member and/or Personnel involved or potentially involved in a conflict of interest to complete the AX-GCH-01 Conduct and Conflict of Interest Questionnaire, providing an accurate and timely report of the facts and circumstances related to the conflict of interest, and present it to the Human Resources Department and/or, if necessary, to the Integrity Committee for review and approval.

6.1.7 Anti-Corruption Observe fair and transparent business practices to ensure compliance with applicable laws and regulations and prevent bribery and extortion practices.

In the company’s activities, no one should participate, order, authorize, promise, conspire, induce, or assist someone in corruption practices, either directly or through a third party. Nor should they give, accept, or commit gifts, advantageous conditions, salaries, trips, commissions, or any other form of compensation to influence a business decision. Similarly, no one should give or obtain undue advantages or benefits of any kind, nor engage in any other bribery or extortion practice in relationships with clients, suppliers, financial institutions, dealers, contractors, companies, authorities, or government representatives, or any other person or entity with whom we conduct operations.

Below is a table of what is permitted and NOT permitted according to the stipulations in the previous paragraphs:

Permitted	Not Permitted
Pens, calendars, or small promotional items, business meals, occasional invitations to local sports, theater, or other cultural events; all with a value less than or equal to $1,000 MXN.	Gifts, services, trips, or personal supplies exceeding a value of $1,000 MXN.

Additionally, all company personnel are obliged to adhere to PO-GAL-02. Anti-Corruption and Bribery Policy.

7. Information Management Personnel must adhere to the documentation related to information security and personal data managed by the IT department according to AX-GPO-07 Document Preparation.

7.1 Information Requests from Authorities and Third Parties For the purposes of this code, personnel who receive a formal request for information from any authority or official body, consisting of providing information and/or documentation of their own and/or third parties related to the company, must immediately inform the Legal Department, which is the only entity authorized to determine its validity and respond to such request, channeling it to the Integrity Committee.

All requests and/or requirements must comply with the above procedure, so company personnel will undergo interviews, answer questions, present, show, or deliver documents of and about the company. The same treatment must be given to information requests from third parties or their legal representatives.

8. Resource Management Personnel must use the company’s economic and material resources sparingly, efficiently, and productively, avoiding personal benefit or extracting them for profit or purposes unrelated to the company’s final objective.

The use of resources required in our processes must adhere to the environmental sustainability, occupational safety, and health guidelines that the company issues and disseminates continuously within a framework of social responsibility.

8.1 Use of Facilities and Services Economic, material, facilities, services, and assets are available for use in the execution of business and activities or functions performed by personnel.

The Integrity Committee will sanction those who present false or altered expense accounts through AX-GAL-02 Mechanism to Prevent, Address, and Sanction Applicable Illicit Acts of Corruption and Bribery, which is applicable to the company.

8.2 Records Any economic or material resource acquired or made in the company’s name must be recorded in the company’s accounting.

Personnel must always comply with current accounting standards and policies and refrain from making false or misleading entries or authorizing them.

8.3 Expenses Expenses made on behalf of the company must have supporting documentation and be authorized by the persons empowered to do so, who must ensure that these expenditures are necessary and within the parameters established in the policies.

Business or work trips on behalf of the company with clients, suppliers, or industry people with whom there is a relationship must be evaluated by the corresponding management in each particular case and may be carried out when:

• They are positive for maintaining or improving the company’s business relationships.
• They do not create obligations or commitments between the parties.
• They cannot be misinterpreted or provoke criticism from third parties.
• Recreational or leisure trips on behalf of the company are prohibited.

8.4 Protection of Assets Company assets must be used to meet work needs and achieve business objectives. Assets include both tangible items such as furniture, equipment, and supplies, and intangible assets such as intellectual property and public image. Intellectual property may constitute confidential information or trademarks – exclusive property of the company – including business plans, acquisition plans, trade secrets, registered or unregistered trademarks, customer information, supplier information, and other important information.

The work developed by personnel is also a form of intellectual property. Everything they produce or develop in relation to their work and/or service with and for the company is the sole and exclusive property of the latter and is considered “work for hire.” This also applies to work done at home under the telecommuting modality.

