Ethics code and anticorruption policy

This Ethics Code for ACCLAIM ENERGY MEXICO is not, nor does it pretend to be exhaustive.  Therefore, any unforeseen situations will be resolved according to the criteria for best practices in management and corporate governance.

Any additional issues that come from different situations in our business and from the dynamics of our environment in general, will be incorporated as needed.

The Ethics Code for ACCLAIM ENERGY MEXICO is based upon our Corporate Philosophy and comprises the following principles:

1. Perform the activities that our clients mandate with loyalty, respect, diligence, legality, objectivity, impartiality, efficiency, integrity, and honesty.
2. Respect the dignity, freedom, privacy, and rights of our employees, through fair, balanced, and honest dealings.
3. Protect the health and safety of our employees, our clients, and that of the communities in which our Company does business.
4. Avoid any type of discrimination, harassment, threats or abuse in dealing with our employees, partners, and clients.
5. Forbid child labor.
6. Avoid situations that could generate conflicts of interest in the relationship of our employees with the Company and in the relationship with our clients.
7. Adhere to the laws, and to any applicable regulations established by the government of the countries in which we do business.
8. Avoid acts of corruption, without exceptions, in any way.
9. Protect and make proper use of tangible and intangible assets of the company and those of our clients.
10. Not to take part in any agreement with clients, suppliers, nor competitors, which aims to limit the free flow of forces in the markets in which we operate.
11. Not making use of any Company assets for personal profit.
12. Provide technical, commercial, operational, and financial information that is accurate.
13. Protect the confidentiality and integrity of personal or privileged information from our employees and customers, making sure that there are not any non-authorized uses or access to it.
14. Advertise your services within the legal framework of decency, accuracy, and loyalty, for the benefit of our clients and open and fair competition in the market.
15. Protect the environment and make rational use of resources to perform our business activities.
16. Avoid participating as a Company, as well as using the Company’s assets or image in political-partisan activities.

ANTI-CORRUPTION POLICY

GOALS

Reaffirm in all employees and managers of ACCLAIM ENERGY MEXICO the mandate to perform their activities in line with ethical and integrity standards, complying at the same time with the anti-corruption laws, regulations and ethics applicable in the countries in which we do business, including, but not limited to, the U.S Foreign Corrupt Practices Act (FCPA).

Establish the basic rules, ethics and a general framework to prevent, detect, investigate, remediate, and, if required, punish any person who works in the Company or represents it, who has committed an act of corruption, in any manifestations and under any circumstances.

SCOPE

This policy if applicable to:

• ACCLAIM ENERGY in every country in which we do business.
• Every employee, executive, manager, or counselor in the Company, without regard of their hierarchy level or functions.
• Every person or entity that, either directly or indirectly, acts on behalf of the Company, as representatives, agents, consultants, advisors, referral partners, etc.
• Every contractor, subcontractor, supplier, referral partner and any person who does not represent the Company but provides any kind of service shall be notified of the existence of this policy and shall be encouraged to comply with it.

GUIDELINES AND PROCEDURES

• Definitions:

Act of corruption or bribery: To offer or to promise payment in money or valuables to any person, with the goal of influencing in a non-proper way any action or decision to obtain an undue business benefit or advantage for a person or a Company.

The mere act of promising or offering any type of undue compensation, even if the payment is not executed, constitutes an act of corruption.

Valuables: Gifts, invitations to entertainment events, travels and expenses, job opportunities, and other undue attention-seeking efforts.

• Guidelines

We will comply always and in detail with all anti-corruption laws, ethics and regulations applicable in all countries in which we do business, always honoring the value of honesty.

It is forbidden that employees, contractors, or representatives of the Company perform, instruct, approve, promise, conspire to perform, or induce any corrupt practices, either directly or through third parties.

Relationship with other Companies or entities

It is forbidden to offer, ask for, pay or accept any form of compensation in money or valuables from or to clients, suppliers, Companies or other organizations, with the aim of obtaining an undue business advantage.

Relationship with authorities

It is forbidden to offer any form of bribe to authorities, including government officials, employees or officials of parastatal Companies, members of political parties, candidates for public office, with the goal of inducing or obtaining an action or inaction to get and undue benefit or advantage for the Company or its clients.

Gifts and attentions

It is forbidden to offer or give valuables, either directly or indirectly, when these are above reasonable business practices, are considered inappropriate, or are not registered in the Company’s accounting records.

Accounting records

All accounting records will always follow applicable accounting laws and regulations, including anti-corruption laws and regulations.  Companies will keep accounting records in a way that accurately reflects every transaction to a reasonable level of detail.

Use of assets

It is forbidden to use any asset or resource of the Company for any activity that is illegal or contrary to the values of the Company.

DISCIPLINARY MEASURES

Complying with this policy is a necessary condition for getting and keeping employment in ACCLAIM ENERGY MEXICO.

Any employee or official with the Company who does not comply with this anti-corruption policy, will be subject to disciplinary measures, up to ending employment with the Company, and even being subject to legal measures before the competent authorities.

COMPLAINTS

Any employee or official with the Company who has information about an act of corruption or that there are indications of one, shall report this immediately to the CEO either in an anonymous or identified way, and shall inform their superior, in case they are not involved in the act or suspected act.  There will be zero tolerance for any retaliatory actions against any person who files a well-intentioned complaint.