MERA CODE OF ETHICS

1. Purpose

This Code of Ethics establishes the principles, values, and guidelines that must govern the relationship between MERA, its Suppliers, and its Clients, ensuring that all interactions are conducted with transparency, responsibility, and respect, promoting compliance with applicable laws and regulations regarding human rights, labor, environmental matters, anti-corruption, anti-terrorism, and the prevention of money laundering.

2. Fundamental Principles and Values

Transparency: acting with clarity in the management of information and in all operations.
Legality: All activities, decisions, and business relationships must strictly comply with the legal framework in force in the countries in which we operate. This includes strict adherence to national laws, as well as to international treaties and regulations applicable to human rights, labor, environmental matters, anti-corruption, anti-terrorism, and the prevention of money laundering. MERA, its Suppliers, and Clients commit not to tolerate unlawful practices nor to participate, directly or indirectly, in acts that violate applicable legislation or that may put at risk the reputation and integrity of any of the parties.
Respect: The dignified treatment of all individuals, regardless of their origin, gender, beliefs, or position, is an essential value. MERA, its Suppliers, and Clients must promote an inclusive environment free from any form of discrimination or harassment.
Responsibility: All parties involved must fully assume the consequences of their actions and decisions. This implies acting with diligence, fulfilling acquired commitments, and ensuring that the impacts of our activities are positive for society and the environment.
Integrity: rejecting any form of fraud, corruption, or improper practices.
Sustainability: promoting practices that protect the environment and support collective well-being.

3. Regulatory Commitments

3.1. Human Rights

MERA recognizes that respect for human rights is a fundamental pillar of any business relationship. Therefore, Suppliers and Clients must ensure that, in the development of their activities, the dignity, equality, and freedom of all individuals are guaranteed. This implies the absolute prohibition of practices such as child labor, forced labor, or human trafficking. Conditions must be established to ensure non-discrimination, inclusion, and equity, avoiding any unequal treatment based on gender, age, ethnicity, religion, sexual orientation, disability, or any other personal condition.

Likewise, an environment is promoted in which tolerance and mutual respect prevail, ensuring that every person linked to MERA’s value chain can carry out their work under conditions that safeguard their physical, emotional, and moral integrity.

3.2. Labor Rights

Commitment to labor rights constitutes an extension of respect for human dignity. Suppliers and Clients must ensure that working conditions comply with local and international regulations, providing a safe and healthy work environment. Employment conditions must be clear and fair and must not give rise to exploitation, abuse, or practices that undermine job stability. Harassment in any of its forms is rejected, and a culture of respect in the workplace is promoted. Additionally, organizations are encouraged to promote training, professional development, and an adequate balance between work and personal life for their collaborators.

3.3. Environment

MERA considers environmental protection a shared responsibility. Business activities must be carried out by minimizing environmental impact and strictly complying with applicable environmental regulations. This implies adopting responsible practices in the use of natural resources, promoting energy efficiency, the rational use of water, and proper waste management. Practices that cause pollution of air, soil, or water must be avoided, and, whenever possible, clean technologies, circular processes, and recycling policies should be promoted. MERA expects its Suppliers and Clients to share the vision that sustainability is not only a legal obligation but also an ethical commitment to future generations. Environmental responsibility is inseparable from competitiveness and must be viewed as an opportunity to generate shared value.

3.4. Anti-Corruption

Integrity in business constitutes a non-negotiable principle for MERA, its Suppliers, and/or Clients. In this regard, any form of corruption is categorically rejected, including bribery, extortion, fraud, influence peddling, improper payments to public officials, as well as any unfair practice intended to obtain an illicit or improper benefit. All activities carried out within the framework of business and/or contractual relationships must strictly adhere to legality and comply with the provisions of the General Law of Administrative Responsibilities of the United Mexican States, the Foreign Corrupt Practices Act (FCPA) of the United States of America, the UK Bribery Act of the United Kingdom, and any other applicable national or international regulation on anti-corruption. Within this framework, MERA, its Suppliers, and/or Clients declare that neither they nor their agents, representatives, employees, or any third party acting on their behalf have made, nor will they make, promises, offers, or deliveries of money, goods, or any item of value to public officials, political parties, or private individuals, in order to obtain or retain business, secure improper advantages, or influence official decisions.