If personnel possess confidential information or trademarks or any trade secret related to someone outside the company (such as their previous employer), they must not use this information in relation to their employment and/or service, nor share it with other members and/or personnel of the latter.

Personnel must protect the company’s tangible assets by ensuring they are used carefully, safely, and effectively, and ensuring that the equipment they are responsible for is properly maintained. If they need to take assets, such as laptops, outside the office, they are obliged to take care of them.

Protecting intellectual property by maintaining its confidentiality is the obligation of all personnel; they are prohibited from revealing company information to any person without proper authorization.

8.5 Use of Assets While the company recognizes that, in some cases, personnel may use computers or phones for personal purposes, these assets should primarily be used for business purposes and for the functions for which they were assigned.

Similarly, personal assets that personnel have within the facilities should be used only for personal purposes and should not be used to receive and/or store confidential information or intellectual property.

8.6 Use of Computer Systems, Email, and Internet Personnel must adhere to the documentation related to information security and personal data managed by the IT department.

9. Conduct with Clients In relationships with clients, personnel must always act with objectivity, impartiality, independence, fairness, excellence, and in accordance with the growth and profitability objectives of the company.

9.1 Attitudes and Impact The company is committed to meeting clients’ needs as much as possible through the products and services offered that suit their particular situation and needs.

Personnel, particularly those directly responsible for client service, must maintain a position of respect, quality, efficiency, and courtesy.

9.2 Offering Services and Products Personnel providing information about the company’s products and/or services by any means must ensure that it is truthful, verifiable, and free of elements that could confuse or lead to a misinterpretation of its characteristics. They must avoid:

• Steering clients towards products and/or services they do not need, solely because they are more profitable for the company.
• Omitting detailed descriptions of a product and/or service, including potential risks or inconveniences for the client.
• Making false or misleading comparisons with equivalent products and/or services offered in the market.

9.3 Fair Treatment and Equality by Segments The values that support the company’s market presence are innovation, excellence, and leadership, as well as the treatment and benefits that the company’s products and/or services represent for the client. Therefore, operations that affect this relationship should not be demanded or accepted.

Personnel must be impartial, objective, and fair in their relationships with clients and suppliers, and must refrain from:

• Imposing conditions where the provision of the company’s products and/or services is subject to the client accepting others they may not need or want.
• Seeking reciprocal deals, whereby the company will accept the products and/or services offered by another company only if that company accepts the company’s products and services.
• Using illegal or intimidating means to enforce the agreed conditions in contracts. They must resort to the appropriate judicial authorities to assert the company’s rights, always under the supervision and authorization of the Legal Department.

9.4 Decision Not to Deal with a Client Personnel are not obliged to accept any natural or legal person as a client, even if they meet the established requirements, when illicit activity is suspected or circumstances infer such activity. This situation must be carefully monitored by the Commercial Department and the Legal Department and, if necessary, reported to the corresponding Business Unit Management and the Integrity Committee.

9.5 Means to Obtain Information About Clients It is the obligation of personnel to identify, through legal documentation, the natural and legal persons who will be their clients, as well as verify the accuracy of the information presented before contracting with them.

10. Conduct with Competitors Personnel will maintain a relationship with competitors that fosters loyalty, credibility, and trust, to promote a healthy competitive environment.

10.1 Comments About Competitors The company maintains a policy of mutual respect with its competitors, so personnel must avoid making adverse comments or statements about them to the general public, especially to clients, and must be objective, truthful, and complete if necessary. Specifically, they must:

• Base the promotion of the company’s services on their qualities and the benefits they can provide to the client.
• Not comment on the reputation or business practices of competitors, nor refer to their problems or weaknesses.
• Ensure statements about the characteristics, added value, or cost-benefit of a competitor’s services are impartial, truthful, and verifiable.

10.2 Business, Professional Exchanges, and Forums Personnel participate in them when their functions are useful, legitimate, and facilitate the exchange of information on matters of common interest, such as the development of new products and/or services, the use of technology, or relationships with official bodies or authorities.

Personnel must not use forums, events, and organizations, nor accept their use to establish agreements with competitors on the prices of the services they offer.

