Introduction

International Prospering Group S.A. de C.V., is committed to acting professionally, fairly and fully in all its commercial activities. As part of this commitment to its ethical business practices, Oil Industry Logistics will not tolerate any form of bribery or corruption.

This Anti-Bribery Policy describes the behavior and principles necessary to support this commitment. In particular, it establishes the policies and procedures of International Prospering Group S.A. of C.V. which aim to ensure compliance with the Bribery Prevention Act in the United Kingdom (Bribery Act) and the US Law. UU on Corrupt Practices Abroad (FCPA). Anti-bribery laws and regulations can be complex. This Policy will allow employees to recognize conflicts; avoid prohibited behaviors when they are obvious; and seek immediate advice when they are not so clear. Likewise, it will be necessary that certain employees, by virtue of their functions, personally attend anti-corruption training courses.

Policy Summary

All employees, executives and directors of International Prospering Group S.A. of C.V. and all those who act on behalf of or representing International Prospering Group S.A. C.V., are strictly prohibited from offering, paying, requesting or accepting bribes or gifts, including bribery and payments made in order to facilitate, expedite or accelerate administrative procedures (hereinafter, "facilitating payments" or "facilitation payments").

The provisions set forth in this Policy apply to International Prospering Group S.A. of C.V., to its one hundred percent subsidiaries controlled by it, and to joint ventures controlled by International Prospering Group S.A. de C.V., and all its employees, executives and directors. In the case of joint ventures where International Prospering Group S.A. of C.V. do not have a majority participation, they are expected to comply with this or another similar policy.

Agents, representatives and intermediaries acting on behalf of International Prospering Group S.A. of C.V., anywhere in the world, must comply with the Business Principles (which include the corresponding anti-bribery provisions) of International Prospering Group S.A. of C.V. (or of the operating company of International Prospering Group S.A. de C.V. in question) or with a similar code of conduct. It is expected that third parties, such as suppliers and other contractors, comply with the International Prospering Group S.A. Code of Conduct. of C.V. (or of the operating company of International Prospering Group S.A. de C.V. in question) or a similar code of conduct.

Given the serious nature of this type of infraction, failure to comply with this Policy by an employee, whether intentionally or negligently, may result in disciplinary action that could ultimately result in the termination of the contract. work.

Relevant Legislation

Anti-bribery laws exist in most countries of the world. Below we focus on the laws of the United Kingdom and the US; however, International Prospering Group S.A. of C.V requires that the laws of all countries in which

Bribery Prevention Act of the United Kingdom (Bribery Act.)

Under the Bribery Prevention Act of the United Kingdom, any person commits a crime by offering, promising or giving money, gifts or any other valuable object to another person, or by requesting or receiving it from another person as an incentive or reward for another person. perform an improper management, or when the act of accepting or receiving is improper. Any kind of gift, benefit, reward or advantage may constitute a bribe, not being necessary for a money supply. This general law penalizes the offer of bribes to people in both the public and private sectors, that is, it is not limited to the corruption of government officials (bribery).

The Law also contains the offense of bribery of foreign public officials (see definition of public official on page 9). A prosecutor does not have to prove that an "improper" act has been committed, only that the offender's intention was to influence the public official in order to obtain or maintain a business or commercial advantage.

The Bribery Prevention Act applies to any offense that takes place in the United Kingdom, but also to offenses that take place outside the United Kingdom when committed by British citizens, residents of the United Kingdom or entities incorporated in the United Kingdom, even in some cases where they are accepted by local customs and customs or are allowed by local law.

The Law also introduces a new corporate crime that imposes criminal liability on any company incorporated in the United Kingdom or that develops part of its business in the United Kingdom for failing to prevent the offer of a bribe by any person who provides services on behalf of the United Kingdom. or representation of the company. This may include employees, agents, representatives, intermediaries, subsidiaries and joint ventures.

A corporation will not be guilty of a corporate crime if it can be shown that it has implemented "appropriate procedures" to prevent such persons and entities from commenting on bribes. This Anti-Bribery Policy is part of the "appropriate procedures" of Oil Industry Logistics.

