an
ethical culture

Compliance Policies and Codes

ll of the global policies of Grupo Bimbo are available on the company’s internal website, and each year associates are asked to sign a statement that they understand and commit to those policies.

Global Integrity Policy

Establishes general guidelines and parameters to ensure that the Company, its associates and representatives, not only understand and comply with local and international anticorruption laws in their roles, activities and in every relationship they may form as they do business, but also that they are guided by the correct way of acting with their social and commercial environment.

Global Antitrust Policy

Global Antitrust Policy provides guidelines onthe commercial practices and relations of GrupoBimbo associates, to guarantee that they abidestrictly by laws regarding free competition inthe markets in which we participate. The policyapplies to all Grupo Bimbo’s associates, businessunits, affiliates and subsidiaries, wherever in theworld they are or whatever their function.

Global Policy
on Human Rights

We make sure that everyone who works at Grupo Bimbo is trained according to an ethical, responsible vision, generating a positive reality that encompasses both their professional and personal lives.

Global Conflicts
of Interest Policy

Establishes general guidelines on handling and reporting conflicts of interest, fostering a climate of trust and integrity within Grupo Bimbo, its subsidiaries and affiliates.

Code of Ethics

In order to build a sustainable, highly productive and fully human company and to earn the preference of our customers, clients and associates.

This document provides a regulatory framework to guide those standards of conduct, outlining our stance on various related issues and the criteria to follow in situations of non-compliance.

Global Policy for the Protection
of Personal Information

Regulates the lawful treatment of personal data at Grupo Bimbo in order to guarantee privacy and prevent any breach of security.

Compliance
program

Legal and Compliance Department promotes, regulates and standardizes various aspects of integrity and transparency within Grupo Bimbo through a compliance program aimed at ensuring that all activities and processes are sustained by ethics, honesty and best practices, following internal and external rules and regulations. This strengthens our integrity model by preventing, identifying and remediating any risks that might jeopardize the Company.

Anti-corruption

Every year, the Integrity Compliance Program is subject to external assessment by an independent third party who is expert in the field.

In 2021, we conducted assessments measure our integrity, money-laundering and personal data protection risks in Mexico, Venezuela, Ecuador, Brazil, India, China and Kazakhstan.

At Grupo Bimbo, training and awareness- building in the matter of integrity is highly important for both associates and at-risk counterparties. With this in mind, every year we reinforce communication with associates through integrity shorts, which can be used at the start of work meetings or gatherings. Also, in 2021 we began providing integrity training to high risk third parties.

Communication on Policies and Procedures

Our zero-tolerance policy on breaches of integrity has had outstanding results; to date we have received no reports of any confirmed case of public corruption.

This includes the Grupo Bimbo Steering Committee and the administrative, middle management, executive and senior management levels. For our operating staff, messages on integrity are conveyed through the People and Communication teams of each organization, as well as by the leaders of the Functional Divisions.

Speak Up

speakup@grupobimbo.com


Speak Up is a secure mechanism that guarantees absolute confidentiality, f ree of reprisals, for anyone who wants to express a concern, while maintaining the job security that every associate, partner, shareholder and supplier deserves.

Through collaborative teams formed by representatives from the Global Departments of Compliance and Audit and KPMG, our independent auditor, in 2021 staff members from Speak Up, researchers and the call center were trained in investigating and responding to reports regarding labor issues, regulatory framework, and the program for fraud risk management.

Sustainability Governance

To guarantee maximum positive impact, we created a Sustainability Strategy, underpinned by a solid corporate governance structure that establishes mechanisms for acting transparently, accountability and tracking progress toward our commitments and goals.

  • Manage and guide progress in the area of sustainability.
  • Measure and monitor sustainability performance results.
  • Ensure that strategic and tactical decisions are aligned with our sustainability goals.
  • Provide clarity and transparency in matters of sustainability.

To articulate these efforts for the best possible results, we have divided our governance structure into two levels:

Over the course of the year we compiled compendiums of the eight major initiatives and fundamentals, documenting the way our strategy is managed as well as the minimum standards and action lines for achieving the targets of each initiative. These guides, like the Policy on Sustainability, are the basis for each business unit, through its local committee, to identify opportunity, devise action plans and track their KPIs and activities.

The Global Sustainability Division and global leaders work to ensure compliance with practices and projects. Every year the business units are sent a guide to the projects they must include in their operations’ Capex, depending on their risks, strategies and opportunities.

Materiality

As part of our commitment to our stakeholders and sustainability, Grupo Bimbo conducts a regular materiality study to decide on the next steps to take, considering the company’s strategy and its diagnosis of environmental, social and economic issues, along with the principles established by the Global Reporting Initiative (GRI).

Responsible management practices in the supply chain.

Innovating healthier products.

Sustainable packaging and circular economy.

Ethics and integrity.

Human rights in the value chain.

Water stewardship.

Energy efficiency and renewable energy.

Waste management.

Climate change adaptation and mitigation.

Product quality and safety.

Risks, Impacts
and Opportunities

The greatest impacts caused by Grupo Bimbo are:

1. Our carbon footprint:
Resulting from our operations and the distribution of our products.

2. Our water footprint
One of the issues found to be meta-material for stakeholders.

3. Human Rights
We work to set general guidelines on respect for human rights, in keeping with the culture of Grupo Bimbo and with national and international laws and global instruments.

4. Regenerative farming
Through our work with farmers we have a positive impact on our carbon footprint and opportunities for development in the community.

5. Waste
Food waste and other types of waste are key issues for coming years, and will determine our ability to better manage our resources.

6. Improved nutritional profiles
We continue this important effort to improve nutritional profiles and bring products that meet the world’s lifestyle and nutritional requirements.

7. Plant-based diets
The food crisis and climate change have together made it necessary to find dietary alternatives that are less aggressive with the planet, such as plant- based diets. We need to include the diversity of grains that exist on our planet to offer a specialized portfolio to those who decide to adopt this type of diet.

8. Transparent, healthy brands
There is a pressing need to offer brands committed to a cause, and a commitment to contribute to well-defined causes that inspire and motivate consumers to join in supporting them.

9. Community engagement and support
We are committed to improving quality of life in the communities where we operate, and we want to contribute to their prosperity, build resilient communities and better lives for all.

Corporate Governance