Marcelo Sanchez

Ethics code

Ethics code

Reach

The Ethics Code of bia is of general scope and includes the members of the Board of Directors, President, Vice-Presidents, Directors, Managers and each and every one of the collaborators of the group, which is formed by all business units: apex, cbc, bia and beliv, including its subsidiaries and related companies.

All of us who are part of bia accept the personal responsibility of complying with the Ethics Code with the following:

Perform our work with honesty, care, diligence, professionalism, impartiality and integrity.

Implement the strictest ethical standards to maintain certainty and trust in our management. To read and understand the Ethics Code and the consequences that result from its breach.

Corporate Values

All bia collaborators share and live the following values:

- I am owner
- I dream big
- I am passionate about what I do
- I live with integrity
- I am excellent
- I am disciplined

All our business and professional activities are based on integrity. We act with honesty and transparency.

Likewise, we maintain respectful and harmonious relationships with open and honest communication. We work as a team. We are always in search of excellence. All this translates in the development of the company and in opportunities of personal and professional growth for each one of the members of bia.

LOYALTY TO OUR PRODUCTS

Loyalty to our company is a very important value at bia. All bia collaborators must reflect loyalty at all times, both inside and outside the company. We are all ambassadors and representatives of all the brands in the portfolios of all our companies. This is why we prefer our products over others.

Our collaborators understand the quality of the products that we offer and that this is why we freely chose to consume our own brands and we avoid purchasing products of other companies that compete with our products and we definitely do not consume similar products from our competitors.

In case of social events outside the company to which we are invited, we will offer prudently our brands when possible. Of course, we will not behave improperly for any reason.

RESPONSABILITIES

The Code specifies how each one of us who are part of bia must conduct our performances and our relations with our colleagues, suppliers, clients and the communities in which we operate. No collaborator of the company has the authority to request or perform any action that violates this Code. The Code is not subject to any type of waiver or exceptions by any collaborator. The Compliance Department, together with the People and Management Department, are responsible of promoting the knowledge and broadcasting of this Code. The Compliance Department is responsible of answering questions related to its interpretation. Any collaborator that deliberately breaks this Code or who allows or authorizes a subordinate to break it will be subject to disciplinary sanctions, up to and including dismissal.

1.- ETHICAL RULER

1.1 – Integrity and rules of conduct
All our business and professional activities are based on integrity. We act with honesty and transparency.

1.2 – Inclusion and no discrimination
We develop, without exceptions, business practices that are inclusive and free of all discrimination. We recognize in diversity a wealth that promotes innovation and allows better understanding of the cultures in which we work. We encourage the free exchange of ideas because we recognize the force of dialogue to build a culture of excellence and to achieve a shared vision and mission.

1.3 – Equal employment opportunities
Our personnel selection practices are based on equal opportunities. Our collaborators develop their career plans based on meritocracy and objective evaluations. We implement training programs to transmit new knowledge that allows the collaborators to improve their opportunities of professional growth.

We compensate our collaborators according to their development and through compliance with objective policies.

1.4 – We report harassment
We repudiate and denounce any practice of harassment or abuse, particularly sexual and labor harassment.

1.4.1 – Labor harassment
Labor harassment is the repeated occurrence of hostile behavior or attitudes that threaten the dignity of a collaborator. This behavior may come from a person that has supervision responsibilities or from a colleague.

1.4.2 – Sexual harassment
Sexual harassment refers to sexual advances not welcome or accepted by the recipient, with the threat to harm his or her employment status or modify its employment opportunities, regardless of whether it is a relationship of supervisor and supervised, or among collaborators.

2.- COMPLIANCE WITH LAWS AND REGULATIONS

2.1 – Respect for the Law
Our business and professional activities will be developed with strict adherence to laws and regulations in force in each of the countries in which we operate.

2.2 – Anti-Corruption Policy
We ban and denounce bribes and any other form of corruption to the authorities and public workers. It is forbidden for our collaborators to offer or grant intentionally, directly or indirectly, to a public official or employee, a promise or advantage for themselves or other people in exchange that the public official or employee perform or omit any act in the exercise of his public functions. It is prohibited to receive from third parties undue payments of any type, gifts or favors that, because of their value, characteristics or circumstances pretend to alter the development of commercial, administrative or professional relations.

We all must read and accept the Anti-Corruption Policy, with is an essential part of the Anti-Bribery Management System – ABMS. The main objective of ABSM is to identify, control, monitor, detect and investigate corruption situations that may happen in the company. ABMS is mandatory for all the collaborators and we are all responsible for its effectiveness and operation, mainly denouncing any corruption act.

2.3 – Respect for human and labor rights
All our actions are carried out with the strictest respect to the Human Rights of the Universal Declaration of Human Rights.