Those who offer bribes may be punished with up to 10 years in prison and / or unlimited fines. Companies that commit any of the crimes typified by this Law may also face a series of significant fines, confiscation of benefits from any contract obtained through corrupt means and be excluded from the possibility of participating in public tenders and other government contracts.

US Law UU On corrupt practices abroad (FCPA)

The FCPA prohibits giving or offering money, gifts or valuables to officials of a foreign government for the purpose of influencing that foreign official or third party, or inducing the foreign official or third party to exert influence to assist the corporation. obtain or retain business. The Act applies to US citizens, permanent residents and US companies, or to any person acting on their behalf or representation, as well as to foreign individuals and companies who violate the rules in a manner that is deemed to have sufficient connection to them. USA The United States government has expressed its view that the FCPA can be applied to a transaction even when it has a very limited connection with the US, for example, when a foreign person or company uses a system of US communications or US banking networks in connection with a violation of the rules. The FCPA also imposes internal control, accounting and recordkeeping provisions.

Those companies that violate the FCPA will be subject to fines for significant amounts, while individuals may face possible fines and up to 5 years in prison under the anti-bribery provision and up to 20 years under the accounting provisions.

What is a Bribe?

A bribe usually involves giving or offering money, a gift or any other object of value to someone related to a business or government for the purpose of obtaining or retaining a business advantage or inducing or rewarding the recipient so that he or she acts improperly or when it is improper for the recipient to accept the benefit. Bribery can also take place when the offer or delivery of a bribe is made by or through a third party, for example an agent, representative or intermediary. Both giving and receiving bribes is prohibited in most jurisdictions.

Bribes often involve monetary payments (or the promise of payments) but may include other benefits or advantages. For example, bribes could include:

Luxurious gifts, business attentions such as travel expenses or tickets to sports or artistic shows, especially when such attentions or gifts are disproportionate, frequent or offered in the context of ongoing commercial negotiations;

Cash payments by employees or third parties such as members of consortiums, business presenters or consultants;

The use of services, facilities or goods of a company without any consideration;

Loans, loan guarantees or other credit facilities;

Offer subcontracts to a person linked to someone involved in the adjudication of the main contract;

Contract the services of a local company owned by a potential client / public or government official or offer a scholarship to a member of the family of a potential client / public or government official;

Donations of a political or charitable nature made by a third party linked to, or at the request of, a person with whom Oil Industry Logistics conducts business;

Benefits such as the granting of internships or the offer of work experiences, both paid and unpaid.

Facilitation payments are payments of small sums of money or fees requested by government officials to expedite or facilitate the performance of routine government procedures (such as granting a visa or customs clearance of merchandise). In some countries, making these kinds of payments can be considered normal practice; however, they are also often considered illegal in these countries.

Policies and Procedures of International Prospering Group S.A. of C.V.

FACILITATION PAYMENTS

The Anti-Bribery Policy of International Prospering Group S.A. of C.V. does not allow Facilitation Payments.

Any Facilitation Payments request made to an employee or representative of International Prospering Group S.A. of C.V.  The immediate superior or Officer in charge of Anti-Bribery and Corruption Policies should be informed (Official International Prospering Group S.A. de C.V.).

There may be very exceptional circumstances in which a Facilitation Payment is inevitable (for example, when an individual's safety or personal well-being is threatened or otherwise affected). Any such payment must be reported immediately to the immediate superior or International Prospering Group S.A. of C.V. and must be duly justified.

Gifts and Corporate Attentions

The exchange or delivery of gifts and corporate attention of low economic value can encourage good willingness in business relationships. However, their value and frequency must be strictly limited, in accordance with the provisions of usual commercial practices and all applicable laws.

Employees must not solicit, accept, offer or deliver corporate gifts or entertainment to induce, endorse or reward improper conduct, including in relation to any business or prospect of future business involving International Prospering Group S.A. of C.V .: for example, when these could be perceived as gifts or attentions that compromise the judgment and the integrity of the recipient. This requirement extends to the delivery or acceptance of gifts or corporate attention through any third party or by members of the family of an employee of a current or potential client. Additionally, employees must not offer gifts, corporate attention or any other benefit to potential clients or government officials on their own account.

