Code of Ethics of Grupo de Consultores en Cumplimiento de Delitos Financieros SA de CV ( "FINCCOM”) Applicable to Employees, Candidates, Suppliers, and other Interested Third Parties of FINCCOM

Introduction to FINCCOM

En FINCCOM We change the world and the way to do Compliance, not only through applicable laws, but also with social, moral, ethical, philosophical, human, natural, physical and spiritual duties; but not from those of any society, culture or country, because we understand that we still live in a state of ignorance, it is because we attach ourselves to the common good, of all sentient beings and the care of our planet earth, and more there.

This Code is applicable to all Employees, Candidates, Suppliers, and other Third Parties (collectively referred to as "Concerned parties”) Who have, or plan to have a relationship of any kind with FINCCOM, with the aim of governing, regulating and seeking a mutual ethical environment.

Engagement FINCCOM

In order to live our principles and values ​​and, therefore, comply with this Code, it is essential that in FINCCOM We are all Stakeholders of high moral quality and that it is natural for us to comply with it, leading by example, in all spheres of our lives.

The mission FINCCOM is to be a reliable partner for our society, clients, suppliers and consulting collaborators to have legal growth and progress. Our fundamental activities are to protect the legal interests for compliance with local and international legal regulations regarding the prevention of financial crimes, as well as any aspect related to unlawful conduct.

We work with companies that seek to optimize their operations and strengthen their internal regulatory framework that allows them to comply with all the legal requirements established by the authority and can grow and generate jobs that help the country's economic growth.

We strive to earn and maintain the trust of the public and to consistently abide by the highest ethical standards. We request all Interested Parties to ensure that their decisions are part of the interests of the greater good and thus, generate an ethical value that transcends.

By acting in a comprehensive and ethical manner, we generate value as a company and maintain trust among ourselves and with other people and partners, investors, customers, suppliers, and everyone with whom we interact through our actions as a team.

Our Code in FINCCOM

This code is adopted to apply in all aspects of FINCCOM and with all Interested Parties. It is not an employment contract and does not imply or generate any employment right or of any specific type, for a specific time.

All Stakeholders must act with integrity, demonstrating our commitment to the highest ethical standards and professional conduct in interaction with other clients, with shareholders and all those related to FINCCOMTo achieve this, it is important to know and understand and act in accordance with the values ​​and principles expressed in this code, applying them to all the acts we do and wherever we operate. When we do business, we must always be in harmony with the codes of our clients, always prioritizing our code, or that with the highest standards.

It is necessary to act with prudence, responsibility and transparency.

We have a responsibility not only to act ethically in a group, but also to expect the same from our collaborators, so it is very important to express concerns and ask questions when they are had.

Each of the Stakeholders has an obligation to immediately report any unacceptable conduct if it believes that its own behavior or that of another employee is contrary to the values ​​and principles described in this code, or feels a legitimate instinct that it is not correct. It is essential that the doubt is immediately exposed either to your direct manager or through the communication mechanisms of the business ethics manager to etica@finccom.com.

Principles that Guide Our Conduct

With our clients

Our Clients and Consumers are the main reason why we exist. Your care is essential to our success. Therefore, the consistency, professionalism, innovation and safety of our consulting services, as well as dissemination products are the main commitment to them.

It must be the commitment of each member and collaborator of FINCCOM provide personalized service to clients at all times and on the different platforms with which they have contact, always maintaining ethics and respect for the culture that has developed to continue positioning the firm as one of the best consultants in legal compliance of financial crimes in the country.

With our members and collaborators

Within FINCCOM The aim is for all collaborators who join the firm through different means, to be respected and to find a free and adequate space for their development, both professionally and personally. Dealing with him is based on the Golden Rule: Respect, Justice, Trust and Affection. Those collaborators who wish to send a suggestion on how to improve the group's values ​​can do so with total openness through the media of their choice.

Equality and Respect for individuality

There are no differences or special treatment for political, economic and social ideas, everyone has the opportunity and the right to have their own ideas. Each one has a unique value and the public and private life of each of the collaborators and team members is respected. FINCCOM, as well as the ideas that some of the members want to implement in the firm, always with adequate follow-up in the event that they are favorable for the firm. This last step must be aimed at the direct representatives.

