At Maquiladora Gráfica Mexicana S.A. de C.V. (MGM), we understand ethics as a daily commitment that guides our decisions, relationships, and operations. This Code of Conduct summarizes the principles and standards of behavior that govern the actions of everyone who is part of or collaborates with the organization, both inside and outside our facilities.
Integrity, legality, and social responsibility are not optional—they are the foundation upon which we build trust with our employees, clients, suppliers, and communities. This document guides the prevention of legal, reputational, or labor risks, promotes a transparent organizational culture, and drives practices aligned with the highest national and international standards.
This Code is mandatory for:
It applies to all activities, facilities, channels, and physical or digital means, both in Mexico and abroad.
The Code is aligned with the Mexican Constitution, the Federal Labor Law, applicable NOM-STPS standards, the Federal Law on the Protection of Personal Data, ISO standards (26000, 37001, 45001, 14001), SMETA standards, and principles from the UN, ILO, and OECD.
Our organizational culture is based on principles such as:
These are reflected in our institutional values: commitment, collaboration, quality, innovation, empathy, transparency, and pride in belonging.
Maquiladora Gráfica Mexicana promotes a healthy balance between work responsibilities and personal or family life. We recognize that work-life balance:
Managers and supervisors must respect personal time and avoid unreasonable workloads or expectations beyond agreed schedules. Flexible work arrangements or support during family-related circumstances may be considered when applicable. We encourage a culture that values not only professional performance but also emotional health, family bonding, and personal growth.
All collaborators must act with professionalism, respect, and responsibility. This includes:
Those in leadership positions have an additional responsibility: to exercise their authority impartially, without favoritism or abuse of power.
3.1 4-EYES PRINCIPLE CORPORATE STANDARD:
All MGM contracts with a commercial or liability implication must be signed by the Managing Director and one of the following MGM key officers: the Operations Director, the Commercial Director, or the Finance Manager.
Ideally, contracts related to operational matters should be co-signed by the Operations Director; those related to sales topics by the Commercial Director; and those concerning finance or organizational matters by the Finance Manager.
In all cases, two signatures are mandatory for the contract to be valid.
Maquiladora Gráfica Mexicana is committed to transparent, accurate, and auditable financial management. All financial transactions must be:
It is strictly prohibited to:
Moreover, no MGM executive or employee shall purchase any vehicle that was leased or purchased under a company contract without the prior written approval of MGM´s Board of Director (BoD). Nor shall any executive or employee sign any contract to lease or purchase a vehicle on behalf of the company, or negotiate any terms or conditions for company cars, without such BoD approval.
Furthermore, no MGM employee or executive shall make any decision that goes beyond the ordinary course of business or incur any significant financial obligation on behalf of the company without the prior written approval ot the Board of Directors.
Employees involved in financial or administrative duties must uphold the highest standards of honesty and fiscal responsibility.
Company assets—technology, vehicles, facilities, materials, funds, and digital systems—must be used exclusively for work purposes. It is forbidden to:
• Use them for personal purposes.
• Damage them through negligence.
• Lend or transfer their use without authorization.
The acquisition, assignment, or disposal of any company asset whose individual value exceeds the threshold set in internal policies, including vehicles, must be authorized in advance through the appropriate governance and approval channels. Such decisions must align with corporate strategy and may not be taken unilaterally or outside the ordinary course of business.
Violations may result in compensation for damages, payroll deductions, or disciplinary measures.
Upon termination of the labor relationship, all resources in the person’s possession must be returned. Fulfillment of this obligation is required for issuing employment certificates or final settlements.
Only symbolic or courtesy gifts may be accepted if they:
Prohibited items include:
Are alternative rather than cumulative conditions.
Maquiladora Gráfica Mexicana strictly complies with international trade regulations including export control laws, customs requirements, and international sanctions.
All employees involved in logistics, procurement, or international operations must:
Failure to comply may result in legal penalties and severe damage to the company’s reputation.
MGM promotes a fair, inclusive, and safe work environment. We categorically reject:
We are committed to paying fair wages, complying with legal working hours, respecting rest rights, and providing safe and ergonomic working conditions.
