Human Rights Global Policy

1. INTRODUCTION

We respect and promote all internationally recognized Human Rights stated in the International Bill of Human Rights, in the Human Rights American Convention, in the values and fundamental rights of labor included in the Declaration of the International Labor Organization, related to the values and fundamental rights of labor and the fundamental agreements of the International Labor Organization. Likewise, the Guiding Principles of Corporations and Human Rights of the United Nations.

The Corporate Group is committed to adhere to the Convention on the Elimination of All Forms of Discrimination Against Women, the Convention on the Rights of the Child, among others.

This commitment is reflected in the Corporate Group´s Code of Ethics being its primary goal to have all employees, partners, contractors and suppliers observe it at all times as well as respecting all internationally recognized Human Rights.

This policy assigns responsibilities to Global Mobility Apex – Apex employees, whom Bia Food Investments and its subsidiaries have designated as service supplier of consultancy and support in specific processes related to this policy.

2. OBJECTIVES

The general objective of this policy is to promote and respect all Human Rights within the company and with its suppliers.

The specific objectives of this policy are:

a. Forbid and not tolerate any internationally recognized Human Rights violation .
b. Forbid and not tolerate any Human Rights Policy violation in every form and situation.
c. Request the fulfillment of every law applicable to any country the company operates in, as well as the present policy and the international Human Rights laws.
d. Forbid and not tolerate any kind of reprisal against employees who file a complaint or collaborate in the investigation of those complaints.
e. Promote among employees the filing of complaints in good faith or with reasonable cause and without fear of retribution.

3. REACH

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.

4. DEFINITIONS

a. International Bill of Human Rights: The International Bill of Human Rights is the legal tool declared by the United Nations at different moments: the Universal Declaration of Human Rights; the International Covenant on Civil and Political Rights, adopted by the UN General Assembly through the 2200A Resolution (XXI) on 16 December 1966, and in force from 23 March 1976; The International Covenant on Economic, Social and Cultural Rights (ICESCR), adopted by the UN General Assembly on 16 December 1966, and enforced on January 3rd 1976; the First Optional Protocol to the International Covenant on Civil and Political Rights; and the Optional Protocol to the International Covenant on Economic, Social and Cultural Rights, approved by the UN General Assembly on December 10th 2008, and enforced on May 5th 2013.

b. Declaration of the International Labor Organization (ILO) on Fundamental Principles and Rights at Work: Adopted in 1998, the State Members respect and promote the principles and rights described in four categories: freedom of association and the effective recognition of the right to collective bargaining, the elimination of forced or compulsory labor, the abolition of child labor and the elimination of discrimination concerning employment and occupation.

c. United Nations Guiding Principles on Business and Human Rights: Framework on the issue of human rights and transnational corporations and other business enterprises. Were adopted and endorsed by the United Nations Human Rights Council in 2011.

d. Human Rights Due Dilligence: This process is an evaluation to address proactively the possible impact of the main activities within the company concerning Human Rights, the integration of the conclusions in a report and the recommendations according to the evaluation. The Human Rights Due Diligence process will be adopted according to the guidelines of the United Nations Guiding Principles on Business and Human Rights (2011).

e. Global Mobility Apex: External service provider entity part of the Corporate Group.

f. Corporate Group: Comprised of the business units of BIA Foods Investments, Inc., including its subsidiaries and companies that are or will be part of the group in the future.

g. Ethics Line: Tool through which every shareholder, executive, partner, contractor, associate or even third parties can report, even anonymously, any misconduct that violates the present Code of Ethics, national or international legislation, or internal policy.

h. Main activities of the company: Activities directly developed and related to the core business (i.e., manufacture, logistics, marketing, among others).

i. Strategic direct suppliers: Goods and services providers that are essential to business development, determined by the General Management of BIA or whom it designates to negotiate purchase and services contracts for each business unit, including raw materials, packaging materials, logistic services, among others.

5. RULES
5.1 Public Commitment

The company is publicly committed to respect and promote all internationally recognized Human Rights, communicating it by the means it deems appropriate.

5.2 Training and skills development

Training plays an important role in the commitment to Human Rights in our corporate activities and operations. For this reason, the Corporate Group should have training programs for its employees and strategic direct suppliers in order to meet this policy.

