1. INTRODUCTION

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.

  1. SCOPE OF APPLICATION

This Code is mandatory for:

  • All operational, technical, administrative, executive, and managerial personnel.
  • Contractors, suppliers, commercial representatives, visitors, and partners.
  • Any person who directly or indirectly has a relationship with MGM.

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.

  • ETHICAL PRINCIPLES AND VALUES

Our organizational culture is based on principles such as:

  • Integrity: Doing what is right, even when no one is watching.
  • Legality: Strict compliance with the law.
  • Respect: Promoting dignity and inclusion.
  • Justice: Acting with fairness and impartiality.
  • Social responsibility: Actively contributing to environmental and social improvement.
  • Loyalty and accountability: Acting consistently and accepting consequences.
  • Sustainability: Making decisions with awareness of future impact.

These are reflected in our institutional values: commitment, collaboration, quality, innovation, empathy, transparency, and pride in belonging.

  • WORK-LIFE BALANCE.

Maquiladora Gráfica Mexicana promotes a healthy balance between work responsibilities and personal or family life. We recognize that work-life balance:

  • Enhance employee well-being and satisfaction
  • Increases productivity and reduces absenteeism
  • Supports inclusion and gender equality

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.

  • EXPECTED CONDUCT

All collaborators must act with professionalism, respect, and responsibility. This includes:

  • Punctual and honest fulfillment of assigned tasks.
  • Respectful treatment of colleagues and third parties.
  • Responsible use of institutional resources.
  • Dignified representation of the corporate image.
  • Rejection of any form of violence, harassment, or discrimination.

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.

  • FINANCIAL TRANSPARENCY AND ACCOUNTABILITY

Maquiladora Gráfica Mexicana is committed to transparent, accurate, and auditable financial management. All financial transactions must be:

  • Duly recorded, documented, and traceable.
  • Based on real, lawful, and authorized operations.
  • Subject to internal controls and audit processes.

It is strictly prohibited to:

  • Alter accounting records.
  • Conceal income or expenses.
  • Engage in fraud, embezzlement, or misuse of funds.

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.

  • RESPONSIBLE USE OF RESOURCES

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.

  • GIFTS, INVITATIONS AND BUSINESS COURTESIES

Only symbolic or courtesy gifts may be accepted if they:

  • Have a low economic value (e.g., less than $1,000 MXN).
  • Do not generate obligations or dependency.
  • Are authorized by the immediate supervisor or compliance office.

Prohibited items include:

  • Cash or cash equivalents.
  • Invitations to trips, shows, or events without professional justification.
  • Concealed donations.

Are alternative rather than cumulative conditions.

3.5   TRADE COMPLIANCE AND EXPORT CONTROLS.

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:

  • Know and follow applicable import/export restrictions
  • Refraining from engaging in activities with sanctioned countries or entities
  • Report any suspicious transaction or commercial irregularity

Failure to comply may result in legal penalties and severe damage to the company’s reputation.

  • HUMAN AND LABOR RIGHTS

MGM promotes a fair, inclusive, and safe work environment. We categorically reject:

  • Child labor (under 18 years of age).
  • Forced or coercive labor.
  • Violations of freedom of association or collective bargaining.
  • Any form of discrimination (based on gender, age, ethnicity, sexual orientation, religion, disability, etc.).
  • Undignified working conditions, physical, verbal, or psychological abuse.

We are committed to paying fair wages, complying with legal working hours, respecting rest rights, and providing safe and ergonomic working conditions.

  • CONFLICTS OF INTEREST AND TRANSPARENCY

Everyone at MGM must avoid situations where their personal interests could interfere with those of the company. This includes:

  • Favoring family members in employment decisions.
  • Maintaining external activities that compete or conflict with their responsibilities.
  • Using internal information for personal benefit.

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.

  • ANTI-CORRUPTION AND ETHICAL BUSINESS PRACTICES

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:

  • Offering or accepting money, gifts, favors, travel, donations, or benefits to influence decisions.
  • Using intermediaries to conceal improper acts.
  • Manipulating bidding or hiring processes.

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.

  • DATA PROTECTION AND CONFIDENTIALITY

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:

  • Use data only for authorized work-related purposes.
  • Avoid unauthorized disclosure.
  • Protect the physical and digital means where data is stored.

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.

  • INTELLECTUAL PROPERTY AND INNOVATION.

The protection of intellectual property (IP) is essential to our integrity, competitiveness, and innovation.

All employees must:

  • Respect the company’s trademarks, patents, copyrights, and trade secrets.
  • Avoid unauthorized reproduction, copying, or use of software, brands, or creative content.
  • Acknowledge the ownership of inventions and innovations developed during employment.
  • We also commit to respecting the IP rights of third parties and avoid plagiarism or infringement in any form.
 
  • HEALTH, SAFETY, AND ENVIRONMENT

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:

  • Follow protocols and use personal protective equipment.
  • Report risks, accidents, or unsafe conditions.
  • Participate in training, drills, and evaluations.

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.

  • DIVERSITY, INCLUSION, AND NON-DISCRIMINATION

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:

  • Gender, sexual orientation, or gender identity
  • Age, health condition, or disability
  • Race, ethnicity, religion, ideology, physical appearance, or socioeconomic status
  • Political or union affiliation

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.

  1. RELATIONSHIPS WITH CLIENTS, SUPPLIERS AND THIRD PARTIES

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:

  • Know and respect this Code.
  • Sign compliance clauses or commitment letters.
  • Act with legality, integrity, and social responsibility.

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.

  1. REPORTING MECHANISMS AND WHISTLEBLOWER PROTECTION

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:

  • Physical reporting mailboxes
  • Institutional email: eticalaboral@mgmex.com.mx
  • Direct contact with Directive committee, including HR and Managing Director

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.

  1. DISCIPLINARY MEASURES

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:

  • Verbal or written warnings
  • Temporary suspensions
  • Termination of the labor relationship
  • Legal actions if the offense constitutes a crime

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.

  1. DISSEMINATION, UPDATING, AND SIGNATURE OF ADHESION

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.