Everyone at MGM must avoid situations where their personal interests could interfere with those of the company. This includes:
It is mandatory to declare potential conflicts and to refrain from participating in related decisions. The Ethics Committee evaluates cases and defines preventive measures.
We also maintain a policy of financial integrity: all transactions must be properly recorded, documented, and auditable. Alteration of records, embezzlement, or concealment of operations is strictly prohibited.
MGM adopts a zero-tolerance policy towards any form of corruption, bribery, extortion, collusion, or influence peddling, whether in dealings with public or private entities.
The following are strictly prohibited:
Only symbolic, low-value gifts may be accepted, and only with prior authorization. Cash, luxury invitations, or favors that compromise objectivity are not permitted.
All suspicious cases must be reported through official channels, with guaranteed confidentiality and non-retaliation.
Suppliers and contractors are required to sign ethical compliance clauses. Breaches may result in contract termination and potential legal action.
The handling of personal, strategic, and operational information is governed by the Federal Law on Protection of Personal Data and the General Data Protection Regulation (GDPR), where applicable.
All personnel must:
Signing confidentiality agreements is mandatory. Loss, misuse, or leakage of data may result in disciplinary and legal consequences. Intellectual property (software, designs, processes, trademarks, patents) must be respected. Reproduction or use without express authorization is prohibited.
The protection of intellectual property (IP) is essential to our integrity, competitiveness, and innovation.
All employees must:
The life and well-being of our collaborators is a priority. MGM implements an Occupational Health and Safety Management System aligned with ISO 45001.
Personnel must:
We also implement an Environmental Management System (ISO 14001), focused on minimizing impacts, optimizing resources, and complying with environmental laws. We promote recycling, energy efficiency, and responsible waste management.
Everyone is responsible for maintaining a safe and sustainable work environment.
Maquiladora Gráfica Mexicana promotes an inclusive environment where diversity is seen as a strength. We are committed to ensuring equal treatment and opportunities for all people, regardless of:
Discrimination is prohibited at all stages of the employment cycle: from recruitment to termination. We also reject stereotypes, offensive comments, and jokes disguised as humor.
We actively promote the inclusion of traditionally excluded groups (women, persons with disabilities, at-risk youth, Indigenous peoples, older adults).
All discrimination reports will be treated confidentially, fairly, and without retaliation.
We maintain ethical, transparent, and legal relationships with all our external partners. Supplier selection is based on objective criteria: quality, price, regulatory compliance, and ethical commitment.
Third parties are required to:
Favoritism or unjustified preferential treatment is not permitted.
We promote a culture of professional, empathetic, and timely attention. Courtesies or gifts are subject to authorization and must not compromise impartiality. Unfair competition, defamation, and industrial espionage are prohibited.
Any collaborator or third party who becomes aware of conduct that violates this Code may—and should—report it. MGM ensures accessible, safe, and confidential channels, including:
Reports may be anonymous or identified. They are investigated impartially, respecting due process and the dignity of those involved.
Retaliation is not tolerated against those who report in good faith. Malicious or bad-faith reports will also be sanctioned.
Reports contribute to process improvement, policy review, and control strengthening.
Non-compliance with the Code constitutes a labor offense and may be sanctioned based on its severity and in accordance with the Internal Work Regulations. Sanctions may include:
Factors such as intent, recurrence, impact, and cooperation during investigation will be considered.
There are no exceptions based on rank: the Code applies equally to all individuals, regardless of level, seniority, or position.
Sanctions are intended to correct behavior, prevent harm, and protect organizational values.
The Code is provided upon entry into the company, disseminated through internal channels, and included in ongoing training programs. All personnel must know, understand, and apply it.
The company may conduct knowledge evaluations, request signed acknowledgments, and carry out periodic reviews to keep it up to date. The current version is mandatory from the date of publication.
FINAL COMMITMENT
This Code represents more than a regulation: it reflects who we are as an organization and what we aspire to be. Every signature, every ethical action, every aligned decision strengthens our collective identity.
Acting with integrity is not an option. It is our duty.