Code of Conduct and Responsibility

This Code of Conduct and Responsibility describes the guidelines to which the actions of all GMI Consulting employees adhere in the fulfillment of their functions and makes clear the commitment of those who make up this Consulting Firm in compliance with its rules, principles and regulations, as well as the laws of Mexico and the countries where it operates.

These rules of conduct have been drafted with a perspective of respect for human rights and are generally observed, so they apply to all employees in all areas, particularly for those who of course or their functions have dealings with communities and groups of neighbors.

PERSONAL ETHICAL PRACTICES

GMI Consulting assumes and requires its employees the commitment to carry out their professional activities with total adherence to legitimate and ethical practices.

Duty to report transgressions

Every employee has the duty to inform the General Management in good faith of any circumstance that he considers to be a violation of any internal rule or the Corporate Policies of this Firm. Any suspected violations of the rules must be reported to the General Management, who will be obliged to investigate the matter and take the necessary corrective measures.

There will be no retaliation against any of the employees for having reported in good faith a possible violation of the rules. However, the collaborator may incur liability if he reports with intent or in bad faith with the sole purpose of harming a third party.

Anti-Bribery Conduct

Bribery is understood as the donation of money or any other value with the intention of influencing the conduct of a community leader, an authority, or any other person for the benefit of the functions of the collaborator or GMI Consulting.

The use of funds of the collaborator or property of GMI Consulting for illegal, unethical or otherwise improper purposes, whether in a personal capacity or on behalf of the Firm, is strictly prohibited; Such uses include improper payments, illegal commissions or illegitimate compensation. No contributor shall pay, offer or authorize any type of bribe or make any illegitimate payment either in a personal capacity or on behalf of the Firm.

The delivery of money (except for the acquisition of a product or service) or gifts may be considered an illegal commission and subject to penalties, so no collaborator should offer or authorize the delivery of money or a gift on behalf of the Firm to any person.

Conflicts of interest

Conflict of interest is understood as any situation in which the judgment of a person is unduly influenced by their own interests or those of third parties, opposing those of GMI Consulting or its clients, and possibly affect or affect the integrity of their decisions and compromise the interests of this Firm.

At all times, commercial, financial or other relationships that may cause conflict with the interests of this Firm or its clients, or affect or influence the ability to fulfill the duties of the collaborator, must be avoided. There is a conflict of interest when, including but not limited to, any of the following assumptions are updated:

• The collaborator directly or through a relative in the first degree has a financial interest or is obliged to a competitor of GMI Consulting, with any of its clients, with any authority related to its functions, or in any business of which it is aware that this Firm has or contemplates the possibility of having a commercial relationship.

• The collaborator directly or through a relative in the first degree acquires real or movable property, rentals, patents or rights in which it is known that GMI Consulting has them or is likely to have them.

• The collaborator uses a position or charge in GMI Consulting or the equipment, supplies or facilities of this Firm for personal activities or purposes, or carries out any action that may involve sponsorship or support of the Firm to an activity that has not been authorized by the General Management.

Any collaborator who becomes aware of an actual or potential conflict of interest, or the appearance of a conflict of interest, whether their own or that of any other collaborator, must immediately notify the General Management in order to ensure the integrity of the Firm’s transactions and the protection of their interests and those of their clients.

Duty to Maintain the Confidentiality of Information

It is the responsibility of all employees of GMI Consulting to comply with the Confidentiality Agreement signed with this Firm to safeguard confidential information that may be in their possession and not to disclose it to any person who is not authorized to receive it by any means, inside or outside the Firm.

Confidential information means any information that has not been publicly disclosed by the Firm or its clients, personal data collected during fieldwork, and any information that could be useful or beneficial to GMI Consulting’s competitors to the detriment of this Firm or its clients. Common examples include technical information on clients’ projects that has not been published by them; the personal and sensitive data of the interviewees and the people with whom the researchers interact during the fieldwork; the financial data, audits or other evaluation reports of the Firm; the terms of GMI Consulting’s contracts with its clients; research projects; information-gathering tools, methodologies and institutional manuals; and the information of any third party that is subject to a confidentiality agreement.

Confidential information shall only be used for the purposes established by this Firm. In the event that a collaborator ceases to provide its services to GMI Consulting for any reason, its legal obligations with respect to confidential information will remain in force, in terms of the Confidentiality Agreement signed between the Firm and the collaborator.

