Integrity, Anti-Corruption and Good Governance Policy

Artegia, S.C. (the “Firm”) practices in strict compliance with the law, professional ethics and the highest standards of integrity. This Integrity, Anti-Corruption and Good Governance Policy sets out that commitment and the rules that govern our dealings with clients, authorities, suppliers and any third party. Integrity is not negotiable: no result, client or fee justifies departing from it.

This Policy is binding on partners, staff, interns and anyone acting on behalf of the Firm. It is grounded in applicable Mexican law, in particular the General Law of Administrative Responsibilities, the Federal Criminal Code and the Federal Anti-Money Laundering Law, and in the international standards that govern many of our clients, such as the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.

The Firm prohibits offering, promising, giving, requesting or accepting, directly or through third parties, money, goods, services or any undue benefit to obtain or retain business, influence a decision or secure preferential treatment. This applies to public officials at any level of government, to foreign officials and to private-sector dealings.

We do not make facilitation payments, meaning payments intended to expedite procedures or actions that an authority is already required to perform.

The Firm does not accept engagements or fees to design, carry out or conceal fraudulent or unlawful acts. In particular, we do not take part in sham transactions, the issuance or use of tax invoices for non-existent operations, tax evasion, smuggling, money laundering, the alteration of documents or the submission of false information to any authority.

The tax planning we advise on is based on real transactions with a business purpose and substance, and on technically defensible positions. Where a matter or instruction is incompatible with this Policy, the Firm will decline or terminate the engagement.

Our dealings with administrative, tax, customs, labor and judicial authorities are institutional, transparent and conducted through legal channels. We defend our clients’ interests with technical arguments, never through undue influence, offers or pressure.

Only occasional courtesies of symbolic value, customary in a professional relationship and which neither create nor appear to create an obligation, are permitted. Gifts or hospitality will never be offered to or accepted from public officials, never in cash or equivalents, and never during an ongoing proceeding or negotiation.

Before accepting an engagement we verify that no conflict of interest exists. Any actual or potential conflict is disclosed to the client and, if it cannot be properly managed, the Firm declines to act.

We identify our clients and, where applicable, their beneficial owners, and apply due diligence measures proportionate to risk. We require suppliers, correspondents and external collaborators to meet the same integrity standard, and we do not engage third parties to do what this Policy prohibits us from doing directly.

Our fees are agreed in writing, invoiced with tax receipts reflecting the services actually rendered and received through bank channels. The Firm keeps complete and accurate accounting records and maintains no off-the-books funds or accounts.

Client information is protected by our duty of confidentiality and professional secrecy. It is used only to handle the engagement and is safeguarded with reasonable security measures, in accordance with our privacy notice.

The Firm’s donations, sponsorships and pro bono services are given transparently, to legitimate organizations and without expecting anything in return. They are never used to obtain an undue advantage. The Firm makes no contributions to political parties or campaigns.

Anyone may report in good faith a possible breach of this Policy by writing to [email protected] with the subject “Integrity”. Reports are handled confidentially, and the Firm does not tolerate retaliation against anyone who reports in good faith.

Any breach of this Policy will result in the appropriate disciplinary or contractual measures, including termination of the relationship, without prejudice to any applicable legal action. The Policy is reviewed periodically and approved by the Firm’s management.