Fomento Económico Mexicano B de C : Code of Ethics

Code

of Ethics

FEMSA

femsa.com

CONTENTS CODE OF ETHICS FEMSA

CONTENTS

INTRODUCTION	4
Message from our chairman	5
Purpose	6
Scope	6

OUR CULTURE	7
Our Mission and Vision	8
Our Values	9
OUR PEOPLE	10
Human Rights	11
Respect for human dignity	11
Inclusion and diversity	11
Fundamental principles and rights at work	12
Safety and health at work	13
OUR PLANET	14
Commitment to our community	15
Environment	16
OUR RESOURCES	18
FEMSA use of assets	19
Information management	20
Privileged and confidential information	20
Accounting and financial records	21
Intellectual property	21
Personal data	21
Information security	21
OUR RELATIONSHIP WITH THIRD PARTIES	22
Clients	23
Suppliers	24
Competition	25
Government and authorities	26
Marketing	27

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CONTENTS CODE OF ETHICS FEMSA

CULTURE OF LAWFULNESS	28
Regulatory compliance	29
Anti-corruption	30
Anti-bribery	30
Anti-money laundering	31
Political contributions	31
Conflict of interest	32
Financial interests	32
Family and others	33
Gifts, hospitalities and entertainment	33
Other activities	33

OUR RESPONSIBILITIES	34
Board of Directors	35
Directors	35
Audit Committee and Corporate Practices Committee	36
Secretary of the Board	36
FEMSA Regulations and Corporate Governance	37
Ethics Committees	37
General Directors of the Business Divisions	38
Employees	38
Human Resources	39
Internal Audit	39

ETHICAL COMPLIANCE SYSTEM	40
Reports	41
FEMSA Ethics Line	42
Questions and concerns	44
Corrective measures	44

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INTRODUCTION

MESSAGE FROM OUR CHAIRMAN • PURPOSE • SCOPE •

INTRODUCTION CODE OF ETHICS FEMSA

MESSAGE FROM OUR CHAIRMAN

At FEMSA we know we must put our cultivated values into practice to achieve our mission of generating economic and social value. Acting with respect, honesty and integrity, and being governed by the laws and regulations of the countries in which we operate is an essential part of our corporate culture.

The Code of Ethics FEMSA is the basis of our corporate behavior and the foundation of our policies, procedures, and guidelines. It has been approved by the Board of Directors, which has also authorized its issuance and continuous updating, which is necessary due to changes observed in the business environment.

Updating this code allows us to strengthen trust in our directors, employees, investors, customers, suppliers, authorities, and communities. The FEMSA Code of Ethics formalizes in a single document our ethical principles, unifies criteria, and establishes a common frame of reference that guides us to always act in a comprehensive manner.

It is a useful work tool that helps us make the right decisions in accordance with our values. I invite everyone who is part of the FEMSA family to read and continuously consult our FEMSA Code of Ethics. It is also very important to report any irregularities observed.

I know I can count on your support, enthusiasm, and commitment to continue creating success stories and strengthening FEMSA's reputation.

Kind regards,

José Antonio Fernández Carbajal

Executive Chairman of the Board of Directors of FEMSA

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