Page 28 - CÓDIGO DE ÉTICA La Comer inglés digital

When any member of the Company has to make or influence a decision that
7.2 MONEY LAUNDERING PREVENTION ACTIONS
The Company is committed to comply with the laws and regulations
regarding activities considered vulnerable. Therefore, business relationships
4
will only be established with reputable customers and suppliers whose
activities are carried out with funds from legitimate sources. Hence, we must
comply with the measures implemented that allow us to have knowledge of
our clients and suppliers, calibrating the risk based on the type and size of
business in question.
In the same way, reasonable measures must be taken to prevent and detect
forms of payment that may be unacceptable or suspicious in accordance
with the corresponding policy. Failure to detect business relationships or
transactions that may put the Company at risk may also result in severe
damage to its reputation. Therefore, as employees, we must be aware of and
comply with external and internal measures regarding the prevention of
money laundering and terrorist financing, to always be vigilant in the event
CODE OF ETHICS RESPECT IS THE GOLDEN RULE
that someone tries to use the services or products of the Group’s companies
to hide or simulate the origin of illicit resources.
7.3 CONFLICT OF INTEREST AND RELATED PARTIES
There is a real or apparent conflict of interest when the interests of a person,
their family or related third parties (where there is an emotional or personal
bond) complicate their decision-making or compromise their efficient and
objective performance.
A related party is understood as any person or legal entity who has
business dealings with the Company and who meets any of the following
assumptions:
Any person who is a relevant officer and/or has significant influence
on the related party, and who has a blood or marriage kinship up to
the fourth degree with the Company’s personnel that is part of the
Management Group or Relevant Directors.
The related party has share participation or power of command of
any executive, Board of Directors member or relevant director of the
Company.
4 Specifically, the Federal Law for the Prevention and Identification of Operations with Resources
of Illicit Origin in force on the date of this Code of Ethics’ publication, as well as the general
provisions issued for that purpose by the Financial Intelligence Unit subordinated to Mexico’s
Tax Authority (SAT, Servicio de Administración Tributaria).
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may directly or indirectly benefit them or a family member (as an employee,
supplier of goods and/or services or client), they must notify their immediate
supervisor and the area’s deputy director or director of the existence of a conflict
of interest; the latter must make the final decision. These transactions may
be authorized if they are properly supported insofar as they are carried out at
market prices and under the same commercial conditions and requirements
applied to third parties. These operations must be documented and reported
to the Corporate Audit Area, who will follow up their progress.
The Company’s Board of Directors and its representative bodies have the
authority to review transactions with third parties considered conflicts of
interest or related parties and to approve or cancel them.
In the event that direct relatives of the Company’s employees or executives are
hired, justification that they have the sufficient qualifications, performance
and credentials for the position must be submitted and there must not be
any direct employment or commercial dependency relationship between
the employee and said family member.
For no reason will staff be assigned to positions where a relative of theirs has
the opportunity to verify, supervise, review, audit or affect their work, in any
way that may influence their salary or promotion progress.
If Company members contract marriage or other kind of kinship, they will
not be able to work in related areas that may generate a conflict of interest.
Misuse of resources or influence of any position is prohibited. Even when there
is no immoral intention, the appearance of a conflict can have a negative
impact. It is crucial to consider how certain actions may be perceived and
how a perception of conflict of interest can be avoided.
7.4 OTHER POSITIONS WITH DIRECT COMPETITORS
OR WITH SUPPLIERS
In their free time, the actions of employees or executives must not clash with
their responsibilities in the Company. Company employees (regardless of
their position or hierarchical level) are not allowed to participate in another
organization that is a direct competition or with a supplier. If an executive
is invited to participate as an administrative or advisory Board director in
another entity or organization, he must inform his superior and the Executive
Chairman through the Corporate Audit area, who will communicate the
resolution taken.
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