Anti-Bribery and Integrity Commitment Statement

Our Environmental Project Management Office (PMO) is committed to delivering infrastructure projects with the highest standards of integrity, transparency, and accountability. This statement affirms our zero-tolerance stance toward bribery, corruption, and any unethical conduct in all aspects of our operations. We believe that environmental infrastructure projects must be delivered with integrity to truly serve communities and ecosystems. We will not compromise our principles for financial gain, political influence, or project expediency—ever.

Application and Reach

This policy applies to all our activities in Mexico, Germany, and any other country where we operate. It covers our employees, project managers, consultants, contractors, suppliers, and any third parties acting on our behalf.

Ethical Conduct in Project Delivery

We categorically prohibit offering, giving, requesting, or accepting any form of payment, benefit, or advantage intended to improperly influence a decision, gain a business advantage, or bypass regulatory requirements. This includes—without exception—the awarding of contracts, the approval of projects, or the acceleration of permits.

Political Exposure and Conflicts of Interest

We conduct enhanced due diligence when working with individuals or entities considered politically exposed persons (PEPs) to ensure no undue influence or conflict of interest exists. Any personal, financial, or political ties that could compromise project impartiality must be disclosed and managed appropriately.

Gifts, Hospitality, and Benefits

We do not solicit or accept gifts, hospitality, or entertainment that could be perceived as influencing our professional judgment. Modest and culturally appropriate gestures may be accepted only if they are lawful, infrequent, and transparently recorded.

Donations and Sponsorships

Charitable contributions, community support initiatives, and sponsorships are made solely for legitimate purposes and never as a means to secure or retain business. All such contributions require prior written approval and transparent documentation.

Prohibition of Facilitation Payments

We do not make “facilitation payments” or unofficial fees to expedite routine government actions or administrative processes, regardless of local customs or practices.

Anti–Money Laundering Compliance

We actively monitor transactions to prevent and detect money laundering. We will not engage in any project or financial arrangement involving funds derived from illegal activities.

Responsible Supply Chain

We work only with suppliers and contractors who demonstrate a clear commitment to ethical business practices. Our procurement process includes due diligence checks to identify and exclude any party involved in bribery or corruption.

Prevention, Reporting, and Whistleblowing

We expect anyone working with or for the PMO to promptly report suspected misconduct or unethical behavior. Reports will be treated confidentially and investigated thoroughly, without retaliation against the whistleblower.