We are a firm committed to universal values such as respect, transparency and honesty.

Introduction

This Code of Conduct and Ethics (the “Code”) encompasses principles of conduct which Sánchez Vebber, S.C. (the “Firm”) always follow to ensure that its business is conducted with transparency, integrity and responsibly. This Code establishes conducts that the Firm expects of each member of the firm, officer, Executive Committee member, director, client and supplier, and any other person related to, or who does business with the Firm (“Interested Parties”).

Each Interested Party of the Firm is responsible for compliance with the applicable legislation and to act ethically. For this purpose, this Code is a guide intended to sensitize the Interested Parties with significant legal and ethical matters that frequently arise, with accessible mechanisms to report illegal or unethical practices.

Likewise, this Code is an instrument that assists us in ensuring compliance with our internal regulations, as well as all the legislation applicable to our business.

If you have any question regarding the Code or if you have any concern about some conduct that violates the policies of the Firm or applicable legislation, you can consult through the contact channels set out in the section on Contact and Complaint Channels of this Code. Nobody in this Firm has the authority to make exceptions to this Code.

Mission, Vision and Values

Mission:

Provide legal services and legal advice and consultancy of all kinds, to all persons, with honesty, responsibility, equity and equality and a humanistic and sustainable focus.

Vision:

Provide sustainable legal services for all persons, with a focus on diversity, equity and inclusion. Taking as a base the UN Sustainable Development Goals.

Values:

The values of this Code reflect our identity and the manner in which we conduct ourselves, governing our relationships with the stakeholders.

Honesty: We consider honesty a fundamental principle in providing our services. We uphold transparency, loyalty, and consistency, always in compliance with the law, both in Mexico and abroad.

Respect: We acknowledge the impact of our actions on our internal and external environments.

Tolerance: We embrace and accept differences, convinced that diversity of thought enriches our ability to provide comprehensive solutions.

Quality: Our focus is on delivering value to our clients. We continually study legislation and strive to improve our services.

Social Responsibility: We recognize our impact on our surroundings, aiming to create a culture of care and enhance the quality of life. We contribute to building a community and act as agents of positive change, fostering the full and integral development of all our colleagues. We are committed to promoting a fair, equitable, and sustainable society in line with the UN Sustainable Development Objectives. This commitment is integral to our culture and guides our actions towards the future.

Global Vision: We have the capability to serve clients in Mexico and abroad, supporting their expansion and globalization.

Legal Security: We respect the rights of all individuals and are dedicated to complying with the law.

Teamwork: We believe in the benefits of teamwork, promoting professional respect, collaboration, and a cordial environment among the members of the Firm.

Equity: We aim to create spaces where each person has the opportunity to grow and lead a fulfilling life.

Liberty: We acknowledge the uniqueness and irreplaceability of each individual. With honesty and sincerity, we accept the values and criteria of each person, respecting their liberty insofar it does not lessen the liberty of others.

Loyalty: We are committed to our values, principles, community, team, and clients.

Standards of Conduct

The compliance with applicable legislation is fundamental for the Firm. It is the responsibility of each of the Interested Parties to adhere to and comply with the legislation and with the standards of conduct and policies set out in this Code, as well as to report any violation thereof.

Work Environment

We treat all our colleagues with dignity, and we abide by compliance with the labor and employment legislation of respect, tolerance, cordiality an teamwork.

Persons are our priority, and therefore it is sour priority to ensure their wellbeing and the existence of a fair labor relationship at all levels of the Firm.

Anticorruption

No Interested Party must be involved, attempt to be involved or promote conducts connected with corruption. These conducts are forbidden in any relationship, directly or through third parties, with government entities, public officials, or representatives of the private sector.

For purposes of this Code and in conformity with the General Law of Administrative Responsibilities (Ley General de Responsabilidades Administrativas), some conducts identified as acts of corruption include: i) bribery; ii) illicit participation in administrative procedures; iii) influence peddling; iv) use of false information; v) obstruction of powers of investigation; vi) collusion; vii) improper use of public funds; viii) improper hiring of ex-public servants; and ix) infractions to private persons in special situations.

Anti-Money Laundering

We consider that the prevention of money laundering and the financing of terrorism as a fundamental priority or our operations. Our policy is based on the due diligence, the transparency and the strict compliance with the applicable laws and regulations.

We carry out a careful due diligence and identification of our clients and suppliers. This allows us to guarantee that our commercial relationships are transparent and free from illicit activities. In addition, we maintain complete and precise records of all the financial transactions and relevant documentation to guarantee the integrity of our operations.

Each Interested Party is responsible with complying with this Code and to abide by the Anticorruption and anti-money laundering policy of the Firm, and to immediately report any suspicious activity in accordance with the channels of reporting indicated in this Code.

Conflicts of Interest

A conflict of interest occurs when the personal interests of an Interested Party compete with the interests of the Firm and, consequently, may condition its independence, their impartial decisions, and their complete performance. If a conflict of interest occurs or if an Interested Party encounters a situation that may involve or give way to a conflict of interest, the Interested Party must report it to the Firm.

We have internal investigative procedures that allow us study the potential client to determine if some conflict of interest exists that prevents us rendering our services. We place ethics above economic interests, consequently we do not represent clients when a conflict of interest with the Firm, its colleagues or other clients exists which may compromise our ability to provide services and advise in an impartial, objective and for the benefit of the client.

Notwithstanding the above it is possible for us to represent a client, including when a conflict of interest exists, when the client in question is willing to consciously and freely assume the risks associated with this representation. In the Firm we implement strict measures of confidentiality protect the client’s information.

