DEAR FRIENDS:

It is a pleasure for me to present to you our CODE OF ETHICS, in this document you will find the principles, values and commitment adopted by all those who are part of our company to ensure continuous improvement and satisfaction of our customers as well as respect for the individual guarantees of those who directly and indirectly are related to our company.

Our mission is summarized in providing quality and safe products that meet the specifications and needs of our customers, therefore, our main policy is to be authentic for which we adopt a high sense of ethics in compliance with national and international regulations governing the food industry.

This CODE OF ETHICS is communicated to all the participants of the business and mainly to all the members of the organization, who must be a faithful reflection of the values, norms and policies that govern us, being this document a tool that serves us to achieve the objectives in the short, medium and long term having as main goal the protection of the interests of our investors, members of the organization, as well as our customers and business partners.

As top management, I am committed to adequately and efficiently provide the necessary resources for the fulfillment of this document.

Please note that for OUR ORGANIZATION, your opinion is very important, so I reiterate that I am open to listen to your suggestions and actions for the improvement of the Organization.

Without further ado, I remain at your service in the hope that this document will serve to increase the bonds of trust, and to let you know that we are committed to fair treatment, respect, honesty, integrity and business ethics at all levels.

Lic. JAVIER ZAÑUDO QUINTERO

Chief Executive Officer

EDULAG SA DE CV

 

INTRODUCTION.

This code is the foundation of the image of the ORGANIZATION, in it you will find the rules, policies and guidelines to be followed for business and professional activities.

We have established as ETHICS POLICY:

THAT ALL BUSINESS WE CONDUCT IN MEXICO AND ABROAD IS HONEST AND IN COMPLIANCE WITH BUSINESS ETHICS AND IN ACCORDANCE WITH NATIONAL AND INTERNATIONAL LAWS AS WELL AS THE AGREEMENTS AND SPECIFICATIONS MADE WITH EACH OF OUR CLIENTS.

By working in this way we will achieve our goals and objectives, making our commercial relationships with our customers stronger and more lasting, creating trust and therefore generating a good reputation within the food industry.

This CODE OF ETHICS belongs to all of us who are part of THE ORGANIZATION, may this document be the one that directs your steps within the activities of our organization. May each of our members demonstrate the values and principles that are the foundation of THE ORGANIZATION, may we promote an honest and upright work environment in compliance with the respect for Universal Human Rights, demonstrating our leadership in the food industry.

OUR VALUES.

The values of our company are our differential element, based on internal ethical values, adopted by all members of the organization, which have made our successes endure.

WORK: Whether it happens depends on oneself.

SUPERIOR QUALITY: Getting it right the first time.

LEADERSHIP: Working for the common good

TEAMWORK: we collaborate genuinely and mutually adding efforts to achieve the objectives with the different areas and people of the organization.

INTEGRITY AND HONESTY: We assume that there is only one truth and we are congruent with what we say and do.

PASSION TO IMPROVE AND INNOVATE: We look for improvement opportunities to do things better by seeking opportunities to add value to our work.

MISSION:

We are a Socially Responsible company, committed to the environment, society and our employees, we produce and sell ORGANIC AGAVE SYRUP AND AGAVE INULINA to the international market, safe for human consumption, complying with the most demanding quality standards in the market.

VISION:

To be a leading company in the production and sale of ORGANIC AGAVE SYRUP AND AGAVE INULIN, socially responsible, with safe products for human consumption, transmitting our leadership for the benefit of all members of the organization, improving their quality of life and providing development opportunities.

FAIR TRADE POLICY:

The ORGANIZATION, committed to social responsibility, adopts standards of fair and ethical trade in the commercial exchange, building sustainable development and human potential of the members of the organization.

Our objective is to develop a win-win culture throughout the food chain, where the organization’s investors see their efforts remunerated in profits, where employees, all committed to the organization, have an increasingly better quality of life and contribute to better development opportunities for their children.

The management is convinced that the success of the organization and the quality of the products produced are based on the efforts and commitments of our people, therefore, adopting these principles helps us to the sustainable development of our organization, guaranteeing the satisfaction of our customers.

GENERAL OBJECTIVE.

