The purpose is to formalize and disseminate the standards of behavior that guide all actions in the performance of our work and reflect our commitment to ethics within the business. Our performance is measured by the results and the way they are achieved. It is important to mention that our Code of Conduct is applicable to all Stendhal managers and employees.

All managers and collaborators must respond and sign the Manifesto of Adherence to the Code of Conduct at the time of entering the company, said manifesto is updated by each director or collaborator annually.

The objective of the code is to communicate Stendhal’s expectations of business ethics when doing business or collaborating on projects with Business Partners, Distributors and Suppliers.

Our Policy aims to ensure that all our negotiations and operations with third parties, especially with Governments and Government Officials/ Officials, are carried out in compliance with all relevant laws and regulations in the matter, guaranteeing our adherence to the highest standards of integrity in business. This Policy is applicable to all managers and collaborators of Stendhal, as well as to third parties with whom we have business relations, and gives clarity of the guidelines and mechanisms for prevention, detection and immediate response to any act of corruption that may occur in our activities.

All managers and collaborators must respond and sign the Anti-Corruption Manifesto at the time of entering the company, said manifesto is updated by each director or collaborator annually.

The policy includes a “Due Diligence”* process, which consists of a series of reviews prior to the signing of a contract or the start of a business, to evaluate the Third Party with the aim of mitigating risks of connection with natural or legal persons not aligned with our business ethics standards.

Due to the nature of Stendhal’s business, there are no vulnerable activities of illicit origin or cash transactions.

Stendhal emphasizes having “Zero Tolerance and prohibition of corrupt practices, bribery and facilitation payments”, so we make available to all collaborators and third parties the “Reporting Line” so that they can report any violation of our policies or national or international legislation.

It is a mandate of the Board of Directors, that the daily activities of the business are complete and transparent, so it is an obligation of the Chief Compliance Officer to report to the Board, the activities related to the Compliance Program.

The monitoring of the activities of the Compliance Program and the prevention of corrupt practices is included in the Annual Internal Audit Plan, which is approved by the Internal Audit Committee.

*ISO 9001:2015 certification process.

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At Stendhal we reject any financial transaction that aims to operate with money or goods that have been acquired through illegal acts or transactions intended to give it a seemingly legal origin.

Although Stendhal does not carry out vulnerable operations in accordance with the provisions of the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI) of Mexico, in a preventive manner, we established the following guidelines focused on preventing money laundering:

• It is forbidden to knowingly carry out financial transactions that lend themselves to suspicion of money laundering or management of resources that come from illicit activities.
• To carry out interbank transactions with natural / legal persons, it is necessary to have requirements that allow them to be properly identified.
• All invoices must be issued in the name of the holder making the payments.
• Cash transactions (except sales to the general public) are prohibited.
• Financial transactions with minors are prohibited.
• It is forbidden to settle or pay, as well as to accept the settlement or payment, of acts or operations through the use of coins and banknotes, in national currency or currencies and precious metals.

Our Policy provides all Stendhal employees with information and guidelines to act correctly in situations that potentially expose them to compromise their decision-making due to the existence of a conflict of interest, making available the guidelines and mechanisms for detecting, disclosing and recording potential conflicts of interest.

All managers and collaborators must respond and sign the Declaration of Conflict of Interest Manifest at the time of entering the company, said manifesto is updated by each director or collaborator annually.

Our Policy establishes guidelines of conduct that govern our Business Interactions with Health Care Professionals and how we carry them out, in accordance with our values, policies, local and international legislation and regulation.

The Policy establishes guidelines of conduct that govern our Medical-Scientific interactions with Health Care Professionals and how to carry them out, in accordance with our values, policies, local and international legislation and regulation.

Our Policy establishes guidelines of conduct that govern our Interactions with Patients and Patient Advocacy Organizations (ODP) and how to carry them out, adhering to our values, policies, local and international legislation and regulation.

Principles with which we regulate donations and grants, in kind or monetary and the procedures by which we make decisions regarding Stendhal’s participation in community, institutional projects and humanitarian crisis situations. This Policy applies to all directors and collaborators of Stendhal.

This Policy applies to all directors and collaborators of Stendhal and establishes the principles with which interactions with Government Officials must be carried out, from the intention of the same, the definition of the purpose, to the documentation of the results and the actions derived from the interaction. Our goal is to ensure that all of Stendhal’s negotiations and operations with Government Officers or Officials are conducted in compliance with all national and international laws and regulations, and in accordance with the highest standards of integrity required in conducting business, as set forth in our Code of Conduct.

It establishes internal guidelines that employees must follow in relation to the approval and verification of travel expenses and local expenses that arise from the activities of the business, and must guarantee the timely monitoring of them.

Our Policy establishes the application of sanctions derived from behaviors and conducts that deviate from our values and violate our Code of Conduct, our Policies, Procedures, and/or applicable local or international legislation.

In accordance with our Code of Conduct, Stendhal prohibits accepting or soliciting, from any supplier, gifts, entertainment, valuables, favors or commercial conditions inappropriate for personal gain, which may generate commitment or influence purchasing decisions or criteria.

All employees and managers participate in the training program included in the process of entry and induction to the company and in the annual Compliance training program, which includes the following policies:

• Code of Conduct.
• Anti-Bribery and Anti-Corruption Policy.
• Conflict of Interest Policy.
• Policy on Business Interactions with Healthcare Professionals.
• Medical scientific Interactions Policy.
• Policy on Interactions with Patients and Patient Advocacy Organizations.
• Policy of Interactions with Government Officials.
• Donations and Grants Policy.

The trainings are assigned according to the job description and are taught in person and / or through an e-learning platform.

The collaborator or manager must accredit the training with a minimum grade of 8.

All employees and managers must respond and sign the Anti-Corruption Manifesto, the Manifesto of Adherence to the Code of Conduct and the Manifesto of Declaration of Conflict and Interest at the time of entering the company, said manifesto is updated by each collaborator or director annually.