Anticorruption

Principle 10:

Businesses should work against corruption in all its forms, including extortion and bribery

As a member of the UN Global Compact, Proeza contributes to eradicating corruption in all its forms, including bribery and extortion, through its Ethics & Compliance program.

In 2021, at Group level, 87% administrative personnel were trained in anticorruption topics.

Code of Conduct


Our company has a robust Code of Conduct applicable to all subsidiaries. This document aims to establish mechanisms to comply with international norms and best practices in ethics and compliance, to create an environment of trust, and live the institutional values within Proeza. It sets clear behavior guidelines for our interactions within the organization and externally with our suppliers, partners, clients, and the rest of our stakeholders.

All employees are trained and aware of the Code of Conduct, so it is mandatory, and non-compliance with it may lead to sanctions, including dismissal.

All administrative and operational personnel, over 13,000 employees, took our Code of Conduct course.

Oversight bodies


It should be noted that the proper functioning of our program is supported by a compliance structure that allows the execution of its operation, assigning this responsibility to the Ethics and Compliance Committee of Proeza Group (“CEC”): The CEC is the highest control body for Ethics and Compliance within the organization. This governing body reports directly to the Risk, Audit, Compliance Committee of Proeza Group. The CEC also designates an Extension CEC in each of our Business Units. These committees are responsible for monitoring and ensuring compliance within the program of Proeza Group and its companies. Also, we have the figure of Compliance Officers that implement the instructions and mandates of the CEC and/or the Extension CEC, ensuring that the program, policies, and procedures that compose it are duly implemented within their respective companies.

Ethics and compliance program


Our program is based on zero tolerance principles, aiming to build an ethical culture in the organization, comprised of four pillars:

1

Integrity and
anticorruption

2

Administrative and
criminal risk prevention

3

Privacy and personal
data protection

4

Money laundering
prevention

1) Integrity and anticorruption


At Proeza Group, we are committed to having a corruption-free organization. Through our guidelines, values, and best practices, we work every day to conduct business with integrity. Our first pillar focuses on establishing the essential elements of the compliance function within the organization, establishing measures to mitigate corruption in our day-to-day activities.

Continuous training and communication enable the company to maintain its focus on operating ethically and transparently. Within the organization, we have a solid policy structure that guarantees fair commercial practices within our operation. Among them, we can point out:

  1. Anticorruption policy
    Supported in this guideline, we ensure that any activities in Proeza are based on ethical decisions and high levels of integrity under our Code of Conduct.

    Since 2020, we have deployed an Anticorruption policy based on national and international legislation, setting guidelines for our employees, suppliers, and commercial partners in anticorruption, bribery, conflicts of interest, theft, and other ethical behaviors and risks.

    Through it, we expose the mandatory rules for preventing corrupt activities throughout the entire organization and operations.

Employees must report suspected violations regarding Anticorruption Policy on the Transparency Line, and they may do so without fear of retaliation.

  1. Transparency Line assistance protocol
    The Transparency Line is an effective ethics reporting tool for detecting corruption risks and any conduct contrary to the principles and values of Proeza, its Code of Conduct, or any of its policies or guidelines.

    This tool is complemented by an assistance protocol where transparent processes were established to allow complaints, investigation, and sanctions management. It guides the actions that must be conducted to attend complaints, and at the same time, it defines the roles and responsibilities of the team in charge of the process.

    In 2021, we received 183 complaints, all were processed, analyzed and 90 % were closed by the Ethics & Compliance Committee.

Complaints are made through the web page www.proeza.com.mx/transparency and other media platforms (phone, email, WhatsApp, app), which are available 24/7.

  1. Contracting Policy of Third Parties and Veto of Suppliers
    At Proeza, we know that third parties’ corruption acts can also create consequences within the supply chain. To reduce this kind of risk, our guideline ensures that all our suppliers comply with all applicable anticorruption laws, money laundering prevention laws and economic sanctions, including laws of the National Anticorruption System in Mexico, the FCPA, among others.

    In the case of suppliers incurring in acts of bribery, threat, money laundering, breach of contract, and lack of liquidity, a veto process could be executed.

Through the Contracting Policy, our goal is to align our beliefs and values with those of our suppliers, where integrity is believed to be the foundation of enduring human relationships, and to establish an environment of trust and reliability.

2) Administrative and Criminal Risks Prevention


Our second pillar establishes the guidelines and procedures to be followed to properly control the possible commission of crimes and administrative offenses to which the organization is exposed.

  1. International Criminal Compliance Policy
    Proeza maintains a zero-tolerance culture for criminal behavior. For this purpose, we have established international guidelines practices to prevent the commission of crimes (CC Model) within Proeza.

To minimize Proeza’s exposure to criminal risks, Proeza Compliance Officers will analyze and study possible criminal contingencies to which Proeza may be exposed, discarding those actions that may represent any form of exposure to criminal risks.

Proeza is committed to collecting and processing personal data responsibly and following the storage limitation principle. Employees should not keep personal data any longer than is necessary for the purpose for which Proeza originally collected it.

3) Personal data privacy and protection


Our third pillar establishes policies and processes for correctly processing personal data held by the company.

  1. International Data Protection Policy
    Guarantees the right to data protection of everyone related to Proeza Group, including all regions and sites. Proeza Corporate endeavors to ensure that appropriate safeguards are implemented to secure such data transfers in conformity with applicable laws.

  2. Cybersecurity program
    We performed training and communication campaigns promoting cybersecurity initiatives to mitigate security risks and protect the personal data of our stakeholders. In 2021, 90% of our personnel participated in the training.

4) Money Laundering prevention


Our fourth and last pillar establishes rules that help reduce the risks of money laundering operations through verification and risk control measures.

  1. Money Laundering prevention international policy
    Money laundering may occur with fraud, robbery, terrorism, and racketeering. A transaction that seeks to conceal the nature, source, or ownership of funds may indicate an act of money laundering.

    Through adequate controls, the company can detect anomalies, identify applicable laws, and layout international mandatory mechanisms and procedures that must be followed by Proeza Corporate and its Business Units in every country in which we operate.

All our employees, counselors, directors, officers, advisors, and representatives must avoid and be alert to information or activities that may be evidence of money laundering.