Code of Ethics Policy

1. OBJECTIVE

Define the conditions that must be carried out to ensure that TERMINALES PORTUARIAS DEL PACIFICO, S.A.P.I. DE C.V. Has a Code of Ethics that allows its collaborators to preserve and comply with the values and organizational culture

2. SCOPE

This policy applies to TERMINALES PORTUARIAS DEL PACIFICO, S.A.P.I. DE C.V. and its subsidiaries and any other Outsourcing of personnel, Contractors, Subcontractors, Supply Chain, Suppliers and Client

3. DEFINITIONS

Committee: Management Committee of TERMINALES PORTUARIAS DEL PACIFICO, S.A.P.I. DE C.V.

Board: Board of Directors to the Shareholders' Meeting of TERMINALES PORTUARIAS DEL PACIFICO, S.A.P.I. DE C.V. And subsidiaries.

Ethics Committee: It is made up of senior management executives within the organization, as well as members of the Board of Administration.

4. RELATED DOCUMENTS

-Internal Work Regulations

-General Privacy Policy.

-Anti-bribery and Anti-Corruption Policy

-Gifts and Entertainment Policy

-Sanctions Policy

5. DEVELOPMENT

5.1.- Our Values

TERMINALES PORTUARIAS DEL PACIFICO, S.A.P.I. DE C.V. It is a company that has grown rapidly, that is why we want to make sure that the values that have allowed us to get to where we are preserved and improved day by day.

Our values and culture correspond to our family, who are each one of the people who collaborate with us, and who together form TERMINALES PORTUARIAS DEL PACIFICO, S.A.P.I. DE C.V. they are the foundation and personality of this company.

For our shareholders, these values give them the necessary confidence that is translated into profitability and transparency, for our client quality and compliance, for society in general it is reflected in social responsibility, for our suppliers our values give them free security competence and objectivity of our company when contracting its services or products.

That is why we trust that our partners and suppliers will contribute ethical principles similar to ours.

5.2.- Shareholders and Investors

a) TPP is a trusted company whereby access to detailed information on the company's management and the functioning of its bodies is always available to its shareholders and investors.

a) Profitability is always reflected with completely solid business standards and with a safe ground for our investors and shareholders.

5.3.- Our Collaborators

5.4.- Suppliers

a) TPP guarantees equal opportunities for all suppliers, who send competitive offers, promoting healthy competition.

a) We will use objective criteria of purchasing systems, which guarantee the availability of products and services in the best existing conditions.

5.5. Society

a) TPP collaborates with society through investment in infrastructure, the development of the best services adapted to the needs of society, always respecting medical policies that contribute to the best quality of life in the states and cities where we operate.

5.6. Ethical Principles

a) Shareholders and Investors:
· Value Creation: TPP is aimed at conserving, protecting and efficiently using the company's assets and ensuring the creation of value for our shareholders.

· Protection and Truthfulness: the information that TPP provides is complete, truthful, accurate and clear, to guarantee the satisfaction of investors' interests, thus protecting their investment.

b) Our collaborators and stable suppliers:
· Health and Safety: create working conditions that induce the safety, protect health, in a threatening or abusive environment.

· Compensations and Professional Development: the compensation to the collaborators will always be fair, as well as the guarantee of equal opportunities, in order to favor the integral development of the collaborators in all respects.

c) Suppliers:
· Objectivity: this is guaranteed with the TPP's internal controls, so that no person with a significant economic interest in a potential winning supplier is involved, directly or indirectly, in this purchasing process or in a decision associated to such supplier.

d) Society:
· Respect for the Law: TPP reflects its principles ethics with society always concerned and aimed at collaborating with social and economic development wherever the company operates, always following the applicable laws, rules or established norms.

· Integrity and Respect: TPP is committed to never being carried away by bribes from others towards the company or its collaborators. Respect is a very well established principle within TPP. which is our guide and one of our main foundations, therefore, we respect and make respect, by all our suppliers and collaborating companies, Human Rights.

· Integration: we promote the integration of local suppliers in our activities, always maintaining healthy competition among them giving an equal opportunity.

5.7. Behavior of collaborators

a) Respect the policies and regulations of TPP

b) Have the best disposition to customers, always providing clear and truthful information.

c) Use a language appropriate to the respect we show one another.

d) Respect among coworkers, thus creating a healthy, collaborative, anmonic environment, free from any threat, coercion or acts of violence. Those directed against the collaborators themselves are considered particularly serious.

e) Do not accept or make bribes or the like.

f) Communicate any breach of the Code of Ethics of which the Ethics Committee has reliable knowledge.

g) The physical and intellectual property of the company must be guarded by the collaborators.

h) Not to disclose strategic information, information about clients, shareholders or suppliers that are accessed for work reasons, since it is classified as confidential, and consequently treated as such.

i) Assign the use of computer and communication equipment only to carry out the work. The transmission of pornographic images, inappropriate images, images of visual aggression, the generation or transmission of viruses, the illegal copying of software or the distribution of e-mails for political or commercial purposes is prohibited.

j) Report to the company any conflict of interest derived from family relationships, friendship, professional or economic ties with competitors or suppliers.

k) Respect the working place, appearing correctly dressed and without the influence of any narcotics such as drugs or alcohol.

l) Do not use contacts or position for personal purposes.