What constitutes a gift or business attention for the purposes of this Policy?

Any item of value, including, for example, tickets for a sporting or cultural event, gift vouchers, prizes, discounts, loans, travel expenses, stocks or other securities and the use of facilities such as, for example, houses from summer.

When are gifts or corporate attentions acceptable?

You must determine, in accordance with your own judgment, what is considered acceptable, taking into account this Policy and the approval requirements established below.

Usually, corporate gifts and services of low economic value can be offered or accepted provided there is no expectation or belief that something will be delivered in exchange. Among the gifts and corporate attentions of this nature may include:

Small gifts, including gifts of symbolic value such as calendars, diaries, pens or other small promotional items such as samples;

Occasional meals with the people with whom you do business that do not imply large outlays of sums of money;

Occasional assistance to events that do not involve large expenditures of sums of money such as, for example, musical performances, theatrical performances or minor sporting events;

Reasonable and necessary travel and accommodation expenses in connection with legitimate business trips.

When corporate gifts or entertainment are not included in the previous categories or when you are not sure if they fit these categories or if they are appropriate, you must obtain the approval of your immediate superior or of the ABC Official, before offering or accepting the gift or Attention.

You must always obtain prior approval to:

Any gift whose value exceeds the sum of the allowed limit per country (see Limits in local currency for Gifts & Expenses for business attention);

Corporate services (that is, meals, an invitation to attend a show or sporting event, business travel expenses or a combination of these activities) that exceed the sum of the allowed limit per country (see Limits in local currency for Gifts & Expenses of business attention).

To avoid doubts, prior approval will not be required to:

Promotional products of brand of symbolic value (eg, pens, calendars, shirts);

courtesies such as drinks, sandwiches or snacks of little value offered at the International Prospering Group S.A. of C.V. or from third parties, within the framework of a legitimate business meeting.

In addition to taking into consideration the proportionality and intention behind the proposed corporate gifts or attentions, you should also take into account the frequency and opportunity of them. Relatively modest gifts and corporate services that are given / received frequently or, for example, during the period of negotiation of a contract, may be perceived as improper. Therefore, even when a specific proposal does not exceed the approval limit, you must be sure that it is not appropriate or prudent to request approval and immediate superiors will also take these factors into account when approving the expenses.

If you are the recipient of an unexpected corporate gift or attention that apparently exceeds the approved limits, you must state that you have received the effect in question from your immediate superior or from the International Prospering Group S.A. of C.V. after the fact happened. With respect to a gift, you may be required to return it, deliver it to International Prospering Group S.A. of C.V. or donate it to a charity if it is not considered appropriate to keep it.

All gifts and corporate attentions that require approval will be documented in full in the local registry of gifts and corporate attentions. Gifts and corporate attentions from the company that are below the approval limits will be subject to normal procedures for approval of expenses and will not be approved if the person in charge of authorizing them considers that the expense has been improper. These cases will be reported to the International Prospering Group S.A. of C.V.

The record and procedure for the approval of expenses will be subject to regular review by the Internal Audit Team.

The review of the registry will include not only the control of the value of each one of the gifts and social attentions, but also the frequency and the joint value of such gifts and attentions offered / received by individuals / specific companies.

There are some cases in which gifts and corporate attention are never acceptable, namely:

Gifts in cash or cash equivalents (for example: gift vouchers, loans, shares or stock options);

Gifts and corporate attention that are dishonest, improper or could harm the integrity or the good name of International Prospering Group S.A. of C.V .;

Gifts and corporate attention that violate any law or local regulation;

Gifts and corporate attention that the recipient is not allowed to receive by instruction of their employer / client. If there is any doubt in this regard, you must communicate in writing about the intention to make a gift or offer corporate attention to the recipient or the employer / principal of the recipient so that they can inform in advance if the recipient's acceptance will violate any applicable local policy / law.

