Compliance Policy

1. Purpose

The management of MCI Group, aware of the importance of defining and formalizing its Compliance Policy, has mandated the implementation of an independent Compliance Management System with sufficient authority to carry out its activities in accordance with prescribed System Procedures. This ensures compliance with applicable regulations and the requirements of the Compliance Management System, providing assurance to clients and society.

This policy aligns with MCI’s ethical values and confirms the company’s commitment to maintaining lawful and ethical conduct. It defines the framework of compliance principles that govern the company’s operations.

This policy reflects MCI’s culture of integrity and adherence to regulations, considering both organizational interests and stakeholder expectations. It is aligned with MCI’s strategic objectives and reinforces the company’s zero-tolerance stance toward any conduct that could constitute a criminal offense.

For this reason, the full commitment of Management and all MCI members is required.

2. Principles

The main duties of the Compliance Body are outlined as follows:

• Independently drive and oversee the implementation of the Compliance Management System, ensuring that all affected parties have access to MCI’s compliance regulations.
• Identify compliance obligations, keeping them updated and disseminating them to organizational members.
• Identify and manage compliance risks by analyzing and assessing them to prioritize actions and resource allocation for prevention, detection, and management.
• Promote the use of MCI’s reporting channels and ensure that whistleblowers face no retaliation.
• Organize awareness and training cycles to equip affected parties with the necessary knowledge and competencies for compliance risk management. Additionally, it is responsible for promoting training programs and ensuring adherence to MCI’s Code of Ethics and Conduct, as well as compliance policies and procedures.
• Advise both the management of MCI Group and any other organization members who require assistance from the Compliance Committee, reporting to the Governing Body and Senior Management on Compliance Management System performance.
• Properly document and make available compliance-related information, except for confidential materials restricted to certain organizational areas. This documentation should be accessible, suitable for use, and traceable.
• Measure the performance of the Compliance Management System through indicators, ensuring that all elements function correctly and promoting continuous review and improvement.

3. Obligations

Compliance with laws and the proper functioning of the Compliance Management System is the responsibility of all MCI members, regardless of their position within the organization. They are expected to uphold ethical behavior, refrain from criminal offenses, and follow any instructions provided by the Compliance Body in the course of its duties.

All organizational members must understand, observe, and apply the provisions of this Compliance Policy, collaborating with the Compliance Body, Governing Body, and Senior Management as necessary. They must adhere to the Code of Ethics and Conduct and immediately report any potential or actual criminal activity to the Compliance Body.

Additionally, all members are expected to comply with this Compliance Policy, attend designated compliance training sessions, and promptly provide any requested information or documentation to the Compliance Body.

4. Knowledge and compliance statement

This policy is provided to all organizational members and is available on the corporate intranet.

Furthermore, MCI will make this policy available to third parties through its corporate website.

Members in positions particularly exposed to criminal risks must submit an annual statement of compliance with this Compliance Policy.

5. Consequences of non-compliance

In accordance with the Code of Ethics and Conduct and this Compliance Policy, all affected parties, regardless of hierarchical level or geographical or functional location, must comply with the established principles and procedures.

To ensure proper implementation of the Compliance Management System, MCI encourages the reporting of any violations through its Whistleblower Channel.

To enforce this policy, MCI has established a Compliance Disciplinary System. This serves as an internal guide to demonstrate the effective implementation of the Compliance Management System and enables the organization to sanction regulatory breaches in accordance with applicable labor laws or relevant professional relationship regulations. The regulatory framework includes the MCI Code of Ethics and Conduct, internal policies and procedures, and applicable laws and best market practices.

The Disciplinary System aligns with the provisions of the national Penal Code and applies to all violations outlined in the Compliance Management System.

Sanctions imposed for labor-related breaches will be proportionate and compliant with applicable regulations while maintaining strict enforcement.

If it is confirmed that an organizational member’s actions constitute a criminal offense attributable to MCI as a legal entity, the matter will be reported to the relevant Public Authorities. This notification will include any evidence and/or indications gathered.