Environmental, Social, and Governance, Health and Safety Policy
Business Ethics
1.1 General. All ABC employees respect the laws and regulations of the countries in which it operates and require its business partners to do the same. ABC will not accept any form of corrupt activity, including bribery, conflicts of interest, fraud, extortion, embezzlement, and illegal gratuities, and its business partners will not engage in, or cause their employees to engage in, any form of corrupt activity. We are committed to ensuring that any private or public security force contracted to protect our operations respects human rights and operates in accordance with the principles of proportionality and legality.
1.2 Competitors and Antitrust Laws. ABC’s business partners will comply with applicable competition and antitrust laws and regulations. This includes, among other things, not engaging in price fixing, market sharing, fraudulent bidding, or customer allocation.
1.3 Anti-Bribery. ABC will not accept fraud or incentive payments in any form.
1.4 Conflicts of Interest: All conflicts of interest between a business partner and ABC must be avoided. ABC expects that, in its business interactions, all confidential information provided by ABC will be protected and the intellectual property of its business partners will be respected. ABC will not tolerate conflicts of interest arising from external business activities, personal financial interests, or employing, purchasing from, or selling to family members or individuals with whom there is a close personal relationship.
1.5 Business Ethics: ABC and its partners will conduct business with honesty and integrity and demonstrate the highest standards of business ethics. No actions will be taken to unduly impact the results of any audit, including the submission of falsified records or employee coaching. In accordance with the gift and entertainment policy, ABC and its business partners will not offer any incentives to company employees or representatives of audit firms. 1.6 Monitoring and Compliance: ABC will implement affirmative measures, such as announced and unannounced on-site audits, to monitor compliance with the Social Responsibility, Health, Safety, and Environmental Policy. Business partners must maintain on-site all documentation necessary to demonstrate compliance with this policy. Business partners are expected to take the necessary corrective actions to promptly remedy any non-compliance. Suppliers are expected to actively participate in the resolution process, including the timely preparation and submission of a Preventive Corrective Action Plan. ABC reserves the right to terminate its business relationship with any business partner or collaborator who is unwilling to comply with this Social Responsibility, Health, Safety, and Environmental Policy.
Objectives
Integration of business ethics and good corporate governance practices into the Company’s business and commercial practices to prevent corruption and promote responsible business conduct through:
Complying with 100% of the annual business ethics training and awareness plan
Following up on and resolving 100% of corruption complaints received
Proactively managing ESG risks to address negative impacts and capitalize on opportunities that could be associated with the Company’s activities, its supply chain, and business relationships, with respect to workers, human rights, the environment, consumers, corporate governance, and business ethics.
Maintaining an up-to-date ESG risk matrix and complying with the plan for controlling and mitigating high ESG risks.
Ensure the integration of ESG issues into decision-making and a commitment to improving the Company’s sustainability performance in alignment with global ESG trends and stakeholder requirements, through GRI reports, dual materiality analysis, adherence to international initiatives, and participation in ESG events.
Promote ethical, social, and environmental responsibility in the Company’s supply chain through a supplier development program focused on ESG aspects.
Promote the regionalization of the Company’s supply chain for local social development, job creation, and environmental impact reduction, incorporating and measuring the strengthening of local suppliers annually.
Promote and enable responsible and sustainable purchasing in our supply chain, incorporating environmental considerations into the annual selection of products for our production processes.
Human Rights and Labor Legislation
2.1 Child Labor: At ABC, to protect children and prevent work that could endanger their physical, mental, or spiritual health, harm their moral or social development, or interfere with their education, we are committed to not employing minors or participating in activities that contribute to child labor and require our business partners to do the same.
2.2 Forced Labor: ABC will not promote or accept any form of forced labor or debt bondage, “prisoner-slave” employees, or illegal labor, and expects our business partners to do the same.
2.3 Discrimination, Harassment, and Diversity: ABC values and promotes diversity and gender equality, and supports women’s rights in all areas of our operations and supply chain. We value diversity in all its forms and strive to create an inclusive environment where all people are treated with dignity and respect. We are guided by values and a code of conduct. ABC will not tolerate any form of discrimination or harassment in the workplace. Like our business partners, we will not discriminate against any employee on the basis of race, ethnicity, sexual orientation, gender, religion, age, disability, political opinion, nationality, or other potentially discriminatory factors. We respect cultural differences and guarantee employment based on job requirements, not personal qualifications. We respect the rights of minorities and indigenous peoples and are committed to consulting with and obtaining their free, prior, and informed consent on projects that may affect their rights. No employee will be subjected to corporal punishment, physical, sexual, psychological, or verbal harassment, or abuse. Monetary fines are not used as a disciplinary practice. ABC seeks to ensure a work environment in which all individuals are treated with respect and dignity and are offered equal opportunities for development. We are committed to conducting ethical recruitment processes based on equal opportunities and respect for the human rights of all candidates.