5.8. Company Behavior

a) Respect the internal Policies and Regulations of TPP.

b) Respect your collaborators. Do not discriminate and, where appropriate, act energetically determined before any act of discrimination.

c) In order to preserve a healthy and harmonious environment, the company will provide help to collaborators who have family or social problems, and in turn will enable the necessary, adequate analysis and help them

d) To protect and safeguard the confidential information of the collaborators , considering the exceptions that are required, especially if they are of a legal nature.

e) Maintain and, where appropriate, establish fair salary compensation mechanisms, inform the employee of the objectives for which they will be evaluated, as well as the result of their evaluations, in order to make the clarifications that they consider appropriate

f) The hiring and promotion policies Internal should be based on the professional fence

g) Offer training and make available to employees the necessary tools to perform the job.

h) Respect the labor rights of workers

i)Establish the necessary mechanisms for the monitoring and control of the Code of Esica, ensuring confidentiality at all times in the treatment of complaints received. To this end, the Ethics Committee has been created.

5.9. Ethics Committee

a) Consultancy Body: doubts regarding how to solve problems in special situations, the decision taken should be consulted with the person in charge of a higher level. The Ethics Committee serves as the last instance to resolve or recommend an action to be followed, once the informed chain of command has doubts about the best way to proceed.

b) The Claims Service Body: all collaborators should direct to the Erica Committee to find out about any breach of the Code of Ethics, whether it is directly or indirectly affected, or to assess how to act in a certain situation that occurs.

c)Body for the Diffusion of Values: it will be in charge of spreading and disseminating among all collaborators the values, commitments and standards of conduct that are described in The Code of Eica, it will also promote positive actions that promote non-discrimination, equal opportunities , fair treatment and, in general, respect for Human Rights, inside and outside of TPP.

d) Activities: the Ethics Committee will carry out the following activities:

-Analysis and response to inquiries, complaints or reports received.

-Promotion of activities aimed at the propagation of the ethical principles that should inspire the activity of the company, as well as in favor of good behavior and respect for Human Rights.

-Make the modifications that are considered necessary to the Code of Ethics according to the new circumstances and realities of the company.

-Check the correct adaptation of the Code of Ethics in the company. 5.10- Rules of Action of the Ethics Committee.

e) Confidentiality: All complaints, as well as the problems of the collaborators, must be confidential and the Ethics Committee will have the duty to guarantee this confidentiality.

f) Guarantees: the Ethics Committee will guarantee an analysis exhaustive of a possible breach of the Code of Ethics.

g) Respect: The Ethics Committee will guarantee at all times the minimum respect for the rights of the people allegedly involved in the violation of the Code of Ethics.

After issuing any judgment, the presumed implicated person will be given the opportunity to give all the explanations and justifications that his right agrees, without having any type of coercion involved.

h) Grounding: All the decisions taken by the Ethics Committee, must be duly substantiated and justified.

j) Operation: the collaborators have the freedom to present their complaints or denunciations. However, it is expected from them an adequate criticism about the importance of thesebefore submitting them to the Ethics Committee.

In the event that the decision leads to any relevant fact or labor sanction, inform the Ethics Committee, the sanctions will only be applied with prior approval of it.

j) Form of contact: The collaborator can report any concern directly to any member of the TPP Committee, to make their complaints or denunciations in a formal way, the TPP Committee or the Ethics Committee will keep the following channels available to the

5.11. What can be reported?

*Note: all reports that are presented in relation to activities beyond the scope of TPP's regular operations that are not contemplated within this Eaica Code; They will be considered as inadmissible, releasing TPP from all responsibility for them.

Unethical conduct Description

• Bad practices in bidding for contracts and relationships with contractors Payments to agents to secure the award, payments by a smaller consortium or collusion between contractors to fix the price or share future projects. I pay a competitor to agree not to bid. Division of contracts to evade the minimum requirements. Manipulation of pre-qualifications of contractors in order to give preference to one. Disclosing information that gives a contractor an advantage. Inclusion of falsified costs. Falsification of material specifications or requirements for the purpose of obtaining profits through bribery or illicit business between the employee and the supplier.

• Abuse of Authority Abuse of authority occurs when a superior takes advantage of his position for his own benefit to treat a person improperly, unlawfully or illegally.

• Labor Harassment Actions exercised on a person or group of people in the workplace aimed at producing fear, contempt or discouragement. People receive unjustified psychological violence or moral harassment characterized by persistent harassment through negative and hostile acts by subordinate or superior peers.

• Sexual Harassment: The situation in which any unwanted verbal, non-verbal or physical behavior of a sexual nature occurs with the purpose or the effect of undermining the dignity of a person, in particular when an intimidating, hostile, degrading, humiliating or offensive environment is created

• Alcohol in the work environment Consumption of alcohol during the working hours established by the company for the execution of the activities affecting employee performance and productivity.

• Drugs Consumption of improper substances inside and outside the company's facilities, affecting the performance and productivity of employees.

