For Pemex and its subsidiaries, it is essential that suppliers, contractors, partners and customers share these integrity guidelines and our values and ethical principles, which is the reason we have established guidelines for the relationship through our Code of Ethics for third parties. Likewise, we apply Due Diligence in this area, in addition to developing actions that promote principles similar to the ones we have established, in order to create ethical chains, such as filling out the Declaration of Connections to Private Parties and Statements of previous employment, position or commission in Petróleos Mexicanos, its Subsidiary Productive Companies and, where appropriate, its affiliates (Spanish), in order to prevent the risk of conflicts of interest in our business relationships.

Reinforcing our transparency, accountability, and the fight against corruption are fundamental aspects. This encourages us to permanently update and implement mechanisms throughout the organization to prevent any practice contrary to our values and ethical principles; any misconduct can be reported through our ethics hotline and may lead to disciplinary measures.

All our contracts include an anti-corruption, auditability and transparency clause. 

Third parties who are viable to enter into commercial agreements with Pemex and its subsidiaries are well known to the general public.

At Pemex, we define conflict of interest as the possible impact on unbiased and objective performance of personnel functions due to personal, family or business interests. It occurs when the decisions or actions of our personnel involve an interest other than that of Pemex and its subsidiaries.

This situation must be reported by personnel to their immediate supervisor as soon as they become aware of it or have evidence of its existence.

To learn more about this, access our site: https://www.pemex.com/gentepemex/conflicodeintereses/Paginas/default.aspx (Spanish) where you will find a Guide to detect if there is a potential conflict of interest and the procedure to report it, which can also be done through the APP PEMEX ASISTE, located in the Pemex Cumple Program.

In order to prevent the occurrence of possible acts of corruption and to avoid the influence of Officials or Politically Exposed Persons in the decision-making process involving personnel working for Pemex and its subsidiaries, it is mandatory that in their interaction with Third Parties, they are required to submit a document titled " Statement of Third Party Relationships with Government Officials and Public Servants (Politically Exposed Persons)", through which Third Parties report their business, personal or family relationships up to the fourth degree with Politically Exposed Persons, including relationships of their spouses and relatives.

In the case of the Mexican President, personnel working for Pemex and its companies is barred from entering into commercial agreements with family members, regardless of their degree of kinship.

Personnel who learn of Third Party relationships with Politically Exposed Persons, which could constitute a Real, Potential or Apparent Conflict of Interest, must inform their immediate superior, so that preventive measures may be adopted.

Board Members, Officers and Personnel at Pemex and its subsidiaries shall refrain from receiving or giving Gifts and invitations, including entertainment or any other type of consideration or favor, from those who seek to obtain or maintain undue advantages or benefits in exchange, or that the acceptance thereof may affect the integrity of the negotiations with Pemex and its subsidiaries.

We understand gifts, entertainment, compensation, invitations or other types of goods or favors to mean anything of value that represents a present, product, tickets to events of any nature, discounts, travel, accommodation, prizes, transportation, use of vehicles or property, bonuses, money, shares, gift certificates or any good or service paid for by a third party who is maintaining or intends to establish a business relationship, obtain a personal benefit, profit or advantage for themselves or for a third party, or otherwise compromise our ability to reach objective decisions on behalf of Pemex and its companies.

Restrictions on the receipt or delivery of money, securities, movable or immovable property, which may represent a conflict of interest, are applicable to personnel, their spouses, related persons and third parties with whom they have professional, labor or business relationships.

It is strictly forbidden for third parties to engage intermediaries to deliver a gift or invitation to personnel of Pemex and its companies.

Invitations to events may only be accepted when there is a clear business reason for Pemex and its Subsidiaries; and transportation, lodging and other individual expenses are covered by Pemex and its Subsidiaries and there is prior written authorization from a superior.

 

In an effort to detect and prevent transactions with illegal resources, combat the illegal fuel market, damage to its assets and financing terrorism, Pemex and its subsidiaries carry out Anti-Money Laundering Operations by identifying Vulnerable Activities, and therefore will not enter into commercial Agreements with Third Parties whose resources come from illegal sources or are destined for illegal purposes.

In the identification of Vulnerable Activities, the information and documentation to be provided by any Third Parties shall be disclosed to Pemex and its companies in the appropriate forms during the Due Diligence process pursuant to the regulations that govern it. 

In the event that a Third Party is involved in a Business Agreement during the course of the Due Diligence, it shall, to the extent possible, provide documentation that allows the identification of the Final Beneficiary.

Pemex and its subsidiaries do not tolerate any behavior that involves the tampering with the books or that has an impact on the company's financial statements.

We certify that our financial information is reliable and truthful because we are an issuer of bonds registered with the Securities and Exchange Commission (SEC). We also commit to comply with the provisions of the Sarbanes Oxley Act and any applicable legal and administrative provisions in order to strengthen corporate responsibility and combat corporate and accounting fraud.

Our financial information is reviewed annually by independent firms.

Pemex and its companies are banned from providing funding, contributions, donations or support to any person who is a pre-candidate or a candidate for public office, association or political party, whether in cash or in kind, including services, goods or the allocation of human resources, among others.

Any allocation of resources in cash or in kind for these purposes shall be considered an Act of Corruption, regardless of the applicable Types of Corruption established in the Anti-Corruption Policy.

 

Pemex and its subsidiaries prohibit the granting of donations or gifts in cash or in kind, including goods, services, securities or any other resources, to any individual or legal entity, when these have not been granted in accordance with the provisions of the "Policies and Guidelines for the Management of the Corporate Operation License of Petróleos Mexicanos, its Subsidiary Productive Companies and, as the case may be, Affiliate Companies", under the section "Guidelines for Donations and Contributions to Petróleos Mexicanos, its Subsidiary Productive Companies and, as the case may be, its Affiliate Companies".

 

The Board Members, representatives and officers of the companies shall promote the adoption of the Anticorruption Policies and Guidelines within their respective Boards of Directors, to the extent applicable or, if appropriate, shall issue their own, which shall be aligned with these Policies and Guidelines and in compliance with the Anticorruption Laws and Obligations in force in the countries in which they operate.

As instructed by PEMEX's Board of Directors, the Compliance Program is being implemented in all subsidiaries of the PEMEX Group. 

Anticorruption Policies and Guidelines for Petróleos Mexicanos, its Subsidiary Productive Companies and, if applicable, its Affiliates.

Learn more about the Subsidiary Companies 

For Pemex and its companies, it is important for personnel to be familiar with the Codes of Ethics and Conduct, as well as with the regulations on corruption prevention, transparency and personal data protection, because we are convinced of the importance of maintaining our business agreements and promoting ethical value chains with our third parties. Courses in these areas are mandatory for all personnel, including management and Board Members.

We have a Compliance Program titled "Pemex Cumple", whose objective, among others, is to prevent the risk of corruption by implementing strategies and measures aimed at fostering the development of values and ethical principles, legal compliance, accountability, transparency and the protection of personal data, through the development of human capital.