Training will be done annually and must include a module designed to raise awareness about the existence, content and scope of this Policy, as well as provide collaborators and strategic direct suppliers with a clear and detailed understanding of Human Rights, labor rights and that all of these topics remain relevant to the companies. This will be the responsibility of the Apex People and Management and Apex Purchasing Departments, in coordination with the People and Management and Purchasing Departments of the Bia business units.

The commitment to fullfill the principles and values contained in the Code of Ethics and this policy must be included in the agreements for goods and services of the Corporate Group, including a commitment to comply with current national legislation. Compliance with the above provisions must be guaranteed in the terms and conditions negotiation with the mentioned suppliers without exception, whether for new contracts or renewals. It should be included in each contract, to the extent possible, that the breach of the principles and values contained in the Code of Ethics, including a commitment to comply with current national legislation and this policy by the third party, would imply the termination of the contract by the business unit of the corporate group, without liability on their part.

5.3 Due Diligence Process

Corporate Group and all companies related to it must adopt a Human Rights Due Diligence process, which will include the periodic performance of a Human Rights Impact Study, the implementation of a strategy for integration and / or mitigation and remediation of the real and potential impacts identified, and the risk management impact on Human Rights public report .

This due diligence process should include substantive stakeholder consultation. The process will be led by the Apex Corporate Affairs Department with the accompaniment of a Human Rights expert and the Corporate Group Risk Committee.

This evaluation can be integrated into the framework of other processes, such as risk or environmental impact assessments, which will include as a point of reference the whole spectrum of the internationally recognized Human Rights.

The Human Rights Due Diligence Process will be carried out in accordance with an annual plan that will be presented by the Apex Corporate Affairs Directorate in coordination with the corresponding business unit and in accordance with its line of business.

The Corporate Group also recommends its strategic suppliers to develop Human Rights Due Diligence processes proportional to their size, sector and capacity, as well as to enable easily accessible complaints and claims mechanisms for their stakeholders.

5.4 Prevention and Mitigation

To prevent and mitigate potential and actual risks and impacts on Human Rights, the company will integrate the conclusions and recommendations of the Due Diligence within the framework of its functions and relevant internal processes and will take the corresponding measures every six months.

It is necessary for the correct integration of the recommendations that: i) the responsibility of the decision making must be assigned to the appropriate levels and functions within the company, including the executive levels; ii) the adoption of internal decisions, budget allocations and supervision processes allow compliance with the recommendations made.

The measures to be adopted will vary depending on: i) whether the company is the one that identifies a real or potential impact on its direct operations; ii) a potential or real impact risk is identified in one of its strategic suppliers.

In case one of the Corporate Group´s strategic suppliers is identified as a perpetrator of Human Rights, the Corporate Group will encourage an appropriate behavior change on the supplier, seeking to stop the impact. If this is not achieved, the possibility of terminating the contractual relationship with the supplier will be assessed. To determine the previously mentioned, the company will evaluate its suppliers compliance with this Policy, which will be prioritized according to their level of negative impact on Human Rights.

Any recommendation from the Due Diligence Process should be communicated within the Corporate Group to the Corporate Group Risk Committee to strengthen the understanding of the importance of upholding Human Rights. The Corporate Group must include the risks of impacts identified in the Human Rights Impact Study within its general risk management system, in order to ensure a continuous process of feedback and improvement in the matter of non-compliance risks mitigation.

5.5 Policy Fundamental Principles

This Policy is based on the Code of Ethics of the Corporate Group and on the internationally recognized Human Rights treaties, especially the International Bill of Human Rights, the American Convention on Human Rights, and the Eight Fundamental Conventions of the International Labor Organization. This commitment is reflected in the company’s Code of Ethics.

5.6 Fundamental Principles and Rights at Work

We recognize, as established in the Declaration of the International Labor Organization on Fundamental Principles and Rights at Work, that it is vital to maintain the link between social progress, economic growth and the assurance of the fundamental principles and rights at work.

We are committed to respect, promote and uplift, in good faith and in accordance with each country´s local laws and ILO´s international principles, the principles related to the following fundamental rights at work, also expecting that our suppliers will specifically commit to fulfill them.