The purpose of this document is that the members of our organization have the tools provided by senior management for good business conduct, in this document you will find the guidelines and guidelines for fair production and business, as well as solve potential problems, always placing our decisions in the values of the company within a concept of SOCIAL RESPONSIBILITY AND BUSINESS ETHICS that binds us all members of THE ORGANIZATION, in order to promote respect among employees avoiding harassment, promoting communication between hierarchies, a pleasant working environment, dignified and productive towards the growth of our organization.

SCOPE.

This code of ethics does not replace any internal POLICY or Procedures Manual, it is of a mandatory nature for the Board of Directors, Managers, Chiefs, Area Managers, Supervisors, Operators and any person who directly or indirectly represents EDULAG S.A. DE C.V. and PENTAGONO AGRICOLA S.P.R. DE R.L., hereinafter and for explanatory purposes in this document referred to as ORGANIZATION, whether by labor contract, fees, salaries or commissions. It is the responsibility of each Member of the ORGANIZATION to duly comply with our CODE OF ETHICS.

COMPLIANCE.

Compliance with this code of ethics is carried out by the supervision and periodic evaluation of the different hierarchies supported by the management of the company and the administrative committee, all members have the function of ensuring compliance and constantly monitor compliance with this document in their competence.

We are all obliged to collaborate in case of reviews and audits by providing the necessary information and we must also collaborate in the actions implemented for the irregularities found. The management is obliged to provide the necessary resources for the implementation of such actions.

All members have the obligation to communicate any breach or omission of the CODE OF ETHICS and the Individual Guarantees to the corresponding superior hierarchy and to the person in charge of business ethics compliance, as established in the internal communication procedure.

PRINCIPLES OF ETHICS EDULAG

  1. HUMAN RIGHTS

In EDULAG SA DE CV, we defend the form of the principles and fundamental rights in the work as it marks the National Laws of Labor and Social Welfare, as well as the principles of Human Rights, so we reject the practices of child labor, forced and compulsory, We support the freedom of our employees to be part of trade union associations and their right to collective bargaining. Likewise, and in compliance with the above, we fully comply with the INTERNAL HUMAN RIGHTS COMPLIANCE POLICY, which is communicated to all levels of the Organization.

  1. EQUALITY, DIVERSITY, INCLUSION AND NON-DISCRIMINATION.

In the ORGANIZATION, we promote a culture of dignified, fair and equitable treatment among all members of the organization regardless of their hierarchical level.

In Our Organization we prohibit any type of discrimination, distinction, preference, restriction, action or omission, with or without intention that has the result of hindering, restricting, preventing or nullifying the recognition, enjoyment or exercise of human rights and freedom for one or more of the following reasons:

  • Ethnicity and/or Nationality
  • Skin color
  • Age
  • Sex
  • Gender and/or sexual preference
  • Religious beliefs or worship
  • Motor or intellectual disability
  • Social status
  • Physical appearance
  • Pregnancy
  • Language
  • Opinion or way of thinking
  • Academic preparation

All members of the organization have the same right to be promoted to a higher hierarchical level, to be recognized for their work performance.

  1. CONFLICT OF INTEREST

The members of the organization declare our abstention from having participation, direct or indirect interests in procurement and supply businesses in companies that provide services, inputs, process aids and raw materials to Our Organization, always seeking an ethical way of working free of corruption, bribery, money laundering or other types of fraudulent activities.

We strictly refuse to receive or offer prizes, (expensive) gifts and hospitality, charitable donations, charitable contributions and sponsorships, political contributions, facilitation payments, commissions, due to promotion, closure or continuance of business with customers and suppliers in order to obtain or grant any advantage. All external activities such as Political, Religious and Cultural activities must be in a personal capacity without directly or indirectly involving the Organization.

We are committed to being transparent in all our activities and reject any corrupt practices. We will not make political contributions that amount to an attempt to control or that could be perceived as unduly influencing politicians or decision-makers in favor of a specific cause, and prohibit activities that involve lack of information, lack of representation, or involve threats or coercion.

All activities carried out in the Organization must be for the sole purpose and benefit of the company and not for one or a group of members.

