CODE OF ETHICS FEMSA

1

CONTENTS

Introduction

• Message from our chairman

5

Purpose

6

Scope

6

Our Culture

Our Mission and Vision

8

Our Values

9

Our people

Human Rights

11

o Respect for human dignity

11

o

Diversity and inclusion

11

Fundamental principles and rights at work

12

o

Safety and health at work

13

Our planet

  • Commitment to our community
  • Environment

Our resources

  • FEMSA use of assets
  • Information management
  • Privileged and confidential information
  • Accounting and financial records
  • Intellectual property
  • Personal data
  • Information technology security

Our relation with third parties

  • Clients
  • Suppliers
  • Competition
  • Government and authorities
  • Marketing

15

16

19

20

20

21

21

21

21

23

24

25

26

27

FEMSA Code of Ethics

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Culture of lawfulness

• Compliance with the regulatory framework

29

Anti-corruption

30

o

Anti-bribery

30

Anti-money laundering

31

Political contributions

31

Conflict of interest

32

o

Financial interests

32

o

Family and others

32

o Gifts, travels and attentions

33

o

Other activities

33

Our responsibilities

Board of Directors

35

Directors

35

• Audit Committee and Corporate Practices

36

Committee

36

• Secretary of the Board

37

• FEMSA Regulations and Corporate Governance

37

Ethics Committees

37

• General Directors of the Business Divisions

38

Employees

39

Human Resources

39

  • Internal Audit

Ethical compliance system

Reports

41

FEMSA Ethics Line

42

Questions and concerns

44

Corrective measures

44

FEMSA Code of Ethics

3

INTRODUCTION

  • MESSAGE FROM OUR CHAIRMAN
  • PURPOSE
  • SCOPE

FEMSA Code of Ethics

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ESSAGE FROM OUR CHAIRMAN

t FEMSA we know we must put our cultivated values into practice to achieve our mission of generating economic and social value.

Acting with respect, honesty and integrity, and being governed by the laws and regulations of the countries in which we operate is an essential part of our corporate culture.

The Code of Ethics FEMSA is the basis of our corporate behavior and the foundation of our policies, procedures and guidelines. It has been approved by the Board of Directors, which has also authorized its issuance and continuous updating, which is necessary due to changes observed in the business environment.

Updating this code allows us to strengthen trust in our directors, employees, investors, customers, suppliers, authorities and communities. The FEMSA Code of Ethics formalizes in a single document our ethical principles, unifies criteria and establishes a common frame of reference that guides us to always act in a comprehensive manner.

It is a useful work tool that helps us make the right decisions in accordance with our values. I invite everyone who is part of the FEMSA family to read and continuously consult our FEMSA Code of Ethics. It is also very important to report any irregularities observed.

I know I can count on your support, enthusiasm and commitment to continue creating success stories and strengthening FEMSA's reputation.

With kind regards,

José Antonio Fernández Carbajal

Executive Chairman of the Board of Directors of FEMSA

FEMSA Code of Ethics

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FEMSA - Fomento Económico Mexicano SA de CV published this content on 26 September 2019 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 26 September 2019 14:02:02 UTC