Protection of the Environment

We invite our Interested Parties, as well as all those that visit our offices, to comply with the applicable environmental legislation, conducting themselves in a responsible and sustainable manner, respecting the environment through basic actions, such as the collecting and classifying of office waste, the communication of messages in favor of care for the environment and the reasonable use of resources.

Diversity, equity, and inclusion

We are committed to treating persons with respect and to promote a workplace that defends diversity, equity and inclusion, non-discrimination, non-harassment and non-molestation, by means of internal regulations and policies that promote an inclusive culture in which persons are valued and accepted in identity and/or expression of gender, sex, age, race, physical capacity, sexual orientation, religion, way of thinking beliefs, ideology, appearance, ethnic origin, and culture; not accepting any act of violence and/or discrimination.

We have a zero-tolerance policy regarding any type of molestation or harassment in all areas, which may include, without limitation, intimidation, aggressive words or actions, derogatory jokes, inappropriate gestures, and undesired physical or verbal behaviors. We have implemented mechanisms and regulations that aloe us to prevent, identify and penalize any conduct that may be considered as molestation or harassment.

The Interested Parties must abide by the Diversity, Equity and Inclusion policy of the Firm.

Privacy and confidentiality of information

We consider privacy and confidentiality of information of our Interested Parties and, especially, of our clients, as one of the most important assets of our business. It is our obligation to protect the personal and confidential information of our clients, employees, suppliers and other Interested Party, maintaining such information in absolute secrecy. Notwithstanding the foregoing, the Firm may give out said information when required by law, competent authorities or provisions applicable to the business.

The confidential information may be shared with colleagues of the Firm or with third parties necessary fir the provision of our services. All persons with access to such information are obligated to maintain it in strictest confidentiality, even after the relationship with the Firm is ended.

The information that our clients share is only to provide precise and correct advice. In no way the Firm, its colleagues, or authorized third parties will benefit from this information.

The personal data that the Firm collects of the Interested Parties shall be treated in conformity with the privacy notice if the Firm which I available in [*], as well as in full compliance with the Federal Personal Data in possession of private persons Protection La w
(Ley Federal de Protección de Datos Personales en Posesión de Particulares) and its Regulation.

We have solid security measures to protect the confidential information and personal data of our Interested Parties from unauthorized access, loss, or theft, which are constantly reviewed and updated.

Firm Assets

We care for and respect the assets of the Firm, including tangibles and intangibles, so that we can carry out our services efficiently and transparently. Therefore, we understand that said assets, including the intellectual property and information of the Firm, must be treated with the utmost care to avoid losses, thefts or damage to the Firm or its Interested Parties.

Likewise, we care for, respect and protect the tangible and intangible assets of the Interested Parties, including our clients, deliver to our Firm, separating them from the assets of the Firm. If a client deposits funds in custody to the Firm to make payments on its behalf to third parties, we commit to using those funds exclusively for that purpose. In no case will they be used for different or illegal purposes that contravene this Code. All transactions carried out with client funds will be adequately documented.

Gifts and Hospitality

We maintain high ethical and integrity standards in all our commercial relationships. Our policy on gifts and hospitality is based on transparency, impartiality, and legislative regulatory norms.

We do not accept or offer gifts, entertainment or benefits that may improperly influence our commercial decisions, or which may be interpreted as an attempt to obtain preferential treatment.

Any offer of gifts or hospitality that fall within the limits of courtesy must abide by the Gifts and Hospitality of the Firm.

Financial Statements and Accounting

We understand that nay fraud in our accounting and/or financial information is illegal and an unethical conduct. Therefore, we maintain complete financial and accounting records in compliance with the requirements established in applicable legislation.

Contact and Channels for Complaints

This Code represents the base of our values and culture. Therefore, compliance with it is obligatory for all Interested Parties, who must abide by the principles and policies herein established.

We desire all our Interested Parties to report any conduct which fails to comply with the applicable legislation, this Code or the internal regulations and policies of the Firm.

Likewise, in case of doubt regarding interpretation of this Code, we invite the Interested Parties to go to the personnel of the Firm mentioned below who may provide guidance regarding the contents of this Code.

We value the assistance of the Interested Parties to identify any practice contrary to the values, principles and policies established n this Code. Consequently, we provide the following channels for complaints and the contact in case of doubts pr possible violations of this Code.

Cristina Lucia Sánchez Vebber
+52 5641743931
cristinasv@sanchezvebber.com

We shall carry out the necessary investigations in accordance with applicable legislation and internal procedures established by the Firm, for the purpose of determining is the acts complained of constitute noncompliance of this Code, maintaining, to the extent possible, confidentiality of the acts of the complaint, the parties involved and of the investigation procedure.

Likewise, if applicable, once the corresponding investigations have been completed, the Firm may take the necessary measures to prevent and/or penalize any conduct which is contrary to this Code, the internal policies and regulations of the Firm y applicable legislation, which may go, from a warning or wake-up call, to termination of the commercial or labor relationship or separation from the Firm, in accordance with the penalties established in the policies of the Firm.

We have a strict policy of no reprisals against the complainants that good faith report in good faith, conducts contrary to this Code. At the same time bad faith complaints will not be tolerated by the Firm.

The partners or Industrial partners of the Firm with knowledge of any act that violates o fails to comply with the provisions of this Code and pretend to cover it up or fail to report it in accordance with this section may be subject to penalties that the Firm may determine depending on the gravity of the case in question.

Revisions and Amendments

This Code shall be reviewed once a year from the moment of its publication in the communication channels of the Firm. Likewise, it may be amended or remedied as many times as is necessary at the request of Partners or the Executive Committee for the purpose of maintaining or updated in accordance with applicable legislation and internal regulations of the Firm.