GENERAL ANTI-CORRUPTION AND ANTI-BRIBERY GUIDELINE

At MARITIMEX, one of our core institutional principles is to conduct ourselves with integrity, professionalism, honesty, and ethics, within the framework of Social Responsibility—an honor we have proudly maintained for several years. We strive for all our internal and external collaborators to act in accordance with these principles and institutional guidelines, so that we may work together diligently to combat corruption in all its forms, including extortion and bribery, as stated in the tenth principle of the United Nations Global Compact.

The purpose of the guidelines set forth in this document is to prevent inappropriate conduct by MARITIMEX personnel, its directors, partners or shareholders, suppliers, and service providers at all hierarchical levels, and, where necessary, to identify and responsibly address any act of corruption in any of its forms.

All individuals working with MARITIMEX shall comply with and enforce the following guidelines:

• Compliance with Applicable Law: Conduct all activities, regardless of their nature, in accordance with the principles of integrity, professionalism, honesty, and ethics, and in alignment with the organization’s Social Responsibility.
• Anti-Corruption Practices: Promote and uphold practices that combat and prevent corruption to foster sound business relationships and fair competition, by defining, implementing, and documenting the functions of all departments.
• Prohibited Conduct: In accordance with MARITIMEX’s Mission, Vision, and Values, and applicable Mexican law, it is strictly prohibited to give or receive bribes, incentives, gifts, unofficial payments, favors, or recreational activities not directly related to business operations or services, whether directly or indirectly, to or from potential or current clients, suppliers, external service providers, government authorities at any level, judicial authorities at any level, and, in general, any individual or legal entity, whether national or foreign, public or private, for the purpose of unduly influencing or rewarding a decision or action that benefits MARITIMEX or any individual involved in the placement of products or services, or to secure any undue advantage.
• Financial Integrity: All financial transactions and daily activities involving the use of MARITIMEX’s financial and technical resources must be recorded in accordance with the guidelines of the organization’s administrative and financial departments, and must be made available for review in the event of internal or external audits of any kind.
• Donations and Sponsorships: Any donations or sponsorships carried out by MARITIMEX must be transparent and fully compliant with applicable laws.
• Decision-Making Based on Merit: Business decisions shall not be, nor appear to be, based on any form of relationship—be it familial, personal friendship, or otherwise—but will always be made based on the technical, financial, and professional qualifications of the third party, following internal selection procedures, and always in the best interest of the organization.
• Reporting Violations: Any MARITIMEX collaborator is obligated to report, anonymously if desired, any conduct believed to be in violation of this policy to the MARITIMEX suggestions, complaints, and whistleblowing mailbox, previously made known to all staff. All reports will be handled confidentially and objectively, and will be submitted to MARITIMEX senior management.

Consequences of Non-Compliance: Violations of these guidelines may result in civil or criminal liability for those involved.

REPRESENTACIONES MARÍTIMAS, S.A. DE C.V.
September 2024