ANTI-CORRUPTION CODE

1. INTRODUCTION 

In NEVER8 SA de CV (hereafter NEVER8), its subsidiaries, strategic allies, partners, personnel and suppliers, we are committed to conducting our business with honesty, trustworthiness, integrity and transparency.

This as a fundamental part of our principles and internal business ethics policy.

In NEVER8 behavior in accordance with our values characterizes us and we seek that all our internal and external collaborators act with the same consistency, achieving synergy against corruption in all its forms, including extortion and bribery, in accordance with the United Nations Convention against Corruption and other applicable legislation.

 

2.- OBJECTIVE

Establish the guidelines that verify that NEVER8, as well as its subsidiaries, impose honesty, integrity, transparency and honesty as a continuous practice.

As well as avoiding improper actions on the part of NEVER8, its subsidiaries, strategic allies, partners, personnel and suppliers and, where appropriate, detect and deal responsibly with any act of corruption in any of its forms.

 

The main objective of this code is:

• Prevent, investigate, combat, denounce and eradicate any type of corrupt practice such as: bribery, trying to improperly influence any other person in any other way, whether in the public or private sector, influence peddling, collusion and/or improper hiring .

 

3.- FIELD OF APPLICATION

This Anti-Corruption Code is applicable to all natural or legal persons who maintain a commercial, social, labor and/or professional relationship with NEVER8.

As well as in those workplaces, social and fiscal domiciles where they work and have the services of workers of NEVER8, regardless of its size or activity, throughout the Mexican territory.

All the staff of NEVER8 has the responsibility to comply with this code in the exercise of its functions.

 

4.- MEXICAN LEGAL FRAMEWORK

• Political Constitution of the United Mexican States, whose article 109 dictates that public servants and individuals who incur in responsibility before the State, will be punished who incur in acts of corruption in terms of current criminal legislation.
• General Law of Administrative Responsibilities. Article 66 determines that the individual who promises, offers or delivers any undue benefit referred to in article 52 of this Law to one or several Public Servants, directly or through third parties, will incur in bribery, in exchange for said Public Servants performing or refrain from performing an act related to their functions or those of another public servant, or abuse their real or supposed influence, with the purpose of obtaining or maintaining, for themselves or a third party, a benefit or advantage , regardless of the acceptance or receipt of the benefit or the result obtained.

• Federal penal code. It alludes in its article 212 that the sanctions provided for the crime in question will be imposed on any person who participates in the perpetration of any of the crimes provided for in this Title or the subsequent one.

 

5.- DEFINITIONS

For the purposes of this code, the following definitions are established:

• Corruption: It consists of the abuse of power for personal gain. It can be classified into large-scale, petty and political corruption, depending on the amount of funds lost and the sector in which it occurs.
• large scale corruption: Large-scale corruption consists of acts committed at the highest levels of government that involve the distortion of policies or central functions of the State, and that allow leaders to benefit at the expense of the common good.
• minor acts of corruption: Petty acts of corruption consist of the day-to-day abuse of power by low- and mid-level public officials when interacting with ordinary citizens, who often try to access basic goods and services in settings such as hospitals, schools, police departments, and other agencies.
• Political corruption: Manipulation of policies, institutions and procedural norms in the allocation of resources and financing by those responsible for political decisions, who abuse their position to preserve their power, status and patrimony.
• Bribery: Crime committed by the public servant who, by himself, or through an intermediary, illegally requests or receives for himself or for another, money or any benefit, or accepts a promise, to perform or fail to perform an act of his inherent functions their employment, position or commission, as well as the one who gives, promises or delivers any benefit to any of the persons mentioned in article 212 of the Federal Penal Code, so that they perform or omit an act related to their functions, to their employment , charge or commission
• Influence peddling: Crime committed by any person who promotes the illicit conduct of the public servant or lends himself to the promotion or management of an illicit benefit.
• Extortion: is a crime consisting of forcing a person, through the use of violence or intimidation, to carry out or omit an act or legal business for profit and with the intention of causing patrimonial damage or damage to the taxpayer

 

NEVER8 categorically prohibits bribery and corruption in any of its modalities, any natural or legal person who maintains a labor, commercial, social or professional relationship with NEVER8 who are discovered participating in a corruption or bribery case, will face disciplinary measures that may include dismissal, termination of contracts, early terminations, penalties or economic sanctions, as well as notification to the corresponding authorities.

 

"When you don't take a stand against corruption, you tacitly support it."

  

6.- RECOMMENDED ACTIONS.

1. Comply with current regulations and legislation on anti-corruption issues.
2. Conduct yourself under the principles of honesty, honesty, transparency and ethics.
3. Promote continuous training for personnel against corruption.
4. In accordance with the applicable legislation, it is totally prohibited to give or receive bribes, incentives, payments, gifts, directly or indirectly.
5. Implement an anti-corruption program.
6. Ensure that human resources policies and procedures are consistent with the anti-corruption program.
7. Implement detailed policies and procedures to counter key corruption risks.

If you want to report an act of corruption by a member of NEVER8 please use the means of contact available on this page:

https://www.never8.com/contactanos/