Code of Conduct

The Fresnillo Code of Conduct

Fresnillo Code Of Conduct Oma

Being recognised as a good corporate citizen is something we earn through the efforts and commitment of all who work at Fresnillo. Our Code of Conduct is intended to serve as a guide for the day-to-day behaviour of each of us, which must be consistent with the institutional values of this company: C.R.I.L; Confidence, Responsibility, Integrity and Loyalty.

By following this Code of Conduct, we reinforce the trust of all of our groups of interest in Fresnillo: shareholders, employees, clients, vendors, and community at large.

We all have an obligation to observe this Code of Conduct, guaranteeing not only that the transactions we perform adhere strictly to existing rules and regulations, but also ensuring that we work according to the highest standards of responsibility, transparency and commitment.

We will strive to set an example of strict compliance with the contents of this Code of Conduct in the daily performance of our duties, and that this will allow us to become the most widely-recognized Mexican company in the world for its global focus, process quality, and the excellence of its people.

The Corporate Code of Conduct is approved by the Board as a guideline for all Directors, executives, employees and related third parties (including clients, suppliers and the community) to act in accordance with the Code. The Code helps to ensure a foundation of values, and works as a guide for behaviour that encourages an environment of ethics and responsibility for the benefit of our stakeholders. It serves to complement the internal and external regulations already in force and also to establish corrective measures for anyone who fails to comply with the provisions of the Code. It also provides the framework for the Company’s compliance with the UK Bribery Act and the Mexican anti-bribery and corruption legislation.

Recent changes to the Code of Conduct were approved by the Board (February 2020), the objective of these changes were to:

• update and reflect changes to our recently updated conflict of interest policy;

incorporate a broad definition of corruption (according to mexican and UK regulations);

update our gift policy limit amount;

include prevention of crimes section;

made explict our commitment to have adequate conditions within the workplace for people with disabilities, to promote gender equity, not allow gender based violence and to prohibit any kind of harrasement.