HSPS ANTI-CORRUPTION POLICY

OBJECTIVE

This policy is intended to establish guidelines for HSPS and all those acting on its behalf to avoid any act or conduct that could be translated or interpreted as an act of corruption.

DEVELOPMENT

The delivery or receipt of improper payments or other benefits to obtain any commercial, legal or labor advantage is expressly prohibited.

Specifically, it is prohibited:

This policy applies to all directors, officers and employees of HSPS (hereinafter collectively referred to as "Employees”), including shareholders and partners of joint ventures, so that they fully comply with the requirements of all applicable anti-corruption laws, including , but not limited to the Foreign Corrupt Practices Act (FCPA), the Political Constitution of the United Mexican States, the recently created National Anti-Corruption System, applicable legal provisions (including articles 47 and 88) and the Federal Penal Code (including articles 222 and 222 bis), among others.

The HSPS anti-corruption policy prohibits staff from:

Receiving improper payments in cash and / or electronic transfer.

Receiving gifts or benefits greater than the authorized amount in order to ensure and / or obtain an advantage or priority treatment over other competitors or to secure any other undue advantage on the part of the employee.

Therefore, the receipt of gifts, hospitality or expenses approved by the company are limited to reasonable expenses, in good faith, and when it comes to invitations to breakfasts, lunches or dinners, these should be for the sole purpose of improving communication and deepening understanding between suppliers and customers, without improperly affecting the relationship or leading to misinterpretations resulting in hiring or other business transaction based on favoritism.

COMPLAINT PORTAL

The company has setup an email address (denuncias@hsps.com.mx) as a confidential channel to file complaints, seek advice or report violations, without fear of retaliation.