We believe that liberty, justice and world peace are based in recognizing the dignity of people and the equal and inalienable rights of all members of the human family. We respect the current labor legislation in each country in which we operate and we work within the framework of what the different agreements established by the International Labor Organization.

2.4 – Prohibition of child labor
Child labor is work done by a child who has not reached the minimum age established by the local laws. Child labor prevents the fullest education and development of children. We prohibit the hiring of people under the age of 18 (or the local minimum age) and we demand from our collaborators and suppliers the strictest adherence to this principle.

2.5 – Prohibition of forced and obligatory labor
Forced labor refers to work that is done involuntarily and under threat of penalties. It refers to bonded labor, modern slavery or any form of human trafficking. We repudiate forced labor. We demand from our collaborators and suppliers the strictest observance of this principle. The use of physical punishment, threats of violence, intimidation and other forms of physical, sexual, psychological abuse will not be tolerated as a method of discipline or control in the workplace.

2.6 – Health and safety at the workplaceo
Proveemos de ambientes laborales seguros y de acuerdo a lo que establecen las leyes y normas aplicables. Los colaboradores tienen la obligación de respetar las normas de seguridad e higiene y de utilizar los equipos de seguridad que correspondan.

All of us at bia consider safety a priority. In each of the functions that we perform, safety and accident prevention always prevails.


3.- RELATION WITH THE PUBLIC

3.1 – External communications

All media contact is done through properly authorized personnel. It is fundamental to maintain a transparent and respectful relationship with the media to guarantee the projection of a company image in accordance with our values. Collaborators contacted by any media should transfer the contact data to the Corporate Affairs Department.

3.2 – Social media and instant messaging communication
We encourage and value diversity and exchange of ideas in a respectful and appropriate way. The publication of confidential or inappropriate information through social media or instant messaging can harm our company, the corporation, our brands and our colleagues.

Remember that anything that you publish in social media can affect your image and the image of the company. Use your good judgement before issuing any opinion, comment or judgement to be consistent and aligned with the values and professional standards of our company. To guarantee the adequate use of social media and instant messaging, you must comply with the following:
Do not disclose or share without authorization any image, video or internal information of the company or corporation that have not been disclosed in our own official channels, including pictures, videos, internal documents, trainings, internal meetings, financial information, processes information, strategic planning, projects, goals, commercial projections, client information, etc.

All your opinions must be strictly personal. Do not express opinions implying that it is the official position of the company.

Do not make judgments or opinions that are discriminatory or may result in insults, defamation and slander against any person, product, client, supplier, employee, former employee, competitor or any other part related to the company.

Do not share with people outside the corporate group any mail that you receive in your company e-mail and that contains information for internal use.

Your communication must always reflect respect to people, family, community, the environment and must be based on human values and corporate values.

3.3 – Fair competition
We do not practice unfair competition nor de we encourage any action that involves unfair competition practices. We are committed to observe the compliance of laws and rules of free competition. If by any reason it is necessary to comment on the product and services of our competition, our comments will always be based on objective information and will be communicated by the persons authorized to do so.

3.4 – Relations with our clients and consumers
The relations with our clients are based on equality, trust and mutual knowledge. We are committed with the quality of our products and services. We develop relations that generate shared value, especially with micro, small and medium entrepreneurs. We maintain responsible communication with our consumers so that they may exercise their right to make informed elections.

3.5 – Relations with our suppliers
The company must insure and demand from all its suppliers, including potential ones, to maintain the confidentiality of sensitive and confidential information of the company. When selecting suppliers, the company must guarantee a transparent process, giving the same information to all suppliers and to maintain uniform and clear rules for everyone.

We seek to foster lasting relationships with our suppliers. Our relationships are based on fair and honest treatment. The suppliers must know and adhere to the principles of this Code and to apply them in the context of their own business culture.

4.- CORPORATE SOCIAL RESPONSABILITY

4.1 – Relations with the community
We are committed to act in a socially responsible manner, in all that we do. We respect cultural diversity, and the customs and principles of the communities in which we operate. Likewise, we seek to develop activities that favor economic and social development of our communities.

4.2 – Environment
We are committed to sustainable development. For this reason, the protection of the environment constitutes a comprehensive part of each and all of our processes. We promote the quality of environ- mental management by promoting economic growth and competitiveness in a regional and national scale, incorporating best international practices to prevent and minimize environmental impact in our operations.

We stay focused on the efficient use, reuse and recycling of all of our resources.

We believe in an economic and social development that satisfies the actual needs of people without compromising the capacity of future generations to satisfy their own needs. We establish alliances with the communities and local governments to promote an adequate environmen- tal management.