  1. AUTHENTICITY OF OUR PRODUCTS.

The ORGANIZATION is committed to produce AGAVE SYRUP and AGAVE FRUITS in compliance with National and International regulations, rejecting PRACTICES OF ADULTERATION for economically motivated purposes, for which we urge all our suppliers to adopt this ethical behavior by offering our organization raw materials, supplies and authentic materials of the highest quality without disguising the characteristics of ORIGIN as well as PHYSICO-CHEMICAL characteristics, declaring 100% of the components and technical characteristics of the same.

If there is any case of non-compliance by any of THE BUSINESS MEMBERS OR PARTICIPANTS in any of these points, please immediately inform our person in charge of implementing and enforcing our code of ethics: HEAD OF HUMAN RESOURCES LIZBETH DEHONOR, who will be responsible for taking the corresponding actions.

  1. 5. COMMITMENT TO ALL MEMBERS AND PARTICIPANTS OF THE BUSINESS.

 

EDULAG OFFERS TO EDULAG EXPECTS FROM
 MEMBERS OF THE ORGANIZATION
Provide the necessary resources to perform the daily work in the company, provide safety equipment, uniforms and tools to facilitate their work.

To train and educate workers at all levels, in order to increase competitiveness in the organization, generate awareness and promote business ethics, as well as care for the environment and thus provide opportunities for growth and development, both professional and human.

Remunerate competitively for the service provided to the company.

Respect the integrity and dignity of the worker and their HUMAN RIGHTS according to the ILO code, maintain an appropriate work environment and constant communication so that everyone is aware of the objectives and goals expected, as well as the guidelines and actions taken for their respective achievement.

 That all resources are properly managed, in such a way that they are used to lower costs and care for the environment, which will be translated into benefits for all members of the organization.

That the personnel contribute effort, commitment and creativity in the achievement of the company’s objectives in accordance with business ethics and reject any type of corruption, that they apply the tools acquired for the continuous improvement of the organization and the environment.

That the personnel carry out their work according to the needs of the company.

To work together to achieve goals and objectives, so that all members are vigilant in complying with policies, regulations and work instructions and participate in the actions implemented to forge a better future.
CUSTOMERS
For the ORGANIZATION it is of utmost importance to provide the best treatment to all our customers, so we try to adapt to their needs by offering a fast, efficient and honest service. With the purpose of strengthening and making lasting relationships commercial. We declare confidentiality in the information provided and negotiations made with our organization by our clients.

To provide a quality service in compliance with applicable national and international standards and to act in accordance with the principles of business ethics.

Avoidance of bribery, corruption and conflict of interest practices

That our customers have access to reliable information about our products, as well as this code of ethics through public domain sites.

 

Maintain open lines of communication with our customers through our salespeople, customer satisfaction survey and website.

 Maintain close communication with the ORGANIZATION, in order to meet their needs and contribute to the continuous improvement of the organization.

Conduct the commercial activity in a fair, honest and transparent manner, always seeking to satisfy the needs of our customers.

Guarantee good commercial practices always seeking the growth of the organization, establish commercial terms and conditions in accordance with the regulations of each country and the principles of business ethics, do not seek personal benefit in negotiations but seek the benefit for both.

That our customers know the principles of the organization and our commitments to conduct better negotiations, maintain the good reputation of the company.

To be able to know the concerns and needs of our customers and resolve doubts in a timely manner.
SUPPLIERS
It is a commitment of the company to offer fair and ethical treatment to service providers by encouraging competition among them, our duty is not to declare with service providers the competitive advantages, problems or weaknesses of their competencies.

Conduct business activities with integrity in accordance with the principles of business ethics.

To inform our suppliers of this code of ethics.

Maintain open communication with our suppliers

 Fair and honest treatment in every acquisition. We require fair treatment and an efficient service that meets our requirements and our needs. We always expect the acquisition of AUTHENTIC products avoiding Commercial Fraud practices throughout the company’s production chain.

Conduct business in a fair, honest and transparent manner, do not give or offer bribes in order to obtain commercial advantage, avoid conflicts of interest

To produce a positive effect with our suppliers and motivate the improvement of the organization through good practices, to be recognized as a company that acts with integrity to counteract bribery.

Be open to authorize accountability audits by Edulag, as well as by our certifiers, with the commitment to take care and respect the personal data they may show.
COMPETENCY
The ORGANIZATION, is committed to compete fairly and honestly complying with the laws applicable to our industry, we do not agree with any company or group of companies the illegal allocation of prices, or any similar activity that may alter market conditions. In the ORGANIZATION, we respect our competitors, therefore we do not participate in false and misleading comparisons, the treatment before our competitors must always be respectful and the comments made before them must be objective, we strictly prohibit addressing confidential issues according to our policy of confidentiality and handling of information.

