Code of Conduct

The Fresnillo Code of Conduct

Integrity

We have an Integrity Policy Manual, in keeping with the requirements of the Mexican General Law on Administrative Responsibilities, which establishes prevention, compliance, oversight and accountability mechanisms for avoiding involvement in administrative violations by members of the organization (the “Employees”), regardless of the legal entity for which they work, their labour relationship, duties or the position they hold, in their business relations with third parties, particularly government agencies and public servants

Manual of Organisation and Procedures
Fresnillo also has a set of documents that comprise the Manual of Organisation and Procedures, which defines the functions and responsibilities of each area. It also contains clear policies and mechanisms introduced to prevent and combat corruption and any type of illegal practice, and to take actions against impunity

Code of Conduct
As mentioned earlier, we have a Code of Conduct which has been duly approved, distributed, published and discussed with our Employees so that they can learn about, understand and apply it.  It has systems and mechanisms for constantly monitoring and overseeing compliance with the Code. The Code defines the ethical standards that guide the corporate actions of every Fresnillo Employee, as well as standards that must be applied in its decision-making and management. 

As established in the Code, Fresnillo conducts all its operations and business relations in an ethical manner. To this end, it has a zero-tolerance policy toward any actions of bribery and corruption, and obligates all Employees to abide by the applicable laws in this area at all times. 

Among the guidelines included in the Code are those governing Employees in their relationships with stakeholders, authorities or interested third parties, to avoid illegal acts such as corruption, bribery, conflict of interest or any other that goes against institutional values; as guidelines obligating them  to be aware of and to apply all laws, rules, policies, internal and external policies and procedures applicable to Fresnillo’s activities. 

Whistleblowing Line
We encourage employees and business partners who become aware of any action that violates our Code of Conduct or current laws and regulations, to report it through our whistleblowing line, which is available 365 days a year via webpage, e-mail or phone. You may also lodge any complaint through the company or directly at the corporate offices. All such reports are confidential and may be made anonymously.

Fresnillo will not tolerate any reprisal or threat against any employee or business partner who files a report or lodges a complaint. Similarly, any employee who discourages or attempts to prevent another employee from filing a report or seeking the aid or assistance needed to do so will be subject to disciplinary measures.  Reprisals constitute a sanctionable offense in and of themselves, and may be reported through the whistleblowing line at https://fresnilloplc.lineacorrecta.com/

Control, Oversight and Auditing Systems
Fresnillo has appropriate effective systems in place for control, oversight monitoring and auditing, which continuously and regularly examine compliance with integrity standards. The Compliance area is in charge of establishing controls, overseeing and monitoring observance of integrity standards. Additionally Corporate Governance bodies and the Internal Audit area and annual reviews of the internal control system by external auditors all contribute to this purpose.

Training and Preparation Systems and Processes
Fresnillo training programs include specific courses for Employees regarding policies relating to integrity issues. Additionally, Employees must provide annual statements understanding and commitment to the Code of Conduct.  As part of this process, they are required to disclose the existence of any possible conflicts of interest.

Human Resource Policies
The Human Resources area has processes for recruiting, evaluating and selecting talent according to principles of honesty, integrity and respect.  These policies prohibit discrimination against anyone on the basis of their ethnic or national origin, gender, age, disability, social condition, health, religion, opinion, sexual preference, marital status or any other condition in a manner that infringes upon their human dignity and denies or limits their basic human rights and freedom. The Human Resources area conducts interviews, tests and evaluations of job candidates to ensure that it has the right talent, and, when necessary, may apply certain tests of the trustworthiness of Employees working in certain areas, to measure the potential risk of inappropriate conduct within Fresnillo.

Mechanisms of Transparency and Disclosure of Interest
To ensure transparency and disclosure of corporate interests at all times, Fresnillo takes the following actions:
- Compliance with all the information disclosure requirements established by the stock markets on which it is listed.
- Keeping corporate records and accounting books up to date and maintained in keeping with the applicable regulations.
- Declaration by employees and vendors of any relationship that may imply a conflict of interest, in order to avoid and sanction any conduct that may compromise employees' impartially in the ethical, efficient and objective performance of their duties.