With our internal members

The members who occupy the team FINCCOM are indispensable for the growth of FINCCOM reason why their work is always valued for the growth of the firm, all internal treatment must be carried with respect and focused on creating a healthy and prosperous work environment in which each member has the opportunity to express the ideas that are necessary for the improvement of the growth of the firm.

Respectful workplace

Any form of discrimination, harassment or intimidation that is illegal, or in any other way violates the integrity of a person by a director, a coworker, a client, a supplier or a visitor, or against of any of the Interested Parties.

Discrimination, harassment, whether by race, sex, pregnancy, gender identity or expression, color, height, religion, national origin, nationality, citizenship, age, disability, genetic information, marital status, sexual orientation, culture, is prohibited. , ancestry, war veteran status, performance status or other personal characteristics protected or not protected by law. They are incompatible and totally contradictory to our tradition of offering a respectful and professional workplace.

If you believe that you are being discriminated against or harassed or a complaint is observed or received regarding such conduct, you should immediately inform your manager responsible for work ethics at etica@finccom.com.

Transparency

All processes within FINCCOM are open and transparent, so project managers and representatives must ensure that the team FINCCOM you are confident to ask any questions regarding the practices carried out inside and outside of FINCCOM, as well as periodically report the progress that has been made for internal development.

Development

FINCCOM It is always in search of the professional and personal development of our internal members, ensuring that they are trained and satisfied with their work, seeking in full development and improving skills that allow them to obtain better professional levels within FINCCOM.

The internal member, for his part, will attend to the actions implemented so that they are favorable to the firm, taking into account that their growth is related to the growth of the firm.

All development will be hierarchical and downward, taking into account that the main positions will be according to age and to the convenience of the interests of the firm.

With FINCCOM

When there are references of FINCCOM in social networks or in the participation of any public forum, it is important to take into account the behavior that is being reflected, since that determines the image for our reputation.

"We are all ambassadors of our firm"

None of the Interested Parties of FINCCOM can be addressed to FINCCOM to make value judgments in situations that are controversial and may directly affect the reputation of FINCCOM; If for some reason you are invited to participate in a forum, or if you participate in some media, political and opinion comments that involve value judgments are strictly prohibited.

If any of the Interested Parties of FINCCOM you want to participate in political or opinion comments that involve value judgments, you must communicate your intervention to etica@finccom.com, so that your relationship with FINCCOM.

Responsibility of Our Directors

Directors and Supervisors should openly discuss the requirements of our code with their team members to ensure they understand and follow the standards set forth in the code. This is why you should be aware of the importance of ethics and compliance to make sure members know you and be available to give advice and answer a concern.

When evaluating work performance, one should always consider a behavior related to internal values ​​and be transparent in each of the actions. Always be alert in situations or actions that may constitute a violation of the letter and spirit of this code, policies and our processes.

Violations of the Code of Ethics

Observance of this code is strictly mandatory for all Employees, Candidates, Suppliers, and other Interested Third Parties of FINCCOM. The Heads of FINCCOM, at any level, will be an irreproachable example of its compliance, of constantly disseminating it and of taking the corresponding disciplinary measures when any of its Members and Collaborators fails to comply.

Any member and collaborator who conducts business practices in terms other than those established in this Code will be subject to disciplinary measures that may go as far as the termination of the employment relationship and / or legal action.

We are responsible for reporting

You are responsible for understanding and complying with the code and all laws, regulations and policies and procedures that exist within the company, this also means that you are responsible for seeking advice when needed. If you have any questions or concerns about how the code or policies are applied, please discuss them with your principal or with the person responsible for work ethics.

If there appears to be a discrepancy between the provisions of the code and local regulations, any specific questions regarding the interpretation of applicable laws, you should contact your ethics officer. It is as a general rule that when there is a difference between internal policies and policies where your action as a consultant is being applied, it is important that you contact the person responsible for ethics.

You are responsible for familiarizing yourself with and complying with these policies and with any supplemental procedures policy to which you are subject. FINCCOM. The use of criteria and common sense appropriately in all our actions and the consideration of all aspects of possible impact that the operations, activities and practices that we have with our clients may have, are the key to our franchise and reputation as a legal entity. .

Doing the right thing is a fundamental element for the identity and reputation of FINCCOMWe are responsible for raising concerns about potential reputational issues and systematic risks.

What should you do if you suspect that, even if you are not sure, someone has violated our code?

