Add Commitment to Legality section
(Anti-Corruption Statement)

Dear Elementia Employee,

Elementia has always established a strong commitment to the policy and practice of compliance with all laws and regulations in force, by both the letter and purpose, in each country in which we operate. The three values of our company are Integrity, Respect and Commitment, and our philosophy is integrated in the Focus on results, Innovation, Safety and Teamwork. As part of the commitment to our values and our philosophy, Elementia has always use its best efforts to maintain the highest standards of integrity and ethical conduct in our relationships with our shareholders, employees, representatives, vendors and competitors, and with the government and the public in general. Each of us is responsible for continuing to maintain these high standards in all of our daily business activities.

This Code of Ethics (hereinafter the Code) has been adopted by the Elementia's Steering Committee and is valid for each member of the Elementia's Steering Committee and for each employee in every country in which Elementia operates. The purpose of the code is to present, in a document, some of our current policies and practices related to our company's conduct and, in turn, to further promote the lawful and ethical conduct of Elementia employees and to discourage dishonest behavior.

The business environment has never been more challenging or complex, particularly for a company such as Elementia, which operates in several countries. Now more than ever, it is necessary for each of us to understand our individual responsibility regarding strict compliance with all legal requirements and the highest ethical standards, and, by means of a corporate culture that recognizes the need and convenience of complying with these standards, Elementia can expect to continue to succeed in the future. We recommend that you use this Code to help you address issues as they arise and to know any concerns or questions that you may have, either through the hotline or any of the other communication means described in the Code.

One of the established guiding principles urges each of us to "Fully perform the corporate citizenship obligations, contributing to the welfare of society and the environment in which our company operates". Thank you for your commitment to contribute together with us to maintain the long tradition of ethical conduct of Elementia and continue to strengthen the valuable goodwill and honesty and integrity of Elementia.

Fernando Ruíz Jacques
General Manager

Accommodation and Travel Expenses

Elementia has established policies for the management of travel expenses arising from specific needs of operation, ranging from the planning of trips to the verification of the expenses incurred in them.

Gifts

Employees will select and treat people or firms that do or intend to do business with the Company in a totally impartial manner, with no consideration other than the interests of the Company.

You are expected to avoid any involvement or situation that could interfere, or even appear to interfere, with the impartial performance of your obligations. This means that neither you nor any member of your family will request or accept from any Representative, vendor or other person who does or intends to do business with Elementia any loan, or gift, entertainment or favor of a face value greater than $100 or its equivalent in the local currency, or that otherwise exceeds, in size or cost, the usual courtesies consistent with the ethical business practices and the usual local business practices. Certain Elementia business units or local markets may adopt stricter policies regarding gifts, loans or entertainment. If you have any question, before accepting a gift, consult your supervisor.

In general, any Employee who is offered or receives a gift of high face value must reject it kindly or return it to whoever sent it explaining Elementia's policy against the acceptance of gifts. Keep in mind that the frequency with which gifts are offered and accepted - even those of low face value - must be taken into account when deciding whether or not is appropriate to accept a particular gift. Any appearance of possible failure should be avoided.

Prevention of Internal Fraud

Books and Records; The Right Settlement of Transactions

It is essential that the financial statements of the Company and all the books and records in which they are set down are complete and accurate so that they reflect the actual state of our business and account for the actual nature of all disbursements and other transactions at all times. This is mandatory, regardless of whether those records reveal disappointing results or a failure with respect to the expected profit levels It is a violation of the Code to do anything that compromises the integrity of Elementia's financial statements or other business records.

No attempt to hide the actual results, by reflecting incorrectly, for example, income, expenses, assets or debts, cannot be tolerated and will not be tolerated. Failure to comply with these regulations may constitute a violation of civil and criminal laws.

Protection and Proper Use of the Company Assets

Each Employee is responsible for protecting the Company assets against loss, theft and misuse. Loss, theft and misuse of the Company's assets have an impact on the profitability of Elementia.

Any theft (regardless of the amount in dollars that it represents) and any significant loss or misuse of the Company's assets must be reported to your manager or supervisor, the Legal Department or the Corporate Internal Audit Department or any member of the Compliance Committee. See "Confidential Information and Information Protection" above.

All of the Company's assets, including its equipment, vehicles, supplies and products, shall be used only for legitimate purposes in the course of Elementia's business.

Donations

Elementia cannot make contributions or donations, directly or indirectly, to political parties, electoral campaigns, unions, public entities or Public Officials, in any country where it operates.

Scope of the Code of Ethics and Integrity Policy

The Code of Ethics and the Integrity Policy are applicable to Employees, Managers, Agents and Business Partners.

Conflict of Interest

Conflict of Interest is a situation that occurs where a person's personal, labor, professional, family or business interest may affect the impartiality and objectivity of the exercise of their duties; and it occurs when the interests of a person could interfere with the performance of their activities, obtaining a benefit or advantage for themselves, for family members or for a third party ("Conflict of Interest").

Undue Payments and Bribery

The payment of bribes and retributions to government officials, vendors and others is strictly prohibited. Gifts, entertainment, and occasional business favors to Non-governmental employees in connection with negotiations or the development of business relationships are generally considered appropriate within the conduction of the Company's business if they are (i) legal, (ii) infrequent, (iii) are not cash or cash equivalents, (iv) are of low face value, $100 dollars or its equivalent in the local currency in question, (v) are consistent with the usual practices of the country in question and (vi) would not represent a sense of shame for the Company if they were publicly disclosed.

Training

Elementia has training systems for Directors, Employees, Managers, Agents and Business Partners on Anti-Corruption and Integrity matters.

Consequences

Elementia has a policy of consequences to guarantee the honest, ethical and professional actions of its employees to society.

Reporting

The Compliance Committee will be responsible for answering questions, doubts, and comments about the Code of Ethics, as well as for dealing with and investigating reports or complaints received, and for sanctioning in accordance with the consequence system policy.

The Directors and Employees may submit a report to the Compliance Committee, if they have a reason to believe that an Employee has violated or appears to violate any internal regulations of Elementia or applicable law, through the following means:

  1. a. By entering the Reporting Mailbox available on the Elementia Intranet; or
  2. b. By sending a message to the Elementia Compliance email: "comite.cumplimiento@elementia.com"; or
  3. c. By mailing the information to the Compliance Committee, addressed to Elementia, S.A.B. de C.V., C/O: Elementia Compliance Committee, Lago Zúrich 245, Piso 20, Col. Ampliación Granada, C. P. 11590, Delegación Miguel Hidalgo, Mexico City, Mexico.

The reporting mailbox and the compliance email, as well as the mailbox, are protected in such a way that only Members of the Compliance Committee can access the messages delivered by these means.

The Compliance Committee is the body in charge of investigating the reports submitted to it and, where appropriate, sanctioning them in accordance with the consequence system policy.

Non-Retaliation

Elementia will not tolerate retaliation of any kind by any director, executive or other Employee, or by a vendor or external contractor following a report that has been submitted in good faith.

In addition, Elementia will not tolerate retaliation or other measures taken against any Employee that provides a police officer with accurate information related to the possible commission of a civil or criminal offense or that participates in the investigation by Elementia or governmental authorities of behaviors that are reasonably considered by the Employee to constitute securities fraud in accordance with the securities laws in Mexico, the United States and the countries where it has business.