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SCOPE
              2






                        AND COMPLIANCE









                        2.1 REGULATION
                        This Code of Ethics is applicable to Grupo La Comer, which is composed of
                        La Comer, S.A.B. de C.V. and its subsidiaries and all its different model business:
                        La Comer, Fresko, City Market, Sumesa, Distribution Centers and Headquarters;
                        to  all  employees,  executives,  suppliers,  members  of  the  Board  of  Directors  and
                        governance  bodies of  the  companies that comprise  the Group, contractors,
                        independent consultants who provide services; as well as to the promoters and
 CODE OF ETHICS     RESPECT IS THE GOLDEN RULE
                        personnel who perform any activity in our facilities, regardless of the legal entity
                        for who they work, the location or employment relationship in which they are, the
                        functions they perform or the position they occupy, establishing the minimum
                        framework of action to which they must adhere and whose compliance will be
                        supervised by the executive levels in strict adherence to the Group’s policies and
                        internal procedures. All the members of the Company have the responsibility to
                        read, understand, accept and apply this Code.

                        La Comer puts at your disposal the “Ethical decision-making framework“, which
                        defines a guide in case of any doubts in order to support your decision making.


                        2.2 ETHICS COMMITTEE
                        The Ethics Committee is the internal body responsible for circulating the content of
                        this Code and monitoring its compliance by receiving, investigating and resolving
                        complaints.

                        It is comprised by the Legal Operations Department, the Human Resources
                        Department and the Corporate Audit and Internal Audit Sub-Departments.

                        In the event of doubts or conflicts regarding this Code’s scope and interpretation,
                        these may be explained by the Committee, which has sufficient authority to decide
                        on any situation of uncertainty that may arise.

                        The Ethics Committee will meet every two months. The selected investigations of
                        the reported cases will be presented in the sessions; the Committee will be able to
                        consult with other areas or external experts, depending on the complaint and their
                        resolutions will be voted on. All resolutions are definitive.



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