5. INFORMATION CONFIDENTIALITY AND ASSENTS PROTECTION 

5.1 – Confidentiality of personal information
We are committed to request and use exclusively the data of our collaborators that are strictly necessary for the effective management of business activities, and always according to what it is established by law. The collaborators who, because of their activities have access to the information of other collaborators, must respect and promote confidentiality of this information and will use it responsibly and professionally.

5.2 – Asset protection
We always aim to protect bia assets. This includes its tangible and intangible assets such as rights, brands and information. We maintain the confiden- tiality of the information to which we have access, even if we are not part of a particular company. We are responsible of protecting the assets entrusted to us, preserving them from any loss, damage, theft or illegal use. We use these assets exclusively for appropriate, professional functions and not for personal or third-party use.

The bad use or non-authorized disposition of the assets of the company which results in a loss or contingency for the company, represents a viola- tion to our Code and will be subject to disciplinary measures according to the laws and regulations as well as the labor regulations of each country. The following are considered assets of the compa- ny, but are not limited to these examples: tangibles: inventory, fixed assets, buildings; intangibles: patents, brands, registers, formulas, systems, permits, data bases, commercial plans, corporate information and others.

5.3 – Use and management of financial and non-financial information
The financial information and the results of its oper- ation have to be registered according to the legal requirements and generally accepted accounting principles. Any person with the responsibility to elaborate, process and register this information is responsible of its veracity, integrity, accuracy and precision.

All the reports of all areas of the company have to perform with this same veracity, accuracy and precision. This includes, among other things, the following: quality, commercial, expenses, opera- tions results, development evaluations and excel- lence programs.

The manipulation and alteration of accounting reports and financial statements or any other regis- ter or report is considered a serious misconduct.

All employees are obliged to protect all that information of the company that is not public and are obliged to not reveal it to any person outside the company. This includes financial information, commercial information, patents, marketing plans, etc. Only the Corporate Affairs Area may publicly disclose any private company information.

6.- GIFTS, INVITATIONS AND GRATIFICATIONS

We do not accept gifts, invitations, gratifications, hospitalities or attentions from current or potential customers, suppliers or public workers that may compromise our decision making capacity. Gifts and attentions are considered not only tangible gifts with commercial value but also invitations to restau- rants, trips, concert tickets, seminars, congresses, fairs and other similar activities. If you have any doubt about how to proceed in any of these cases, you may ask the Compliance Area through the Compliance Portal available in: www.portaldecomplianceglobal.com

The invitations from suppliers to seminars, industrial fairs and technical meetings must be authorized by the Director or VP of the corresponding depart- ment, taking into account the aggregated value this knowledge and activities may generate to incorpo- rate new processes and technologies in their respective area and when this invitation does not compromise the objective decision making process and considers only the company interests.

On special occasions the acceptance of gifts that do not exceed US$10.00 (Ten US Dollars) is authorized.

The clients and suppliers will be informed about this company policy. If the employee receives a gift with a higher value, it has to be immediately directed to the People and Management Department, who will use it for a benefit o may make a raffle with the gifts received.

7.- CONFLICTS OF INTEREST 

At bia we are committed to perform our business and activities in a way that ensures that decision-making is objective and not influenced by personal interests. This code provides the guidelines to prevent, identify, communicate and manage conflicts of interest.

Conflicts of interest
It is a situation in which person ́s private interests may interfere with the fulfillment of their work functions.

A conflict of interest may be produced when an employee puts their self-interest above the interest of the company and when that personal interest unduly influences its professional criteria, its decisions and actions. To issue judgment, make decisions or actions when an employee faces a conflict of interest, can hinder the objective performance of their work and may have legal and regulatory consequences. That is why you have to report any conflict of interest at the Compliance Portal in order to be analyzed. Some examples of these situations where conflict of interest may arise include:

7.1 – Personal relations in the workplace
To hire or supervise a person with there is a close relationship. A close relationship may be a family member by affinity or consanguinity, as well as a person with whom the employee lives in his or her family circle even if the person is not a relative.

This policy includes also the relationship an employee of bia may have with a supplier or client of a member of the competition. As a minimum, the kinship degrees established by the laws of each country must be considered when applying this rule. bia considers that a relationship among employees is a private matter. Nevertheless, we try to avoid situations in which personal interest may be in conflict with the interests of the company.

7.2 – External functions
To be part of a board of directors, administrative council or to have or have had consultancy functions to entities that are direct competitors of bia, regardless of whether the functions are or have been paid.

7.3 – External professional or commercial activities
To have a second employment in the company of a client, supplier of bia competitor. To have an important participation (shareholding or administrative) in a supplier or client company of bia and to be in a position or in the condition to influence in bia negotiations to favor those entities because of its position or attributions in the company.