2.4 Employment Contracts, Working Hours, and Compensation: ABC complies with and requires its business partners to comply with all salary and compensation requirements defined in applicable Mexican labor laws and regulations, including overtime, production rates, and other employee compensation and benefits. Furthermore, salaries are paid regularly and in accordance with local legislation and current labor market conditions. Employees are entitled to at least one day off for every six worked, and to enjoy the local and national holidays stipulated by law.
2.5 Freedom of Association and Collective Bargaining. ABC and its business partners recognize and respect the right of workers to exercise their legitimate rights of free association, including joining or not joining any association. Suppliers must also respect the legal right of workers to collective bargaining.
2.6 Alcohol and/or Drug Abuse. ABC proactively strives to eliminate any type of workplace hazard. Those who manufacture products or provide services for ABC must not come to work or company premises if they are under the influence of alcohol or its adverse effects to the point that it impairs their ability to perform their duties. ABC has zero tolerance for drugs and will not allow those who manufacture products or provide services for ABC to come to work or company premises under the influence of drugs.
2.7 Communication: ABC implements and expects business partners to communicate the provisions of ABC’s Environmental, Social Responsibility, Health, Safety and Governance Policy to all their employees.
Objectives
To ensure that our recruitment, compensation, mobility, and development processes operate under principles of equity and inclusion, fostering a work environment that celebrates diversity and combats all forms of discrimination. This is achieved through monitoring and tracking the number of women in the workforce, in leadership positions, and in STEM jobs; the number of women promoted within the organization; and the number of men and women on paternity and maternity leave, respectively.
Measure annually the incorporation of migrants, older adults, and people with disabilities into the workforce, as well as the number of jobs suitable for people with disabilities.
Ensure that the Company demonstrates key capabilities in diversity, equity, and inclusion, and ensure the competence and awareness of Company personnel through:
Establishing and implementing a work plan aimed at raising awareness of human rights and inclusion at all levels of the organization.
Following up on and closing 100% of reported cases of discrimination, equity, and equality.
Promoting wellness and quality of life practices for employees and their families, focusing on socio-emotional factors, addiction prevention, legal guidance, and other areas.
Health and Safety
3.1 Work Environment. ABC systematically addresses health and safety, always ensuring a safe work environment, and expects its business partners to do the same. Risks that could cause accidents or harm the health and well-being of individuals while working for ABC will be reduced. Therefore, occupational health and safety risks will be identified, assessed, and managed through a prioritized process of risk elimination, technical controls, and/or administrative controls. ABC defines a safe work environment as, for example, ensuring that work areas are clean and free from contamination, that the machinery used in production is safe and does not endanger the health of employees, and that instructions regarding the use of personal protective equipment and work equipment are followed precisely. Personal protective equipment and work equipment will be provided to employees. Furthermore, the workplace must be well-lit and maintain temperature and noise levels at acceptable levels. When noise exceeds acceptable levels, personal protective equipment will be used.
3.2 Emergency Preparedness and Response. Hazardous equipment and materials must be stored in accordance with applicable laws. Clearly marked emergency exits are available and must never be blocked; they are well-lit. All employees will receive training on safety measures such as emergency exits, safe use of fire extinguishers, first aid, etc. Each plant has an Internal Civil Protection Plan, with trained brigades and emergency equipment for responding to emergencies Likewise, as part of the controls defined for identified risks, mechanisms are in place to evaluate and manage ergonomic risk factors, seeking the well-being of all our employees and stakeholders. All units are equipped with adequate and clean restrooms and sinks. ABC expects the same from its business partners.
3.3 Risk Assessment and Prevention. We will conduct periodic fire risk assessments at our facilities to identify potential hazards and implement appropriate fire prevention measures.
3.4 Regulatory Compliance. We are committed to complying with all fire safety regulations, standards, and codes established by local authorities and regulatory bodies.
3.5 Fire Detection and Alarm Systems. We will install and maintain reliable fire detection and alarm systems in all our facilities to ensure timely notification of any fire incident.
3.6 Firefighting Equipment We will provide appropriate firefighting equipment, such as fire extinguishers, fire hoses, and sprinkler systems, and ensure that they are regularly inspected, tested, and maintained in working order.
3.7 Evacuation and Emergency Procedures We communicate clear emergency evacuation procedures to all employees and visitors, including designated assembly points and evacuation routes.
3.8 Training and Awareness We will provide comprehensive fire safety training to all employees, contractors, and relevant stakeholders, covering topics such as fire prevention, emergency evacuation procedures, and the proper use of firefighting equipment.
3.9 Emergency Response Plan An effective emergency response plan is in place to coordinate actions in the event of a fire, including procedures for notifying emergency services, evacuating personnel, and managing the situation until help arrives. 3.10 Collaboration and Communication We foster collaboration with local fire authorities, neighboring businesses, and other stakeholders to improve fire safety awareness and preparedness in our community.
3.11 Continuous Improvement We regularly review and update our fire safety policies, procedures, and practices to reflect changes in regulations, technology, and best practices, ensuring the continued effectiveness of our fire safety program.