5.6.1 Elimination of all forms of forced or compulsory labor

The Corporate Group forbids in accordance with ILO Convention No. 29 on Forced Labor of 1930 and ILO Convention No. 105 on the Abolition of Forced Labor of 1957, all forms of forced, compulsory labor, slave labor and any form of human trafficking. The use of physical punishment or threats of violence or other forms of physical, sexual, psychological or verbal abuse as a method of discipline or control in the workplace will not be tolerated.

5.6.2 Harassment and Discrimination Prohibition

In accordance with the provisions of ILO Convention No. 100 on Equal Remuneration of 1951 and with Convention No. 111 on Discrimination in Employment and Occupation of 1958, any type of discrimination or harassment based on age, race, sex, color, origin, national origin, religion, gender identity, disability, sexual orientation, pregnancy status or any other status protected by local laws is prohibited.

The recruitment, hiring, training, compensation and access to career plans processes will be based on meritocracy regarding qualifications, skills, experience and performance.

We will value diversity and unique contributions of our employees and will have a commitment to equal opportunities and intolerance of discrimination and harassment.

5.6.3 Effective Child Labor Ban

Based on the provisions of ILO Conventions No. 182 on the Worst Forms of Child Labor of 1999 and No. 138 on the Minimum Age of 1973, we recognize that every girl and every boy has the right and the opportunity to fully develop their physical and mental potential.

Child labor will not be permitted within our corporate group, so hiring minors is prohibited, being the legal age the one established by local laws in each country in which we have operations. The company considers 18 years of age to be of legal age. We will communicate and inform our suppliers about the importance of eradicating child labor.

5.6.4 Healthy and safe work conditions

The Corporate Group will provide and maintain safe and healthy workspaces and environments that comply with applicable laws, regulations, and labor, safety and health requirements, including the adoption of preventive measures by employees, clients and other stakeholders regarding epidemics or pandemics. We are committed to work with our employees to continually improve health and safety in our workplaces, including identifying hazards and taking corrective and preventive action.

5.6.5 Freedom of association, freedom to unionize and collective bargain freedom

In accordance with the provisions of ILO Conventions No. 87 on Freedom of Association and Protection of the Right to Organize of 1948 and No. 98 on the Right to Organize and Collective Bargaining of 1949, the company will respect the right of our employees to join, form or not join a union without fear of retaliation, intimidation or harassment. When employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives. We are committed to conduct collective bargaining in good faith with such representatives.

5.7 Ethics Line

The Ethics Line is administered by an independent supplier under ethical and confidentiality standards. The access routes are telephone numbers enabled in each of the countries where we operate, email and website, as described in the Code of Ethics and it will inform interest groups that may be potentially affected about the access and operation of this line, especially vulnerable groups with difficult access to technology.

If applicable, the complaints submitted will be transferred to the competent external authorities for their knowledge through Bia´s Legal Department, complying with the regulations of each country where it applies.

Those individuals who report misconduct or violation of the Code of Ethics, this Policy and / or applicable regulations described here and in other Policies, as well as those individuals who cooperate in an investigation, will be protected against retaliation. The Corporate Group forbids and will take action against any type of retaliation, including dismissal, acts against complainants or collaborators in the investigation procedure. The disciplinary measure will be applied based on what is established in the Code of Ethics, Individual Work Contract, Internal Work Regulations and the Sanctions Regulation, respecting at all times the guarantees of due process and local legislation.

The Ethics Committee of the Corporate Group is responsible for hearing complaints of possible violations to the Code of Ethics, this and other Policies of the Corporate Group. The Apex Compliance Department, in coordination with Bia’s Legal Department, is the one responsible for managing investigations.

Accessing the report remediation mechanisms in the ethics line does not inhibit the possibility of any individual presenting the complaint to go to other external mechanisms prrotected by law. if he / she deems it necesary. The Corporate Group will fully collaborate with the authorities and procedures that are implemented externally in relation to complaints that deal with potential or actual risks and impacts on Human Rights Policy.