7.4 – Others
To have a relation of consultancy, administration, employment, professional or external commercial activities that even though are not in direct conflict with the commercial interests of bia, which may cause that the collaborator is not in a position to perform his or her functions in the company according to the requirements of his or her position. To receive sponsorships from the company, directly or indirectly through an association or entity in which you have an active participation. (Example: athletes, soccer teams, non-lucrative organizations).

It is the responsibility of all bia employees to prevent conflicts of interest. This means that they must take the necessary measures to avoid any conflict of interest. In those cases where a conflict arises, it must be communicated to Compliance through the Compliance Portal.

Additionally, it is the responsibility of all bia employees to evaluate if there is a real or potential conflict of interest while executing their jobs. It is a serious misconduct of an employee to not reveal the existence of a real of potential conflict of interest. Doing so will result in the corresponding sanctions.

8.- ETHICS THIS COMMITTEE AND ETHIC LINE

8.1 – Ethics Committee
The Ethics Committee is made up of five people from different departments of the company, including the Executive President who is responsible for the dissemination and application of the Ethics Code. These functions can be delegated or be exercised through the Department of Compliance. The members of the Committee are named by the Executive President and it is coordinated by the Compliance Director.

8.2 – Ethic Line
Any person that has knowledge or founded suspicion of any breach to this Code or the laws and policy of the company must report them through any of the available means of the Ethics Line of the company. Complaints can be filed through e-mail to: denuncias.bia@etictel.com, through the Ethics Line platform: https://ethikosglobal.com/canaldedenuncias/ or through the phone numbers in each of the countries in which we operate.

Anonymous complaints are allowed. Nevertheless, dialogue and trust will be promoted so that the complainant can relay his or her personal complaint in a confidential manner.

The company will not allow any reprisal against any employee who has made a complaint. The investigated person cannot take reprisals against colleagues, employees, clients, suppliers or any other person that the employee suspects made the complaint against him or her.

Any attitude that is proven to be retaliatory for a complaint will result in the corresponding sanctions. Likewise, while the investigation is performed, the confidentiality of the case will be maintained by all areas assigned to the investigation.

The breach or violation of the established Code is considered a violation and will be sanctioned according to its gravity, without prejudice to other actions to be taken, according to the law. Any false report will be sanctioned when checked that there was intention or bad faith against the denounced person.

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Anti-Corruption Policy Summary

Anti-Corruption Policy Summary

INTRODUCTION:

At Bia we have developed this Anti-Corruption Policy to provide an official document to our members of the board of directors, senior management, and collaborators in general, as well as business partners and third parties. This document specifies our commitment to transparency and our fight against corruption through responsible, ethical and transparent action.

This policy is an essential component of our Compliance Program that seeks to ensure that we can focus on our work functions and relationships with third parties without any legal, financial, reputational or other risks related to external and internal regulations that govern our conduct.

OBJECTIVES:

The objective of the Anti-Corruption The objective of the Anti-Corruption Policy is to define the limits within which the following must act in situations they may face to protect the organization and the specific people involved: all collaborators, officials, senior management, members of any administrative or inspection body related to the entities that are part of Bia and its subsidiaries, as well as business partners and third parties.

Some of the specific objectives of the Anti-Corruption Policy are:

• Promote a culture of ethics and values that help prevent, detect, investigate and mitigate the risks of corruption.
• Provide a reference framework for the establishment, review and achievement of anti-corruption objectives, reflecting best international practices.
• Define the concepts, criteria, scope, limits, and responsibilities in the compliance of the Policy and the consequences of non-compliance.
• Maintain financial controls designed to ensure that the books, records and financial statements of Bia reflect with detail and accuracy the transactions carried out by the company.

SCOPE:
This Anti-Corruption Policy is of general application to all collaborators, officials, senior management, members of any administrative or inspection body related to the entities that are part of Bia, including its business partners and third parties, encompassing its subsidiaries and related companies.

Ethical culture and awareness

We have programs and training in anti-corruption matters, which are taught in person and through the e-learning platform. We also have a Code of Ethics, which contains the ethical standards and corporate values to guide employees in their work.

Zero tolerance for acts of corruption

There is zero tolerance against any act of bribery, fraud, extortion, embezzlement and / or any other form of corruption. This means that any incident, complaint or well-founded suspicion of acts of corruption will be thoroughly investigated and those responsible will be punished.

Commitment and leadership of the Board of Directors and senior management

It is the responsibility of the Board of Directors and senior management to demonstrate their leadership and commitment to comply with the Anti-Corruption Policy and to promote an ethical culture.

Donations and other hospitalities

Any type of donation (whether in cash or in kind) must be approved by the Compliance and Corporate Affairs area through the Compliance Portal.