3.5. Anti-Terrorism

MERA maintains a zero-tolerance policy toward any form of connection with terrorist organizations, criminal groups, or organized crime, including drug trafficking networks. Neither Suppliers nor Clients may, directly or indirectly, collaborate, finance, facilitate, support, conceal, or participate in activities whose purpose or effect is the preparation, planning, or execution of acts of terrorism, as well as activities related to organized crime in any of its forms. This commitment is based on compliance with the Federal Law Against Organized Crime, the Federal Criminal Code, as well as international treaties and agreements on the prevention and combat of terrorism, including the Anti-Terrorism Act (ATA) of the United States of America. Likewise, there is an obligation to conduct thorough due diligence regarding operations, business relationships, and counterparties, in order to ensure that resources, goods, or services are not used for illicit activities. None of the parties may maintain business relationships with individuals or legal entities included in national or international sanctions lists issued by organizations such as the United Nations, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury, the European Union, the United Kingdom, or competent authorities in Mexico. MERA, its Suppliers, and/or Clients declare that neither they nor any third party acting on their behalf maintain business relationships with entities located or incorporated in countries subject to broad or comprehensive international sanctions, including, but not limited to, Iran, North Korea, Syria, and Sudan, or any other country designated by competent authorities.

3.6. Anti-Money Laundering

The prevention of money laundering and terrorist financing constitutes a strategic priority within MERA’s operations and in the relationships it maintains with its Suppliers and Clients. Therefore, it is required that all economic, material, or financial resources allocated to business relationships have a legitimate, verifiable origin free from any link to illicit activities. MERA strictly prohibits fictitious operations, unusual transactions lacking economic justification, and the use of financial structures designed to conceal the true origin of resources. MERA actively promotes the implementation of “Know Your Customer” (KYC) and “Know Your Supplier” (KYP) policies as fundamental tools to ensure transparency in operations and reduce the risk of involvement in illicit activities. In the event of detecting suspicious transactions, the parties shall be obligated to immediately report them to the competent authorities, in strict compliance with applicable legal provisions. Through these measures, MERA reaffirms its commitment to integrity, the stability of the financial system, and the strengthening of formal economic development, in strict adherence to the Federal Law for the Prevention and Identification of Transactions with Illicitly Sourced Funds (Anti-Money Laundering Law), as well as equivalent Anti-Money Laundering (AML) provisions of the United States of America and other applicable jurisdictions.

4. Reporting Channels

MERA recognizes the importance of ensuring that any potential breach of this Code of Ethics can be identified and addressed in a timely, confidential, and secure manner. Therefore, it provides Suppliers, Clients, employees, and other stakeholders with reporting mechanisms to report situations that violate the principles, values, or guidelines established herein. All reports received will be handled with impartiality, objectivity, and respect for the confidentiality of the reporting party. MERA ensures that no person who submits a report will be subject to retaliation, intimidation, discrimination, or any adverse action as a result of their communication. Reporting channels are designed to provide appropriate follow-up for each case, including investigation, analysis, and resolution according to the severity of the breach, always respecting the rights of all parties involved.

5. Consequences of Non-Compliance

Failure to comply with the provisions established in this Code of Ethics shall be considered a serious violation that may compromise the integrity and mutual trust in business and/or contractual relationships between MERA and its Suppliers and/or Clients. Non-compliance with such provisions shall result in:

Immediate termination of the business and/or contractual relationship with MERA.
Notification and reporting to the competent authorities, in cases where the breach constitutes a violation of the law, including acts of corruption, money laundering, terrorist financing, or violations of any applicable regulation.

6. Final Commitment

This Code of Ethics reflects the firm commitment of MERA, its Suppliers, and Clients to legality, integrity, transparency, and sustainability in all business and contractual relationships. Its adoption and compliance constitute an essential condition for maintaining relationships with the company and ensure that operations are conducted in an ethical, responsible, and socially conscious manner.

MERA expects all parties to act consistently with their values and actions, fostering an environment of trust, respect, and professionalism. Compliance with this Code contributes not only to the strengthening of the organization but also to the economic, social, and environmental development of the community, promoting fair and sustainable relationships that generate shared value for all parties.