Keep in mind that special considerations apply when you intend to offer a gift or business attention to a government official or public employee. Excluding exceptions applicable to low-value promotional brand products and modest refreshments at International Prospering Group S.A. of C.V. or a third party referred to above, you will always need the prior approval of the local Oil Industry Logistics Official and the registration of gifts and corporate attentions offered to government officials (see the section on dealings with governments below).

The International Prospering Group S.A. of C.V. Local may advise you on any local variation of the Policy, for example, regarding customary gifts that are legal and that are not perceived as bribery or corruption.

Agents, Representatives, Intermediaries and Other Third Parties

Criminal liability could be imputed to International Prospering Group S.A. of C.V. by acts of agents, representatives and other intermediaries involved in bribes on the occasion of their performance on behalf of International Prospering Group S.A. of C.V.

Before hiring a third party should consider whether the services of this person are necessary; if the person proposed is the one to perform the functions (even considering his experience as well as any possible conflict of interests); and if the remuneration offered is appropriate.

The agents, representatives and intermediaries hired to represent the interests of International Prospering Group S.A. of C.V. must comply with the Business Principles of International Prospering Group S.A. of C.V. (or of the operating company of International Prospering Group S.A. de C.V. in question), which include the relevant anti-bribery provisions. Managers have a responsibility to ensure that the expectations of International Prospering Group S.A. of C.V. in this sense they are communicated to these persons / entities and are observed by them and that, if necessary, the appropriate contractual safeguards and guarantees are established.

Before hiring any agent, representative or intermediary, exhaustive due diligence tasks must be carried out, which may include commissioning risk assessments with third parties in high-risk areas. Above all, it is necessary to know who they are (including information of the real owners of any company); what are your business records (including if you had ever asserted or reported your connection to any illicit commercial conduct); as well as who they have worked for before. Appropriate references should always be obtained.

The business units will be responsible for ensuring that commission payments and other payments to agents, representatives or intermediaries in accordance with an authorized intermediation contract (or similar agreement) are accounted for, approved and carried out correctly as agreed and in compliance with any another legal requirement. All payments made to an agent, representative or intermediary must be made by direct bank transfer (not to a third party) to the country in which the agent, representative or intermediary has established the main business seat or in which provides substantial services on behalf of of International Prospering Group SA of C.V. Any request for payment to third parties of a commission, remuneration for services or other fees that do not conform to the provisions of this Policy must be approved by the International Prospering Group S.A. of C.V.

Deal with Governments

While many countries penalize bribery and corruption in both the public and private sectors, the rules applicable to the public sector tend to be stricter. Although the principles of this Policy apply both to businesses in the public sector and in the private sector, special care must be exercised in dealing with governments, government agencies or state-owned or state-controlled companies, especially when there is already a contract with the government or relevant government entity and / or seek to obtain business from that government or government entity.

International Prospering Group S.A. of C.V. prohibits the delivery of sums of money, gifts, business or other valuables to any government official or public employee with the intention of influencing the actions of said official in order to obtain or retain business or a business or commercial advantage or that in any other way is related to making decisions that may be perceived as beneficial to the commercial interests of International Prospering Group SA of C.V.

The approval of the International Prospering Group S.A. of C.V. It is necessary before offering gifts or business attention to any government official or public employee, even in relation to:

The payment or reimbursement of travel expenses or business services (eg, airline tickets, meals or hotel bills);

The delivery of gifts;

Making contributions for charitable purposes.

All gifts and business services to government officials and public employees, other than the exceptions of symbolic value referred to in the section of gifts and business services must be documented in the local register of gifts and business services.

Government officials and public employees include:

Any person occupying a legislative, administrative or judicial position, including ministers, elected representatives of national, regional or local assemblies, officials of a political party, public officials, magistrates or judges;

Employees, officials, agents or other persons acting in an official capacity for a government, government secretariats, government agencies or public bodies, public or commercial enterprises owned, totally or partially, by a government;

Employees, officials, agents or persons acting in an official capacity for an international public organization such as the World Bank, the United Nations or the European Commission.

Donations Policies

It is the policy of International Prospering Group S.A. of C.V. Do not make any political donation in your organization status. However, your employees may choose to make donations with their own income but without the intention of influencing any third party for the benefit of International Prospering Group S.A. of C.V. or in any other way that may give the impression that it has been intended to exert such influence.

