Constructora Amaco

Code of Ethics

Background

Prior to this manual, middle-management personnel were given a talk about not engaging in acts lacking in "ethics" or involving "corruption" when interacting with clients and suppliers; likewise, field personnel were told that under no circumstances may they be disrespectful toward the company's female personnel, or toward clients, suppliers, or any person present at or passing through the job site.

Objective

General objective

The main objective of this Code of Ethics and Conduct is that the behavior of those who interact with the company must be consistent with the corporate values that form part of the behavior approved within the company, specifically clients, suppliers, and employees; these values are a guide for our daily professional conduct and show us the upright way to act in the different situations that may arise.

Specific objectives

Create and instill preventive behavior to avoid actions that are unethical or outside the corporate values, defining procedures, regulations, and values, and informing all personnel in order to create an ethical environment.

Breaches of the values of the Code of Ethics and Conduct will be monitored and identified for their continuous evaluation.

Once breaches of the code are detected, they will be remedied and updated in this document.

Purpose

The main purpose of this document is to set out the conduct and ethics that safeguard corporate standards of behavior in the internal relations of our personnel and in their dealings with clients, shareholders, partners, investors, employees, suppliers, and everyone connected with the company.

This code is strictly binding for everyone involved in the company, and it also extends to subcontractors, suppliers, consultants, or service providers for the company whose actions could result in conduct contrary to the established ethical values.

It defines the accepted practices and the models of integrity that must be followed when working at Constructora Amaco, regardless of one's level in the company.

This code defines the values of our company, Constructora Amaco, which must be known by everyone who belongs to the company; compliance with these values is meant to improve the way we act in our professional development.

It also sets out the basic ethical definitions for decision-making in professional conduct, avoiding putting personal interests first and favoring the interests of the company.

Definitions

Conduct: The way a person behaves in a given situation or in general

Corruption: Abuse of any public or private position in order to generate an undue private benefit at the expense of collective or individual well-being.

Integrity: Doing what is right without harming the interests of third parties; moral uprightness, the opposite of corruption.

Mission

To offer the best service and quality in the construction and development of infrastructure projects

Vision

To be the best construction and project company for infrastructure development nationwide.

Values

Quality

Determined by all AMACO members, both internal and external, and driven by the philosophy of adding value for our clients.

Back to contents

Honesty

At AMACO it is a human quality that consists of behaving and expressing oneself with sincerity and consistency, respecting the values of justice.

Back to contents

Responsibility

At AMACO we know that responsibility means understanding that a set of guidelines and rules must be respected, as well as contributing to the growth and harmony of the environment in which we operate and of the people we interact with.

Back to contents

Trust

At AMACO, trust is the key word that must guide relationships among people throughout our company, since the objectives pursued are shared and everyone must work to achieve them together.

Back to contents

Commitment to the environment

Construction activity has a permanent impact on the environment, so we seek to reduce and remediate to a minimum the impact of construction processes on the environment, always offering in our projects the possibility of having the work certified under an international standard.

Back to contents

Integrity

This value is fundamental for Amaco; the rules of integrity dictate our behavior toward authorities, clients, and the other groups we interact with, setting out the interaction guidelines that reflect ethical behavior and provide evidence of our personnel's conduct

Back to contents

Conduct that governs us

Social commitment is the driving force and incorporates permanent responsibility with regard to the social, economic, and environmental conduct of stakeholder groups, involving every level of the company: partners, executives, administrative staff, and operational staff.

Harassment and mistreatment

Abuse of authority or power is not tolerated under any circumstances, nor is violence among employees or toward third parties.

Harassment, hostility, or sexual abuse in any form is not tolerable in any case, whether insinuation, verbal, or physical, including requests for sexual favors conditioned on any favor in order to obtain a benefit.

Any situation of harassment or mistreatment is unacceptable and must be reported to the Ethics and Social Responsibility committee.

Back to contents

Corruption and bribery

Bribery is strictly prohibited; that is, employees are prohibited from engaging in any form of corruption, including extortion and active or passive bribery, and no employee may make or receive unlawful payments with any party related to Constructora Amaco S.A. de C.V.

Back to contents

Training

The integrity training program is permanent and for everyone; courses are scheduled to ensure the development of all employees on this subject, mainly regarding compliance with the Code of Ethics and Conduct.

Our personnel are selected for training using a risk-based approach, considering their areas of responsibility and their position in the organization.

There is a training program with dates set throughout the year.

Back to contents

Drugs and alcohol

All personnel are hereby informed that any use, distribution, or sale of drugs or substances prohibited by law is strictly forbidden. As for alcoholic beverages on the premises or at work sites, they are prohibited by the Ley Federal del Trabajo (Federal Labor Law) and by this Code of Ethics and Conduct; likewise, entering the premises or work areas in an unfit state, under the influence of drugs or alcohol, is prohibited.

Back to contents

Health and safety

Personnel working at Constructora Amaco are responsible for maintaining and creating safe, healthy work environments and for adhering to the labor laws of the country and of our clients; they are also encouraged to keep work sites orderly and clean, since this eliminates risks, and management will support this at all times.

Back to contents

Honesty and legality

We must always conduct ourselves within the parameters of honesty, legality, and transparency in all transactions, obligations, and commitments with our employees and third parties. We will keep abreast of initiatives from government bodies and business associations related to our activities, and we will take part in projects of social benefit.

Back to contents

Gender equality

There is no distinction between women and men; the same job opportunities and possibilities will be maintained, along with equal access to institutional benefits and to opportunities within the company's development, in compliance with our compensation policy for the company's partners and executives.