3.12 Accountability and Compliance We hold all employees accountable for compliance with fire safety policies and procedures and will take appropriate disciplinary action for any violations. We will also conduct periodic audits to ensure compliance with fire safety regulations and standards.
3.13 First Aid and Medical Care ABC maintains first aid equipment in appropriate locations, and each plant has trained emergency personnel. In the event of an accident involving an employee or stakeholder, initial assistance will be provided, the cause will be investigated, and corrective actions will be taken to prevent recurrence.
Objectives
Environment
4.1 Environment and Sustainability. ABC will comply with all applicable environmental legal requirements and will require its business partners to obtain, maintain, and comply with all necessary environmental permits and licenses for their operations. ABC encourages the development and dissemination of environmentally friendly technologies and recommends that all business partners with a significant environmental impact implement certifiable environmental management systems or similar systems that facilitate their environmental stewardship.
At our company, we recognize the critical importance of protecting and respecting the rights of land, forests, and water, and of preventing forced displacement in all our operations and business activities. We are committed to taking concrete steps to ensure that our operations do not contribute to environmental degradation or human rights violations against local communities, and that these sustainable natural resource management practices minimize our environmental impact, including protecting sensitive areas, conserving biodiversity, and reducing pollution.
4.2 Land, Forest, and Water Rights: We commit to respecting the rights of local communities and Indigenous Peoples to land, forests, and water, in accordance with applicable national and international laws and internationally recognized standards.
4.3 Consultation and Free, Prior, and Informed Consent: We recognize the right of local communities and Indigenous Peoples to be consulted and to give their free, prior, and informed consent before any projects that may affect their lands, forests, or water resources are undertaken.
4.4 Prevention of Forced Eviction: We commit to respecting the rights of local communities and Indigenous Peoples to housing, land, and livelihoods, and to preventing any form of forced eviction in the context of our operations.
4.5 Transparency and Accountability: We commit to transparency in our operations and to being accountable to stakeholders for our actions and decisions related to land, forests, water, and forced eviction. 4.6 Collaboration with stakeholders We are committed to collaborating constructively with local communities, indigenous peoples, non-governmental organizations and other stakeholders to address challenges related to land, forests, water and forced eviction and to promote sustainable solutions.
4.7 Renewable Energy and Decarbonization We are committed to progressively increasing the use of renewable energy in our operations and reducing our greenhouse gas emissions to contribute to the decarbonization of the economy.
4.8 Responsible Chemical Management We are committed to managing chemicals responsibly in our operations, minimizing risks to human health and the environment, and complying with applicable regulations and standards.
4.9 Sustainable Resource Management We are committed to using natural resources efficiently, reducing the consumption of water, energy, and materials, and promoting reuse and recycling in all our activities.
4.10 Biodiversity We are committed to protecting and promoting biodiversity in all our operations, conserving natural ecosystems and supporting the restoration of degraded habitats. We are committed to complying with all laws, regulations, and international standards regarding animal welfare and to implementing continuous improvement programs and collaborative agreements with experts and organizations dedicated to animal welfare.
4.11 Land Use and Deforestation We are committed to using land responsibly, avoiding the conversion of natural ecosystems such as forests, wetlands, and agricultural lands to unsustainable uses, and contributing to the fight against deforestation.
4.12 Evaluation and Continuous Improvement We are committed to regularly evaluating our environmental performance, setting ambitious sustainability goals and targets, and taking action to continually improve our environmental impact. At ABC, we are committed to integrating these principles into all our operations and business activities, and to continuously working to improve our performance regarding land rights, forests, water, and forced evictions. We are constantly seeking ways to reduce our resource consumption (including energy, waste, and water), prevent pollution, reduce greenhouse gas emissions and positively impact our carbon footprint, maintain acceptable noise levels, and improve the overall environmental impact of our operations and products throughout the value chain. It will avoid conflict minerals and, in addition, chemical and hazardous materials must be properly labeled and stored safely, recycled, reused and disposed of properly.
Objectives
To promote innovative practices by incorporating circularity principles and increasing the percentage of aluminum in our operations to effectively advance our decarbonization efforts, including incorporating billets made with pre- and post-consumer aluminum into our aluminum profile manufacturing process, resulting in a lower carbon footprint.
To ensure responsible waste management, reduce waste generation at the source, and promote its recovery through authorized suppliers to effectively advance our zero-waste efforts, increasing the recycling rate, avoiding landfilling as a final disposal option, and seeking recirculation, co-processing, and recycling options for all our waste.
To promote efficient water use in the Company’s operations, ensure the optimal quality of our wastewater discharges, and incorporate circularity practices that allow us to transition to a zero-discharge operation, with the operation of treatment plants that enable the proper treatment and reuse of water.
To ensure the quality of emissions to the atmosphere in accordance with current regulations that affect air quality through monitoring and control, by means of programs for the proper management of emissions.