Donations to private entities (Cooperatives, Non-profit Associations and similar)

Donations may be granted when the function of the Private Entity has humanitarian purposes and pursues a public benefit, provided that it meets, among others, the following requirements:

a. Donations must be oriented primarily to the welfare of the community or for humanitarian purposes.
b. Donations must follow the procedure established in the Compliance Portal and have the proper authorization.

Courtesies and other hospitalities

All courtesies, gifts, invitations to meals, trips, entertainment, and other hospitalities that are made to third parties are subject to the Anti-Corruption Policy.

To consult the applicable limits, consult the Compliance Area through the Compliance Portal.

Gifts, food invitations, entertainment, or other hospitality may not be offered or given to a public official.

Legitimate promotional expenses, including nominal gifts related to company products or its portfolio, reasonable meals, invitations to company events or company sponsored events are allowed, but only if all of the following conditions are met:

a. The expense is directly related to a promotional activity or performance of an existing contract.
b. The expense is reasonable. It is neither luxurious nor extravagant.
c. The expense is accurately and completely recorded in company records, regardless of value.
d. The spending is allowed under local law.
e. Spending is not done in secret and does not appear inappropriate.
f. The expense must be previously registered through the Compliance Portal.

Any exception to the criteria established here must be approved by the Ethics Committee through the Compliance Director.

CONTRIBUTIONS OR FINANCING TO POLITICAL PARTIES

It is prohibited to grant donations, gifts, courtesies, loan or rental of furniture and equipment, means of transportation or any other type of support to political parties, candidates for public office and members who hold office within the political party either directly or hint.

Facilitation payments

The company does not allow facilitation payments, even if they are made with the collaborator’s personal resources; this type of payment is totally prohibited.

Gifts and other gratuities

No collaborator may accept gifts, invitations to meals, trips, fairs, gratuities, and hospitalities from current or potential customers, suppliers, Public Officials or any other third party that could compromise the ability to make objective business decisions.

Any doubt or exception to the above rules must be submitted and approved by the Compliance Area through the Compliance Portal.

Third Parties
TPVs (Touch Point Vendors)

They are subject to the Due Diligence process established by the Compliance Area in the Due Diligence Portal.

In any contracts with TPVs, clauses allowing for the unilateral termination of the contracts if the counterpart performs Acts of Corruption, as well as the requirement to comply with Anticorruption laws, must be included.

Hiring former Public Officials

The company cannot hire former Public Officials who have issued or signed resolutions or made decisions in which they have participated or with whom the company has had any type of relationship. This prohibition applies during the time that said Public Officials act in their official capacity, and for two years following the date of termination of his or her functions. Any exception must be evaluated and approved by the Ethics Committee.

Registers

A system of adequate internal accounting controls is required and all transactions must be reported and reflected appropriately, accurately and with reasonable detail in the company’s books and accounting records.

The finance area will identify the “sensitive accounts” or “Compliance Sensitive Transactions” or “CST” within its accounting plan, and must continuously monitor said accounts.

Contractors must comply with the provisions regarding accounting, books, records, and internal control provisions included in the Applicable Anti-Corruption Laws.

Ethics Phone Line

The access routes are telephone numbers authorized in each of the countries where Bia operates, emails and website, as described in the Code of Ethics.

Those who report misconduct or a conduct in violation of the applicable Code of Ethics, policies and / or regulation, as well as those who cooperate in an investigation, are protected against retaliation. The company prohibits and sanctions any type of acts of retaliation and can sanction, even with dismissal, those proven acts of retaliation against whistleblowers or collaborators in the investigation procedure.

ROLES AND RESPONSIBILITIES

The Board of Directors is committed to promoting a culture of prevention of acts of corruption at a strategic and operational level.

Senior management will implement the control measures for compliance with the procedures for the prevention and mitigation of corruption risks and will make periodic reviews to determine if new risk possibilities have arisen.

The Compliance Department, with the support of People and Management and the Legal Area, is responsible for developing and monitoring the Anti-Bribery Management System and ensuring the effectiveness of the Compliance Program. At the same time, it is responsible for the investigation, follow-up, administration and/or updating of the information of the incidents reported through the Ethics Line until the closing of the investigated cases and will inform the Ethics Committee in a timely manner.

The People and Management department will support the dissemination and awareness of this policy.

Corporate Audit is responsible for evaluating the effectiveness and compliance with this Anti-Corruption Policy, at least once a year.

Each employee is responsible for applying the criteria established in the policies and procedures and must act in accordance with the corporate values and guidelines established in this policy and in the Code of Ethics.