Back to contents

Inclusion

There is no distinction in the hiring of people from vulnerable groups for the positions in which they can perform.

Back to contents

Integrity

Constructora Amaco's executives, supervisors, and site managers are honest and upright in labor and business relationships, committed to values and ethics in carrying out their work.

Back to contents

Leadership

Site managers, executives, and administrative staff with personnel under their charge will always address their subordinates in a respectful and impartial manner, and will maintain continuous communication in order to work as a team and fulfill what the company entrusts to them.

Management, and in turn middle management, will provide optimal working conditions in accordance with the requirements of the work performed.

The company has channels for detecting risk situations.

Back to contents

Handling of confidential information

Information of a confidential nature must be kept secret, and the exchange of information for personal gain is prohibited; the Privacy Notice is available at the following link http://amaco.com.mx/contacto/

Back to contents

Relationship with shareholders and partners

The shareholders and partners of Constructora Amaco will seek to obtain the best financial returns in line with what the market offers, always seeking the preservation of their assets in the short and long term, creating transparency for all shareholders and partners.

Back to contents

Relationship with our competitors

Our relationship with our competitors will be honest and upright in all areas; the laws on competition and the values and principles of Constructora Amaco will always be respected.

Back to contents

Relationship with clients

Clients are the main reason for our existence; upholding our values with our clients, who place their full trust in us, is our main commitment to them.

We must guard against and avoid at all costs any kind of corruption, bribery, harassment, or any situation that falls outside proper morals.

We will always be attentive to all the suggestions, improvements, and observations our clients share with us.

We will make this Code of Conduct and Ethics known to our clients and will recommend that activities always be carried out within this framework.

Back to contents

Relationship with our community

We will always be committed to caring for, and under no circumstances harming, the place where our business activities take place.

Back to contents

Relationship with our suppliers

Suppliers trust that our relationships with them will be conducted under our ethical and honest values, without abetting anything illegal.

Any relationship between our employees and a supplier must be reported to and authorized by the Management of Constructora Amaco.

When selecting a supplier, price and the quality of the products or services will be taken into account, and long-term relationships will be sought.

Care will be taken to ensure that our suppliers do not engage in illegal practices such as money laundering, breaches of environmental policies, or the employment of minors, in accordance with current legislation.

No employee or partner, nor any family member of theirs, may receive money, gifts, services, discounts, trips, etc. from a supplier.

Back to contents

Relationship with the government

One of our clients, directly or indirectly, is the Government, so Integrity will be safeguarded during 2020 and in subsequent years; the codes of conduct and ethics will be rigorously followed, and any act involving corruption or bribery will likewise be avoided.

Back to contents

Relationship with our employees

At Constructora Amaco, all personnel will be treated with respect and their professional development as individuals will be looked after, always seeking to retain our personnel and making dismissal the last option.

Back to contents

Accountability

Everyone who works at Constructora Amaco must be committed to integrity, honesty, transparency, equality, and loyalty in accountability, and this must be consistent with the activities carried out.

Back to contents

Respect for human rights

At Constructora Amaco we are committed to respecting human rights; we guarantee, promote, and protect them in accordance with the United Nations Universal Declaration, emphasizing those related to: the right not to be subjected to slavery, servitude, or forced labor; the right to freedom of expression; the right to form or join a trade union; the right to health; and the right to fair and satisfactory working conditions.

Back to contents

Respect for the environment

Construction processes have an impact on the environment, so environmental laws and regulations will always be complied with.

The waste generated must be treated as required by law.

Back to contents

Corporate social responsibility

Social Responsibility is a commitment of Constructora Amaco, as are regulatory compliance and respect for ethical values, the community, and the environment.

If an employee wishes to take part in activities that contribute to the development of the community, they will be supported, while seeking to ensure that this does not interfere with the performance of our duties.

Back to contents

Sense of belonging

Supervisors, site managers, and administrators will receive leadership training to improve their relationship with the personnel under their charge.

Constructora Amaco promotes activities, workshops, and team building in shared social areas with all personnel.

Constructora Amaco promotes integration through events, talks, and recreational activities among employees and their families.

Back to contents

Forced labor

We are committed to and work in accordance with the International Labour Organization to prohibit forced or compulsory labor; our work arrangements are characterized by:

- NO to prison labor - NO coercion of the freedom to work and to end the employment relationship - NO violence, harassment, or intimidation - NO coercion in the payment of wages - NO disciplinary sanctions that violate human rights - NO mandatory overtime outside the law - NO restrictions on physical freedom of movement - NO conditions placed on opportunities for professional education and training - NO to child labor within Constructora Amaco, with monitoring of our critical suppliers

Back to contents

Transparency in the selection process

Decisions related to hiring personnel are based on skills, attitudes, aptitudes, ability, experience, and alignment with the company's values; under no circumstances is anyone discriminated against on the basis of sex, race, age, color, ethnic origin, or any other factor.

Back to contents

Use of company work equipment

Theft is not tolerated under any circumstances, especially of goods, equipment, or tools, as well as information belonging to the company or to other employees within the premises; it may result in the termination of the employment relationship and in criminal proceedings.

No employee may engage in personal activities during working hours that interfere with or prevent them from fulfilling their job responsibilities, nor use the company's computers or machinery for outside business, or for illegal or unethical activities such as gambling, pornography, or other offensive matters.

Back to contents

Efficient use of resources

Employees are responsible for using the resources provided by the company efficiently and must guard against wasting them. Resources must be looked after to the utmost, and neither the company's name nor its resources may be used for personal gain.

Back to contents