Ethical and responsible behavior during fieldwork

Due to the intrinsic characteristics of field work, employees who carry out activities in contact with members of rural or urban communities in their places of residence should keep in mind at all times the following guidelines:

• Provide dignified, respectful and non-discriminatory treatment to all people;
• Respect social practices and local codes of conduct;
• Interact respectfully with their interlocutors, call them by their first names, or in a respectful manner avoiding name-calling or nicknames;
• Generate an environment of mutual respect and trust, with special emphasis on their relationship with people in vulnerable situations (older adults, indigenous people, women, children, people with disabilities, among others);
• Do not make comments or expressions out of place that may humiliate or put your interlocutor at a disadvantage;
• Respect the uses and customs and traditions of indigenous and Afro-Mexican peoples and communities, as well as the original neighborhoods of Mexico City.

Acceptance of gifts and participation in social activities

It is forbidden to request or accept fees, loans, commissions, services or monetary donations of any kind from suppliers, customers, neighbors or inhabitants of the localities in which GMI Consulting employees perform their functions.

Only non-monetary gifts or hospitality in social activities that are in accordance with the ethical practices accepted by the Firm and that do not have a significant value or the purpose of influencing the behavior of the collaborator can be accepted. Accepting gifts or hospitality does not imply giving any preferential treatment to the person who has delivered or offered those gifts or attention, and even any manifestation that generates expectations of preferential treatment should be avoided.

It is allowed to make gifts and have social hospitality on your own account (never in the name of the Firm) during the usual course of work, provided that:

• Are reasonable and consistent with applicable laws and fall within ethical standards and acceptable community practices.
• They are carried out in exchange for actions or omissions that affect the professional activities of the collaborators.
• Are of limited value, so that they cannot be interpreted as bribes, illegal commissions or illegitimate compensation.
• In no case compromise the Corporate Principles of this Firm or undermine the legitimacy of the work carried out by GMI Consulting.

All employees are free to carry out extracurricular activities during fieldwork, as long as they do not interfere with their performance and in no way can generate a conflict with the interests of this Firm or its clients. If the activities are controversial or sensitive, staff members are expected to seek guidance from their immediate superior before committing to them.

ETHICAL WORK PRACTICES

According to the International Labour Organization: “Decentwork synthesizes people’s aspirations during their working lives. It means the opportunity to access productive employment that generates a fair income, workplace security and social protection for all, better prospects for personal development and social integration, freedom for individuals to express their opinions, organize and participate in decisions that affect their lives, and equal opportunity and treatment for all, women and men.”

GMI Consulting will comply with the following ethical practices in relation to its employees, promoting decent work within the organization:

Equal employment and wage policy

GMI Consulting hires staff under schemes to assess their qualifications for the position, taking into account both their skills and their social and community relationship skills. No applicant for employment shall be subject to discrimination because of ethnicity, skin color, religion, sex, age, nationality, citizenship status, marital status, sexual orientation, physical disabilities, or any condition other than their professional capabilities.

It is the policy of this Firm that its employees receive equal pay for equal work, without any salary difference based on gender.

The Corporate Policies together with the Labor Policies make up the Internal Labor Regulations, which comply with current labor regulations.

Elimination of discrimination and harassment in employment

GMI Consulting is committed to maintaining a work environment free of discrimination, including any form of harassment in accordance with our Sexual and Workplace Violence and Harassment Prevention Policy. This Firm strictly prohibits any situation of verbal, physical, visual, or sexual harassment directed at another collaborator whether based on their gender, ethnicity, skin color, religion, age, nationality, citizenship status, marital status, sexual orientation, physical disabilities, or any other. This policy applies to any conduct observed among employees whether inside or outside the Firm’s premises during the performance of work.

The use of computer equipment to create, view or forward offensive images or messages to any collaborator is prohibited. It is also prohibited to download from the network, transmit or create material for personal purposes of sexual or racial content that is offensive or discriminatory.

Duty of Privacy

GMI Consulting undertakes to respect the Confidentiality Agreements signed with its clients, to protect the integrity of the personal and sensitive data that have been collected by its collaborators during the fieldwork, as well as all data and information of a private nature related to its own collaborators.