Sharing your concerns with a board member is very important, if there is doubt in the code or there is something in the code that you are not sure that this misconduct occurred, it is important to report this and in fact is what the code requires. Failure to report a violation can harm our reputation and put customers and coworkers at risk. FINCCOM.

Contact: etica@finccom.com

Conflict of interests

We have to put the interests of FINCCOM long-term, short-term earnings and in addition to the best care for our partners.

We as employees, representatives or Stakeholders of the firm, are expected to act in accordance with the standards of personal and professional integrity and to comply with all applicable laws and regulations in the policies and procedures. This quintessential reputation is a key competitive advantage and we must never put at risk FINCCOM with scenarios that conflict of interest may arise.

Acceptance of gifts or general recreational activities

The Interested Parties of FINCCOM DO NOT They can accept directly, or indirectly, or give: gifts, gifts, favors, promises, or anything of value.

All gifts, business hospitality and other gifts must have the prior approval of the head of ethics (etica@finccom.com).

Political contributions and activities

Making personal political contributions must have prior approval, you must consult in advance with the ethics manager, as well as its direct manager to know the implications of these being carried out and that they do not interfere with the needs and interests of FINCCOM.

It is prohibited to be part of a political organization without prior notice and acceptance by FINCCOM.

Charitable contributions

The work of FINCCOM it must be free from outside influences therefore employees' individual relationships with charitable organizations must be entirely voluntary, having no impact on employment in compensation decisions with all policies. To authorize charitable event contributions, FINCCOM You should review such requests so that you do not have the appearance of a conflict or misconduct and comply with the authorization requirements contained in this code.

External business activities

All Interested Parties must report the following actions and activities:

  1. Receive the necessary prior authorization to participate as a director or be a member of a company committee with or without profit ends.
  2. Hold the position of director or be a member of the Committee of for-profit companies.
  3. Hold the position of director or be a member of the Profit Committee that represents a potential conflict of interest in a financing investment committee.
  4. Compete for a government position or accept a government entity appointment by any other affiliation or government entity.
  5. Any other external commercial activity including non-profit activities or in which there is or may be a real or potential conflict of interest.

Employment of family and friends

It is important to be careful when you want to employ immediate family and friends or other relatives of employees, either full or part time, or temporary employment, as they can create real or apparent conflicts of interest.

The employment of individuals who are related or related to a member of FINCCOM It is subject to additional restrictions that is why when hiring someone cannot be direct when employing the requested position, an external internal member will be in charge of the selection process to avoid conflicts of interest.

Language

The language, in all its manifestations, verbal, written, corporal, must be aligned at all times to this Code of Ethics, and the Values ​​of FINCCOM. Anyone who violates this principle in their treatment or language will be separated from their relationship with FINCCOM.

Our Values ​​in FINCCOM

Integrity

We are upright in our actions, we do the right thing and doing the right thing will be considered good for everyone because we also do not affect the interests of other subjects. The word "integrity" implies righteousness, goodness, honesty, faultlessness; someone you can trust; no strange mix; what he says means that: what he said; when you make a promise you intend to keep it.

Responsibility

We are people of our word who have the trust and credibility of others because our words and our actions are our best personal brand. For us, a promise has great value.

Reliability

It is our "capacity for efficient and effective performance of people in all processes, without making mistakes derived from acting and individual knowledge, during their job competition, in a specific organizational environment." We optimize our knowledge, abilities, skills and attitudes.

Respect

We know and recognize that each person will have a box of life experiences different from ours. Our comments and positions do not express reality for all listeners, but are the manifestation in which each of us interprets and manifests reality according to his own worldview. Understanding this principle makes us tolerant and understand that each argument is the expression of the one that uses the linguistic resource of speech in any of its manifestations: written, oral, non-verbal.

Tolerance

Tolerance is the annihilation of the false belief of the self, of the ego, which seeks the supremacy of identity and opinion. We understand that each word emitted is the manifestation of the experiences of the one who emits them and we seek in compassion to understand his position.

No retaliation

FINCCOM, nor will any of its Interested Parties exercise in any way, tangible and intangible, any retaliation against any person who reports in good faith any situation contrary to this Code.

Ethical Contact

If you, as an Interested Party of FINCCOM, considers that, in its process of selection, recruitment, interview, negotiation, contact, or any other action of any kind with FINCCOM, a fault or violation of this Code has been incurred, please report it to the following email.

etica@finccom.com