• Conflict of Interest These are situations in which the judgment of a person, as well as the integrity of his actions, tends to be compromised by an economic or personal interest. There is a conflict of interest when the person guides her decisions, or acts for her own benefit or a third party to the detriment of the duty to be professional. For example: inappropriate relationships with customers, suppliers or vendors; selection of family, friends or acquaintances as providers without due process.

• Improper Hiring Employing staff for reasons that could be considered questionable under the organization's human resources policy and for which due diligence was not performed.

• Corruption It is about those activities where the employees of a company misuse their position, level, responsibilities, or their influences for personal gain. See Anti-Bribery and Anti-Corruption Policy.

• Bribery is a crime that consists of bribing an authority or public official by requesting a gift in exchange for performing or omitting an act inherent to their position.

• Discrimination is any verbal or physical conduct that is not encouraged and that causes annoyance to a person; They are aimed at denigrating and damaging and implies a hierarchical positioning of some social groups with respect to others that are markedly minority. The main reasons can be due to: gender, religion, physical characteristics, ethnic background, beliefs, sexual orientation.

• Disclosing or subtracting confidential information It is the theft and dissemination of confidential information to the detriment of the interests and prestige of the organization to obtain a personal benefit and / or third parties.

• Extortion is the threat of public defamation or similar damage that is done against someone, with the purpose of obtaining money or other profit. Said threat exerts pressure that can force a person to carry out an act against their will to the detriment of the norms established by the company

• Fraud commits fraud who by deceiving one or taking advantage of the error, illegally benefits or achieves an undue profit The use of occupation or employment for personal enrichment through the deliberate misuse or misapplication of the organization's resources or assets.

• Breach of Policies It is the lack, transgression or infringement of the rules and / or policies that define the company; for example: inappropriate use of work tools: failure to adhere to established business conduct; breach the established codes of ethics and / or internal regulations; Failure to obey dress codes.

• Money Laundering The process by which money is obtained illegally and passed off as having been generated from a legitimate source. Generally this crime is the end result of a previous criminal activity.This money is handled through one or more transactions to simulate its origin.

• Embezzlement of Funds Are those events of theft or misuse of the resources of an organization by an employee who seeks the appropriation of them; for example: theft of company-owned cash, false invoices, or inflated expense reports.

• Misappropriation of financial statements is the fraudulent or malicious recording and analysis of commercial and financial transactions with the purpose of generating financial statements that do not adequately reflect the economic reality of the company.

• Fictitious reimbursements are those fraud events where an employee requests reimbursement from the company for expenses supported by false or inflated invoices.

• Gifts gifts, gratuities and bribes. See Gift and Entertainment Policy

• Undue remuneration These are payments made under the concept of compensation and benefits for employees supported by false wage claims (ghost employees, requests for overtime not worked).

• Theft is the criminal taking and stealing company property with the intention of disposing of it from the rightful owner.

• Sabotage Destruction of belongings, such as tools or materials, of an organization causing losses and obstruction of production. For example: Destruction and theft of equipment, deliberate delays, computer viruses, etc.

• Bribery It is defined as the act of offering, giving, receiving or soliciting money or any object of value for the purpose of influencing an official act of an authority or a business decision. Bribery is considered to be improper payments to obtain preferential treatment, a favorable reward and influence a business decision or allow fraudulent acts. See Anti-Bribery and Anti-Corruption Policy.

• Violations of security regulations is the breach of the security regulations established by the company, which are necessary for the development of a safe environment within the organization. Such noncompliance puts staff, material resources, and the organizational environment at risk.

• Violence is the intention to cause injury or damage to a person or their property.

5.12. Communication

a) The Human Resources Deputy Management and the Management Coordination will be responsible for ensuring that all current personnel and those who are new to TPP, receive a copy of the Code of Ethics, obtaining a signature of receipt, knowledge of the content and acceptance to its fulfillment.

b) It is the responsibility of each TPP collaborator to fully comply with and respect the provisions set forth in the Code of Ethics, being entitled to the appropriate sanctions in case of non-compliance, including, among others, justified dismissal.

c) The Ethics Committee will be responsible for investigating complaints or complaints submitted by a collaborator and reporting the results of the same in the formats and means it deems appropriate.

6. Disciplinary Regime:

It is the responsibility of each and every one of the Directors, managers and employees of TPP to strictly comply with the provisions of this policy, and it is the responsibility of the directors and managers to explain and publicize this policy among their collaborators and monitor its compliance.

Supervision mechanisms will be implemented to verify the application of the provisions of this policy. If there is any evidence of possible breaches of what is established herein, the appropriate investigation will be carried out.

Regular audits will be conducted and annual reports on the results will be provided to the TPP Council.

The violation of what is established in this policy will be considered an infraction subject to disciplinary action determined by the Ethics Committee in accordance with the Internal Work Regulations, after its timely analysis and in accordance with the applicable labor regime; In any case, the most serious being any form of corruption or bribery, the TPP Council will be notified.

7. Controversies:

Any change, controversy or exception to this policy must be analyzed by the TPP Committee and, if it is serious or if there is a conflict of interest, it must be approved by the TPP Council.