5.8 Resolve or Reparation Mechanism

If the Corporate Group detects a potential Human Rights violation enunciated in the Guiding Principles of this Policy, either through the Due Diligence Process in matters of Human Rights or by other means, it will adopt the necessary actions to remedy that situation, by itself or in cooperation with tthird parties.

If a potential or real negative impact has been identified by one of the strategic direct suppliers, the responsibility to correct or remediate that impact falls on the supplier. However, the company will work to the extent possible with the strategic direct supplier to guide it in the adoption of decisions aimed to remedy the adverse impacts on Human Rights related to its operations, products or services. However, the Corporate Group will follow up on the actions to be implemented and may terminate the service agreement with this provider based on the analysis of impacts and risks on Human Rights that will be carried out by Corporate Affairs and that will be presented to the Risk Committee of the Corporate Group for final deliberation.

The Corporate Group will rely on the assistance of a Human Rights matters expert in order to establish remedial mechanisms if the case arises, also with the participation and advice of Bia´s Legal Department.

5.9 Consultancy of Human Rights independent experts

The Corporate Group may receive advice from an independent Human Rights experts on the general approach to Human Rights, on the Due Diligence processes and on how to respond to a complaint of possible non-compliance.

Knowledge and best practices will be shared as established in the procedure of this policy.

5.10 Reports

The fulfillment of this Policy in accordance with the mentioned procedure and regulations will be publicly informed at least annually about. The preparation of the report will be in charge of the Apex Corporate Affairs Department, as well as the definition of the communication strategy of this to the interested parties.

6. ROLES AND RESPOSIBILITIES
CEO of Bia: will guarantee the fulfillment of the general guidelines on the drafting of the Human Rights Due Diligence Process and the training and execution of the regulations of this policy for all collaborators.

APEX Corporate Affairs Directorate

a) Will provide the general guidelines fo rthe preparation of the Human Rights Due Diligence Process, identifying the main activities of the company according to their line of business. The Due Diligence Process will be coordinated by the APEX Corporate Affairs Directorate with the accompaniment of an expert in Human Rights and the APEX M&A Department as well as any other that is required for the review. The results of the Due Diligence process will be disclosed to the Corporate Group Risk Committee.

b) Will be in charge of ensuring the fulfillment of the Policy and communicate the commitment established by this Policy. Likewise, it is responsible for developing training and induction programs for strategic direct suppliers, in conjunction with P&M.

APEX People and Management Department: responsible for the internal communication of this Policy and for carrying out periodic communication and training campaigns on Human Rights and Labor Rights.

APEX Purchase Directorate: in charge of identifying strategic direct suppliers and ensuring their adherence to the Code of Ethics and the provisions in this Policy.

APEX Compliance Directorate: responsible for investigating reported cases, proposing action plans in case of non-compliance, monitoring their execution and identifying the applicable rules and regulations that mitigate risks of non-compliance in Human Rights in conjunction with the APEX Corporate Affairs Directorate.

APEX M&A Directorate: in charge of including in the Due Diligence process the request for information linked to records related to Human Rights inside the company that are under analysis, in order to establish the level of fulfillment.

APEX PMI Management: responsible for tracking the actions focused on narrowing the gaps identified during the Due Diligence process and managing new risks related to non-compliance with Human Rights during the integration process of new acquisitions.

7. RISKS
The present Policy looks to mitigate the following risks:

Legal Risk: Lawsuits by regulatory entities because of Human and Labor Rights non-compliance.

Operational and Compliance Risk: Lack of attachment to the values and culture of the organization. Inadequate supervision of the fulfillment of labor laws applicable to the Corporate Group.

Reputational Risk: Negative public opinion due to public complaints of non-compliance with Human Rights and Labor Rights.

8. SANCTIONS
Any breach of this Policy and related procedures and policies will be subject to disciplinary actions that must be applied to employees who have committed misconduct directly, or by omission, as well as the possible referral to judicial and criminal authorities.

The sanctions will depend on the severity of the offense and will be in accordance with the laws of each country, the relevant international Human Rights treaties and internal labor regulations.

9. ANNEX – RELATED DOCUMENTS

10. LEVELS OF APPROVAL AND AUTHORIZATION

11. MODIFICATION TO THIS POLICY