11. Conduct with Suppliers The relationships that members and personnel maintain with suppliers must be based on selection criteria according to the company’s policies in this area; with formally established professionals, addressing their needs, and conducted with independence and integrity in all operations carried out.

11.1 Supplier Selection Personnel involved in the selection of suppliers must be impartial and conduct the three evaluations indicated by PO-ADQ-02 Supplier Management Policy (Legal and Financial Evaluation, Commercial Evaluation, and Technical Evaluation), always complying with the determined procedures.

11.2 Agreements on Suppliers Personnel must not participate in any agreement with competitors that aims to limit or prevent dealings with any supplier.

12. Conduct with Authorities Personnel representing the company in any way before Federal, State, or Local Authorities must demonstrate that activities are carried out in strict compliance with applicable legal provisions and the company’s internal policies, refraining from participating in illicit acts.

12.1 Attitudes and Impact Personnel who have relationships with officials of regulatory entities or government bodies must offer them friendly and respectful treatment, recognizing their authority, to facilitate the handling of matters and the establishment of agreements.

Authorities’ requirements and observations must be satisfactorily addressed, with the aim of collaborating effectively and courteously in fulfilling their mission, as long as their requests remain within the powers granted by law and do not undermine the company’s interests, in which case the corresponding legal means will be asserted.

Personnel in their relationships with authorities must refrain from offering benefits of any nature that compromise or appear to compromise their independence and objectivity. If representatives of the authorities request any benefit, the matter must be reported to the Integrity Committee.

Similarly, personnel must refrain from publicly expressing their opinions on the conduct or attitudes of public officials.

12.2 Defense of the Company’s Interests According to Law Personnel must ensure and monitor that legal provisions in the matter are invariably complied with. However, it is possible that in certain circumstances differences may arise, whether in criteria or interpretation, with authorities regarding the application of a norm. In such cases, the position assumed before the authority must be substantiated and motivated, and if necessary, asserted before the appropriate legal instances.

13. Conduct in Interpersonal Relationships The relationship among personnel must be based on due and mutual respect to ensure a harmonious environment conducive to productive work. Personnel must show institutional loyalty, respect for established guidelines and directives, and be equitable in their internal relationships at all times. The parameter for conduct and daily work is the achievement of established objectives and goals, avoiding creating situations of abuse in the work relationship.

The company cares about its personnel, committing to help reconcile work and family life, equal opportunities, combating workplace violence, discrimination, child labor, and sexual harassment, strictly prohibiting any personnel from engaging in practices of mobbing, sexual harassment, harassment, any type of discrimination, child labor, workplace violence, and any type of mistreatment against any other personnel, whether subordinates or hierarchical superiors or third parties.

The company contributes to the well-being of personnel, always respecting their ethnic or national origin, gender, age, disability, social status, health, religion, opinion, sexual preferences, marital status, or any other criterion that may give rise to a discriminatory act, being inclusive.

We must all do our best to avoid discrimination, harassment, and retaliation in the workplace. Personnel must immediately report all instances of discrimination, harassment, or retaliation to the Integrity Committee according to the respective guidelines.

13.1 Integrity Personnel must precisely and uprightly fulfill the duties of their position and function, as well as be consistent with the provisions established in this Code.

13.2 Conduct with Colleagues The treatment among personnel must be respectful and tolerant. Work relationships should be based on collaboration and mutual support.

13.3 Conduct with Subordinates It constitutes an abuse of authority when a hierarchical superior grants unjustified promotions and raises, and generally gives special advantages to certain individuals, teams, or groups in exchange for any type of favor (sexual, sympathy, money, acceptance by a certain group). Similarly, if their conduct intimidates and coerces subordinates, and/or takes reprisals when they do not achieve their goal. The Integrity Committee will directly address such situations.

Leaders must provide personnel, to the extent possible, with the necessary elements and resources to perform the assigned work; evaluate their performance objectively; promptly recognize those who deserve it and, when appropriate, grant them the benefits and entitlements they are due without any conditions.

