Tenet Consultores, S.C. (hereinafter, “Tenet”) is committed to meeting the highest standards of professionalism, integrity, and social responsibility in providing its services and to encouraging all its employees, collaborators, and suppliers to assume the same commitment. This Code of Conduct describes our ethics and integrity, and information privacy and security policies, among other aspects, to which Tenet adheres in providing its services and within its organization.
Tenet is committed to the highest ethical standards and to complying with all applicable laws, rules, and regulations. In particular, Tenet requires our partners, managers, employees, collaborators, and suppliers to comply with the following standards:
Tenet strictly prohibits the promotion, performance, concealment or any other activity aimed at carrying out acts of corruption, including, but not limited to, the payment of bribes, nepotism, collusion, influence peddling, bribery, providing payments to facilitate or accelerate processes and, in general, any activity, conduct, action or omission involving payment in cash or in kind, granting of advantages, privileges, services, taking over debts or obligations or providing excessive attentions, directly or through third parties, to public officials, entities that manage public resources and have authority power over individuals, private companies or their directors, with the purpose of avoiding or evading compliance with a legal, administrative or judicial provision, a code of conduct, a declaration of ethical principles of any company, or with the purpose of obtaining a business advantage or a decision that otherwise would not happened if not as a consequence of such activities, conducts or omissions.
Likewise, acts or omissions involving an abuse of any power position that generate a particular benefit, at the expense of the collective or individual welfare, are not permitted in Tenet.
Consistent with the foregoing, Tenet’s partners, directors, employees, collaborators, and suppliers are absolutely prohibited from offering, giving, accepting, or receiving any gift that has the purpose or result of influencing their performance within Tenet or the performance of third parties, whether they are part of a company or public officials, to generate improper advantages or benefits. Gifts include benefits in kind, fees, commissions, travels, donations, cash, gratuities, excessive value dinners, entertainment, or any other gift, advantage, benefit, or incentive comparable to the aforementioned concepts that do not have a promotional value but are substantial and may be considered as a bribe or violate anti-corruption laws.
Our Tenet partners, directors, employees, collaborators, and suppliers must refrain from any act that contravenes the provisions of this section and fully comply with the requirements of all anti-bribery and corruption laws (e.g., Ley General de Responsabilidades Administrativas, the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, etc.).
At Tenet, we provide advisory services to companies that may be engaged in the same line of business and, therefore, be competitors. In addition, our partners participate or may participate in the boards of directors of some financial institutions, or as investors in other companies. However, Tenet is committed to ensuring that these situations do not interfere with the quality of our services or our responsibilities to each of our clients. Taking care of the interests of each of our clients is our objective and priority.
Because our services are primarily focused on providing advice to our clients in order to comply with the regulatory framework in the most efficient manner and, in addition to the confidential treatment of each matter we handle, our services do not involve the use of our clients’ information in favor of others. Each matter will be treated with independence, objectivity, and professionalism while taking care at all times of the best interest of each of our clients.
In any event, prior to entering any business relationship with our clients, we shall advise them of any matter in which Tenet is involved that may present a conflict of interest with Tenet, its partners, directors, employees, collaborators, partners, suppliers, or other clients. Should Tenet believe that services requested by a client actually involve a conflict of interest, Tenet will refrain from providing such services.
Our partners, managers, employees, collaborators, and suppliers are required to disclose to Tenet any situation that involves or may involve a conflict of interest about our clients’ business affairs in which they are involved.
At Tenet, we are aware that the information entrusted to us by our clients may be strategic, and therefore, we are committed to treating it with the utmost confidentiality. Thus, we are obligated to our clients in the documents we sign when entering a legal relationship with them or even prior to doing so.
Tenet has implemented the highest standards of information security. The computer equipment used by our partners, managers, employees, and collaborators is owned by Tenet and configured by the firm to control access to the information Tenet receives, processes, stores, and transfers, as well as to install tools against cyber-attacks. All data handled by Tenet is processed and stored on servers of our internationally recognized cloud computing providers with the highest information security certifications.
In addition, Tenet follows the principle of least privilege in providing access to client information; that is, Tenet only grants access to information and privileges of use that are strictly necessary for the performance of the partner’s, director’s, employee’s, or collaborator’s duties. In addition, all partners, directors, employees, and collaborators are legally bound to maintain the confidentiality of the information to which they have access in connection with the matters in which they are involved.
Personal data to which Tenet has access is treated confidentially and is governed by Tenet’s Privacy Notice, which is available on our website at https://tenet.com.mx/.
Personal data is treated with the same security measures as described above.
At Tenet, we strive to respect the labor rights of our employees and strictly comply with Mexican labor laws. We also foster an inclusive culture, providing equal opportunities to our employees and collaborators regardless of gender, sexual preference, ethnic or national origin, age, marital status, social status, religion, opinions, or any other cause. Therefore, we do not tolerate any type of discrimination within Tenet.
In November 2023, Tenet adhered to the United Nations Women’s Empowerment Principles, so we are seriously committed to (i) promoting gender equality; (ii) treat all men and women equally at work, respect and uphold human rights and non-
discrimination; (iii) ensure the health, safety and well-being of all workers; (iv) promote women’s education, training and professional development; (v) implement business development, supply chain, and marketing practices in favor of women’s empowerment; (vi) promoting equality through community initiatives and leading with effort, (vii) evaluating and disseminating progress made in favor of gender equality.
In addition to maintaining a safe and respectful workplace, we provide facilities for our employees and collaborators to perform their activities remotely, without compromising the quality and confidentiality of the services that Tenet provides. We also promote the physical and emotional well-being of our team, as well as provide constant training and support to them to expand their knowledge through courses, diplomas, or other postgraduate studies that may be of interest to them.
Tenet does not tolerate physical violence, threats, physical punishment, coercion, verbal abuse, disrespectful conduct, harassment, or bullying of any kind to our partners, managers, or employees. Such acts against any member of Tenet, whether by an insider or one of our clients, shall be grounds for termination of Tenet’s legal relationship with the aggressor.
Any such conduct may be reported anonymously to Tenet by emailing denunciaanonima@tenet.com.mx. Tenet will treat the information submitted as confidential so long as it does not prevent an investigation of the matter.
At Tenet, we are committed to reducing the environmental impact of our activities and working with our partners, managers, employees, collaborators, and suppliers to do the same. Therefore, we promote savings in the consumption of energy, fuel, water, and paper and encourage recycling.
Any violation of this Code of Conduct detected may be grounds for contractual termination with our partners, employees, collaborators, or suppliers without prejudice to any legal action that may be taken depending on the seriousness of the violation. Tenet reserves the right to grant the implementation of a corrective measure to the offender, if the violation is not severe and can be corrected, instead of contractual termination.
Any violation of this Code of Conduct may be reported anonymously to Tenet by emailing denunciaanonima@tenet.com.mx. Tenet will treat the information submitted as confidential so long as it does not prevent an investigation of the matter.
This Code of Conduct does not supersede any applicable law or any contractual terms or provisions that Tenet has entered into with its clients, partners, directors, employees, collaborators, or suppliers. To the extent that there is any conflict between this Code of Conduct and any applicable law or contractual provision, the applicable law or contractual provision shall govern.
Tenet reserves the right to update or modify the provisions of this Code of Conduct. Any such changes shall be communicated to our clients, partners, officers, employees, and suppliers by whatever means Tenet deems most effective.