RISKS

Financial risks:

• Misappropriation of Assets and Accounting Fraud to favor employees or to favor the organization.
• Financial losses, for the benefit of employees or third parties, for goods or services not received, or received with a different quality than that required.
• Fraudulent negotiations with suppliers that impact and increase costs and expenses for the business.
• Increase in expenses and costs of sales due to product theft through unauthorized mechanisms.

Operational risk:

Due to conflict of interests, inadequate supervision, lack of attachment to the organization’s essential values and culture.

Compliance risk:

Due to money laundering, acts of corruption, tax evasion, non-compliance with policies and procedures.

Reputational risk:

Demands from corporate groups of interest (clients, suppliers, regulators).

Corruption risks:

Non-compliance with rules and policies that affect the company’s situation and impact on its reputation.

SANCTIONS

If it is proven that there was a violation of ethics and integrity, the provisions described in the Code of Ethics, the Internal Policies that apply to the corresponding area, as well as the Anti-Corruption Policy and the Anti-bribery Management System, disciplinary measures will be applied depending on the seriousness of the offense and in accordance with the procedures established in the laws of each country.

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Ethics Line

Ethics Line

Call us anonymously from any country at x1111

USA: 888-374-1694
México: 800-269-4431
Guatemala: 2378-1990
El Salvador: 2248-5090
Honduras: 2202-4041
Costa Rica: 0800 542 5311
Nicaragua: 2255-4511
Panamá: 800 0182
República Dominicana: 1800 751 0145
Puerto Rico: 7875458989
Jamaica: 937-8555
Argentina: 0-800-800-1451
Ecuador: 371-0177
Perú: 412-5560
Uruguay: 2518-5422

Send us an email to: denuncias.cbc@etictel.com

Login to: www.ethikosglobal.com/canaldedenuncias

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Quality and safety policy

Quality and safety policy

1. OBJECTIVE
Establish the global intentions and the general orientation of the organization related to its quality and safety performance

2. REACH
This policy is directed to all the operations – affiliates and subsidiaries – where the group operates, as well as new operations or any business expansion, covering all areas of manufacturing and distribution centers. This policy is established according to certification programs that meet the requirements approved by GFSI (Global Food Safety Initiative) which are recognized worldwide.

3. DEFINITIONS
a. Food: A substance (ingredient), could be processed, semi-processed or raw, intended for consumption, and includes beverages, chewing gum and any substance that has been used in the manufacture, preparation or treatment of “food”, but does not include cosmetics or tobacco or substances (ingredients) used solely as drugs.
b. Quality: is the point where a set of inherent characteristics meet certain requirements.
c. Coding: alphanumeric symbology used to identify the exact place and time of the product’s production.
d. HACCP: Hazard Analysis and Critical Control Points. According to the Codex Alimentarius, General Principles of Food Hygiene CAC/RCP 1-1969, the HACCP system makes it possible to identify, evaluate and control significant food safety hazards.
e. Food safety: Food safety as a concept implies that food will not cause harm to the consumer when prepared and/or consumed in accordance with its intended use.
f. Prerequisite program: Are the basic conditions and activities necessary to maintain, along the entire food chain, an appropiate hygienic environment for the production, handling and provision of safe finished products and safe food for human consumption.
g. Safety Management System: Effective management system that allows the organization to control safety-related hazards and that combines interactive communication, system management, prerequisite programs and HACCP principles, interrelates policy and objectives, and ensures the continuous improvement of processes.
h. Traceability: When considering a product, traceability can be related to the origin of materials, the history of processing, distribution and location of the product after delivery.