14. Conduct of Personnel in Extra-Work Activities The conduct of personnel in approved extra-work activities must not undermine their prestige and image. Personnel may engage in extra-work activities, considering the following indications:

• The time and effort dedicated to these extra-work activities must not affect the performance of their duties and certainly not be at the expense of the company.
• These activities must be conducted within the legality provided by our legislation.
• These activities must not be carried out with the purpose contrary to the guidelines established in this Code.

14.1 Political Conduct Personnel may participate, in a personal capacity, in political activities of their preference. In this regard, they must clearly and expressly state that they act independently and not on behalf of the company.

14.2 Academic Conduct No personnel, in the development of academic activities, should refer to experiences, matters, or specific operations in which they were involved or had knowledge of the company, and should not promote or intervene in topics or case studies.

15. Conduct of Due Compliance Personnel must act with integrity, honesty, and adherence to the principles and provisions contained in this Code, committed to safeguarding the company’s assets, and assuming responsibility for their functions at all times.

It is the obligation of company personnel to provide dignified and cordial treatment, avoiding at all times distinction, exclusion, restriction, or preference among people, motivated by ethnic or national origin, skin color, culture, sex, gender, age, disabilities, social, economic, health, or legal status, religion, physical appearance, genetic characteristics, migratory status, pregnancy, language, opinions, sexual preferences, political identity or affiliation, marital status, family situation, family responsibilities, language, criminal background, or any other reason that undermines human dignity and aims to nullify or undermine people’s rights and freedoms; additionally, it is the obligation of all personnel to avoid any type of conduct or act of discrimination, labor inequality, workplace violence, sexual harassment, harassment, sexual harassment, workplace harassment, etc., while performing their contracted duties.

15.1 Management of Company Resources All resources managed by the company are its property; therefore, integrity in their management is imperative. This quality must be the main characteristic of all personnel and members, and any act or behavior that undermines it constitutes a direct attack on them and their members, as it damages the trust of our clients.

Personnel who have direct or indirect knowledge of an act that may constitute or signify harm to the company must report it to the Integrity Committee. Remaining silent implies an act of concealment and, therefore, complicity.

All information provided in good faith will be kept confidential; however, information that maliciously slanders will be sanctioned by the Integrity Committee according to AX-GAL-02 Mechanism to Prevent, Address, and Sanction Applicable Illicit Acts of Corruption and Bribery, which is applicable to the company.

15.2 Fraud and Illicit Acts Any fraud or illicit act in which personnel working for the company participate, in collusion with third parties or on their own, must be subjected to the corresponding legal process as soon as sufficient knowledge or presumption is obtained, and collaboration with the judicial authority must be expedited to facilitate the correct application of the law.

All personnel, within the scope of their functions and attributions, must seek to reverse the damage caused.

15.3 Use of Alcohol and Drugs The possession, consumption, and sale of alcohol and illegal drugs are prohibited in the workplace or while participating in any work-related activity inside or outside the work facilities. Personnel must not work under the influence of alcohol and illegal drugs, nor any substance that prevents them from performing their duties safely and effectively.

The use of alcohol within the work facilities will be limited exclusively to occasions when the Human Resources department conducts events in accordance with company celebrations. At no time within the company’s facilities may personnel and third parties to whom this code applies consume alcoholic beverages, except in cases expressly established in this policy.

15.4 Administrative Offenses It is the company’s responsibility to maintain training programs and updates on policies and control procedures, design and dissemination of security measures, and it is the responsibility of members and personnel to comply with such programs and guidelines.

Personnel who, due to ignorance, distraction, negligence, or poor performance of their duties, commit irregularities that cause damage to the company’s assets will be subject to corresponding administrative or criminal sanctions, as none of the mentioned causes exempt them from responsibility for the damage caused.

Contact Information

We want to hear from you!

The company’s continued success depends on all of us adhering to the principles of this Code of Conduct and Business Ethics.

If you notice someone behaving in a way that conflicts with this policy, inform your leader immediately. If you cannot or do not want to approach your leader, contact the email [email protected] where the case will be handled confidentially and any type of incident (question, complaint, report, proposal, opinion, suggestion) will be followed up through a structure governed by the Integrity Committee to encourage the use of protection mechanisms and build trust, promoting communication within the company.