At Edulag we do not engage in unfair practices in order to gain a customer or market position, we are committed to fair competition.

 

 Receive from them the same treatment that the ORGANIZATION offers, developing ourselves in a responsible and transparent manner, oriented towards a competitiveness that benefits clients and consumers.

We do not engage in unfair practices and invite you to adopt competition based on product quality.
AUTHORITIES
We are committed to comply with applicable laws and regulations and to cooperate with the competent authorities in the full exercise of their powers.

Maintain transparent relations with officials, local government and political representatives, do not pay or offer bribes in exchange for benefits.

 Ethical and impartial treatment in compliance with the Law applicable to the Organization.

Not seek personal benefits or receive or offer bribes or contributions in exchange for facilitation.
COMMUNITY
Generate jobs in the community where we are located and improve the quality of life of our employees, ethical treatment and living wages for our collaborators.
To care for and preserve the environment in our surroundings and to foster values in our employees so that they do it voluntarily and that it transcends to their families and the community.Carry out actions that prioritize the development of society and collaborate with social causes and public welfare. Collaborate actively and voluntarilywith society through support programs such as the donation of resources, support to humanitarian aid institutions (non-profit), scholarship programs for children and young people.		 To foster community development, improve the quality of work life, generate a positive impact for the organization and be a good place to work.
Contribute to combating climate change and motivate business stakeholders (members, customers, suppliers, authorities, etc.) to do the same.
To contribute to the development of a better society in which to live, integrating the efforts of all stakeholders through ethical practices.

OCCUPATIONAL HEALTH AND SAFETY

For the ORGANIZATION, occupational health and safety is of utmost importance, therefore we are committed to continuously improve and maintain the following requirements.

  1. a) Training and updating our personnel in the area of occupational safety.
  2. b) Compliance with Mexican labor and social security standards.
  3. c) Providing and maintaining an adequate work environment.
  4. d) Maintaining safe workplaces and providing safety tools to our personnel.
  5. e) Developing safety awareness among our personnel.

ENVIRONMENT

For the ORGANIZATION, it is of utmost importance to take care of the environment and natural resources, therefore we are committed to take care of the resources, preventing and controlling the pollution emitted, through the rational and efficient use of natural resources and improvements in procedures.

ADMISNTRACION DE RECURSOS

All employees of the organization are obliged to adequately manage the organization’s resources and are therefore committed.

  1. a) To make resources efficient by lowering and maintaining production costs and avoiding reprocessing as much as possible.
  2. b) Avoid waste and carelessness that may result in economic losses for the company.
  3. c) Take care of and properly maintain tools, utensils, equipment, supplies, materials and work areas.

ECONOMIC RESOURCES should not be disposed of unless authorized by the company’s management, however, senior management may use economic resources to implement improvements or acquisitions to the company according to the authorization in force by the management, if any manager exceeds the amount allocated without authorization from the management will be sanctioned according to the sanctions established in this document.

Likewise, criminal or administrative action must be taken against whoever or whoever by omission, carelessness, negligence or willful misconduct, or by partial or total loss of supplies, equipment, tools, utensils, products in process and finished products, or diversion of economic funds or fraud, may be subject to criminal or administrative action.

SANCTIONS:

VIOLATION OF THIS CODE IS SUBJECT TO ADMINISTRATIVE OR CRIMINAL PENALTIES.

  1. The severity of the sanctions refers to the seriousness of the faults committed through negligence, carelessness, willful misconduct or omission; likewise, it is considered a violation of the code not to sanction the non-compliances committed.
  2. Sanctions range from written reprimand, dismissal to criminal charges before the competent authorities; the person in charge of business ethics will be responsible for the timely investigation and closure of the sanctions as appropriate in each case.
  3. The company’s sanctions shall be determined by the immediate supervisor of the guilty party and shall be advised, if necessary, by the administrative committee and the person responsible for business ethics.

LIZBETH DEHONOR
BUSINESS ETHICS OFFICER
PHONE: 33535162783