Charitable Donations

International Prospering Group S.A. of C.V. is in favor of making contributions to the communities in which it carries out activities and allows to make reasonable donations to charitable works with the funds of International Prospering Group S.A. of C.V. However, International Prospering Group S.A. of C.V. you must be assured that donations to charities are not perceived as an attempt to exert influence for the benefit of International Prospering Group S.A. of C.V. or in any other way they are considered improper, and in the worst of cases they are not seen as illicit payments disguised to individuals or public officials in violation of any anti-corruption law. Care must be taken to ensure that the charitable work is lawful and that donations are not diverted to other beneficiaries. Therefore, no charitable donation should be made or arranged without prior consultation with the International Prospering Group S.A. of C.V. local.

Internships / Work Experience

The granting of internships or the offer of working experiences, both paid and unpaid, can be perceived as a benefit (and eventually as an improper benefit) in favor of a third party. No offer of internships or work experience should be made without first seeking the approval of the Human Resources department. All applications received for internships or work experience should be sent to the Human Resources department.

Compliance and Supervision

All employees of International Prospering Group S.A. of C.V. are responsible for complying with this Policy.

The responsibility for monitoring this Policy and its application has been assigned to the International Prospering Group S.A. of C.V. of each subsidiary / business unit of International Prospering Group S.A. of C.V. with the collaboration of the Legal Department of the company. Compliance with the Policy will be subject to regular reviews by the Internal Audit Team.

International Prospering Group S.A. of C.V. it also provides periodic training to relevant employees regarding this Policy and general compliance with anti-bribery obligations. All new employees whose daily activities may be affected by this Policy will receive appropriate training within a reasonable time after their incorporation and will acknowledge that they have received a copy of this Policy, must comply with it and with all laws and procedures related to it. she.

Internal Report of Complaints

All employees of International Prospering Group S.A. of C.V. Collaborate to fight against fraud, corruption and other bad practices within the organization. If you have become aware, or suspect that an act of bribery may be committed within International Prospering Group S.A. C.V., you must make your suspicions known to the appropriate person (usually the International Prospering Group S.A. de C.V.). If you doubt that your concerns have been addressed or will be dealt with in the right way, you should raise the issue directly with a senior executive of the company or with one of the contacts provided through the malpractice reporting procedures (Whistleblowing ) of your company or Policy of Reporting of Improper and Illicit Practices of Oil Industry Logistics (you can obtain information about it in the intranet of International Prospering Group SA de CV in Ipgmx.com).

This will allow International Prospering Group S.A. of C.V. carry out a quick investigation. It would not normally be appropriate to disclose your concerns outside the company or to a third party before International Prospering Group S.A. of C.V. I have had the opportunity to consider the problem. If you request that your identity be protected, Oil Industry Logistics will do everything in its power to ensure that this is the case.

No employee will be affected if International Prospering Group S.A. of C.V. loses business as a result of his decision not to pay bribes or participate in acts of corruption. In addition, if you sincerely believe that an irregularity is occurring and raise your concern in good faith and without willful intent, International Prospering Group S.A. of C.V. ensure that you do not suffer any inconvenience or disadvantage in the workplace for having said what you think, regardless of the outcome of the investigation.

Research

In addition to regular audits to verify compliance with relevant anti-corruption laws and, in general, with this policy and other policies, practices and procedures of International Prospering Group S.A. of C.V., there may be individual occasions in which International Prospering Group S.A. of C.V. want to investigate a specific problem or a particular manifestation. In these cases, an audit or investigation of records, books and accounts may be conducted to prevent and detect violations of anti-corruption laws and procedures and to ensure compliance with this Policy and other policies, procedures and practices of International Prospering Group S.A. of C.V.

During the course of these audits or investigations, the team of investigators may request the assistance of the staff of the International Prospering Group S.A. de C.V., being authorized to contract accounting firms, external attorneys, or other persons, as deemed appropriate by the team of researchers. All personnel have the duty to cooperate fully when requested.