4. NORMS
4.1 Quality and Safety Policy As a Corporate Group dedicated directly or indirectly to the manufacture of food and beverages, we are committed to ensuring the quality and safety of our products through competent personnel, the continuous improvement of our safety management system, complying with legal, customer and other applicable requirements and maintaining effective communication with all stakeholders to achieve our objectives.
4.2 Manufacturing-specific safety policies
4.2.1 Glass, Brittle Plastic and Ceramic Control Policy
4.2.1.1 The safety of manufactured products must be guaranteed and the absence of elements or pieces of glass, brittle plastic and ceramics must be ensured during the production and transfer of the finished product, through an adequate handling and inventory of said elements, following a contingency plan to avoid contamination of the product in the event of unintentional glass breakage, brittle plastic or ceramic.
4.2.1.2 The use of glass, brittle plastic or ceramics within production plant facilities is restricted. The above materials may not be used in areas that could be risky for the safety of the products, except where necessary or when it is not feasible to remove them immediately.
4.2.1.3 Glass, brittle plastic or ceramics will not be introduced with personal belongings.
4.2.1.4 All plant and distribution center personnel must comply with the responsibilities set forth in the Glass, Brittle plastic and Ceramic Control Procedure.
4.2.2 Coding Policy on Finished Product
4.2.2.1 The traceability of manufactured products must be guaranteed and ensure that production complies with:
a) Packaging that must be coded correctly and legibly.
b) Verify and validate in each production, the first and last individual packaging and every hour, with the following minimum information contained: batch, plant identification, year, day, line and time of production.
4.2.2.2 All personnel must comply with the provisions of the Procedure of Coding in Finished Product of each commercialization country´s organization and regulations of products and use the one that is more demanding.
4.2.2.3 It must be insured that correctly coded products are distributed to the market.
4.2.2.4 It is not allowed to operate the production line when coding problems have been detected.
4.2.2.5 It is not allowed to commercialize product without coding.
4.2.2.6 In the event of a coding problem, production must be stopped and resumed until the necessary reparations are made.
4.2.2.7 The final product packaging team should apply the codes required by each product and package particularly, according to the products commercialization and local regulations.
4.2.2.8 If products with coding problems in the market are detected, the Product Recall Procedure should be applied.
4.3 Rules for the areas involved in the supply chain In order to ensure the safety and quality of the products, all the personnel involved during the general manufacture process –such as Purchase department, Research + Development, Logistics, People and Management, Projects, among others– should comply with the procedures, manuals and documents set in the Quality Pillar and Supply processes.
4.4 Compliance of Ethics and Integrity All employees should perform their task with strict adherence to ethics and integrity, fulfilling all the Ethics code and Internal Policy guidelines that apply to their corresponding areas, as well as the Anti-corruption Policy and the Anti-bribery Management System.

5. ROLES AND RESPONSABILITIES
Facility Manager

• Promote the commitment and compliance of the policy, internal procedures, legal requirements, among other things, established for each operating country.
• Promote the fulfillment of policy through the proposition and implementation of reduce harmlessness and quality risks.
• Insure that point 4.1 of this policy is shown and visible in the facility accesses.

Manufacture Director

• Promote the commitment and compliance of policies, internal procedures, legal requirements, among other things, established by each operating country.

Facilities and distribution centers employees

• Know and fulfill the Safety and Quality Policy.
• Know and fulfill the Glass, Brittle Glass and Ceramics Control Procedure and the Final Product Codification Procedure.
• Fulfill all the procedures related to the current policy and the Quality Pillar of the Supply procedures.

People and Local Management Manager (facility, country)

• Ensure the Quality and Safety Policy is included as part of the Inycie in the organization and in the annual training plan that covers all employees from every facility and distribution center.
• Guarantee the outreach and awareness of the present policy.
• Ensure that the Final Product Codification Procedures and the Glass, Brittle Plastic and Ceramics Control Procedure are included in the employee annual training plan of every production facility and distribution center.

6. RISKS
The present policy is focused on managing the mentioned risks, but not limited to the following list:

a) Strategic Risk:

• Loss of the franchise commercial relations.

b) Financial Risk:

• Loss of money because of withdrawal or loss of product because of quality or harmlessness problems.

c) Compliance Risk:

• Low quality commercialized products.
• Commercialized products that may cause harm to the consumers.
• Fine and penalties because of legal non-compliance.

d) Operative Risk:
• Facility closure (temporary or permanent) because of legal non-compliance.
• Non-compliance of the established production procedures.
• Wrong response in the product recall risk (lack of tracking).

e) Reputational Risk:
• Negative exposure of the company’s image.
• Product recall

7. SANCTIONS
Every misconduct associated with hiding or tampering with information related to the quality and safety aspects of the processes or products, or that endanger consumers health, comes with a severe sanction.

The present policy aims to enforce the following sanctions, but is not limited to the following list, depending on the severity of the misconduct in accordance with each country´s regulation:

• Verbal warning.
• Written warning.
• Employment suspension without pay.
• Loss of employment.

If the ethics and integrity violations are proven, the measures described in the Ethics Code, the Internal Policies that apply to the corresponding area, as well as the Anticorruption Policy and the Antibribery Management System, the disciplinary actions will be applied depending on the gravity of the misconduct and in accordance with each country´s established legal procedures and regulations.

8. ANNEX – RELATED DOCUMENTS

CODENAME OF THE PRODUCT
ExternoNorma FSSC- 22000:2005
fab-cal-ppr-0-prd-009Procedimiento Control de Vidrio, Plástico Quebradizo y Cerámico.
fab-cal-ppr-0-prd-011Procedimiento de Codificación de Producto Terminado.
fab-cal-ppr-0-prd-012Procedimiento Retiro de Producto.

9. APPROVAL AND AUTORIZATION LEVELS

SIGNATURENAMEPOSITIONBUSINESS UNIT
Owner of the processManagement boardManagement boardJD
Designed byAna FrancoQuality Assurance ManagerApex
Reviewed byBrenda BoteoCorporate Risks ManagerApex
 Gloria RamosCorporate Government ManagerApex
Approved byAlejandro FernándezManufacture Vice-president COEApex
 Magda TunchezAudit DirectorApex
 Francisco RamosCompliance DirectorApex
 Marco MéridaCorporate Risks and Internal Control ManagerApex
 Juan Pablo GonzálezFinancial ComptrollerApex
 Heidy GarcíaLabor Affairs Legal ManagerApex
 Carlos Gerardo BoschHead of LegalBia
Authorized byLuis Miguel CastilloManagement board representativeJD

10. POLICY MODIFICATIONS

VERSIONDATEMODIFICATION DESCRIPTION
2October
2020
REACH: “Distribution Center” is included. The following quote is erased: “and logistic from the purchase of feedstock until the product storage in the agencies”.
DEFINITIONS: Food definition is added. Tracking definition is added.
POLICY: “Qualified personnel” is added to the global policy. The quote “in order to achieve our objectives” is added at the end. The quote “harmlessness management system” was modified to “Quality Pillar”, except in the point 4.1, where “harmlessness management system” remains.
4.2 Writing errors were corrected.
4.2.1.4 is added that also the distribution center employees should fulfill the glass, brittle plastic and ceramic Control procedure.
4.2.2.1 the item c) is eliminated and is relocated as a separate item. The responsibilities were modified.
RESPONSIBILITIES: The Operations and Services Manager responsibility is eliminated. The writing of the People and Management manager responsibilities is improved.
 September 2021The tracking definition is modified: “Taking into consideration a product, tracking could be related to the material origin, the processing history, the distribution and the product localization after its delivery”. The reference to specific standards on the definitions of quality, food safety and prerequisite programs.
The reach is extended with the next quote: “This policy is established according to certification programs that meet the approved requirements of the GFSI (Global Food Safety Initiative) which are globally recognized.

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San Marcos donates pinto jalapeños to puebla’s food bank

Sustainability

San Marcos donates pinto jalapeños to puebla’s food bank

One of our main goals is to help Mexican families and contribute to the development of the state where everything started: Puebla. That is the main reason why we started our donation programme by sending Pinto Peppers to Puebla’s Food Bank.

We selected an average of 30 tons of Pinto Peppers, a variety chosen for its nutrients and amazing flavor.

As a Mexican company, we are aware of the importance of supporting our country, this is why we will keep the hard work on to help even more families actions like this.

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BSCI audit results

Sustainability

BSCI audit results

Dear collaborators

We are pleased to announce that on July 23 and 24, 2020, we received Intertek auditors at our facilities, who made a follow-up audit within the standard BSCI requirements.

Business Social Compliance Initiative (BSCI) committed with companies to improve working conditions in factories and farms all over the world.

During this process we showed our commitment to be a socially responsible company with results of improvement in the areas of action previously evaluated, since the result obtained was the highest score, going from a C to an A.

We proudly congratulate our team. Thank you for showing day by day the of being passionate with what you do.

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At San Marcos we take care of our collaborators in COVID times

Sustainability

At San Marcos we take care of our collaborators in COVID times

We have a big commitment with our collaborators, who make their best day by day. We want to thank them all for their hard work and support during this difficult season by donating groceries to each and every one of them for four fortnights.

At San Marcos we care for our team, and we want to support you through thick and thin.

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San Marcos and the government of puebla: united for mexican families.

Sustainability

San Marcos and the government of puebla: united for mexican families.

We owe everything to Mexico, specially to Puebla, the state that saw us born, that’s why we have donated 182,868 food cans, equivalent to $3,358,247 to our Government with the aim of helping our people.

Supported by the local DIF office, San Marcos spotted the most vulnerable and worst affected families by this pandemic and we donated peas, beans, jalapeños, nopal, serranos and huitlacoche cans.

We wanted to start this programme in our home state, but San Marcos will keep on helping more families throughout Mexico.

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San Marcos and Cruz Roja start a different fundraiser for our current situation.

Sustainability

San Marcos and Cruz Roja start a different fundraiser for our current situation.

We have worked with the Mexican Cruz Roja for several years now, and we always want to show our appreciation to them for being our support system whenever we need medical assistance in Nopalucan.

Year by year, we support their fundraising. This year everything changed, but we wanted to reaffirm our commitment by donating $100,000 to Puebla’s Cruz Roja and $100,000 to Grajales’ Cruz Roja in order to help these health centers who need our support more than ever.

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San Marcos and Cruz Roja start a different fundraiser for our current situation. Read More »