We are committed to conducting business with integrity, transparency, and respect for the law. Our Ethics & Compliance framework ensures that every decision and action aligns with the highest standards of professional conduct.

We adhere to all applicable regulations, promote accountability at every level, and foster a culture where ethical behavior is the foundation of trust with our clients, partners, and stakeholders.

How to ask a question or raise a concern:

The MBT Speak Up Helpline is an anonymous reporting channel for all stakeholders to report any type of issue or concern – from product quality and safety to management practices. Anyone who retaliates against a reporter will be subject to discipline.

MBT has zero tolerance for retaliation of activities that impact good-faith reporting, and anyone engaging in retaliatory behavior is subject to disciplinary actions.

GRUPO MBT Code of Conduct

Our Code of Conduct serves as the foundation of our corporate culture, guiding how we work, interact, and make decisions. It outlines our commitment to integrity, respect, accountability, and professionalism in every aspect of our business. We expect all employees, partners, and stakeholders to uphold these principles, ensuring that our actions reflect the highest ethical standards and strengthen the trust placed in us.

Our Code Supplements provide additional guidance and clarifications to our Code of Conduct, addressing specific scenarios and operational practices. These supplements ensure that employees and partners have practical resources to interpret and apply our ethical and compliance standards consistently. They serve as a framework for decision-making, helping us maintain accountability, transparency, and integrity across all business activities.

Accounting, Internal Controls or Auditing Matters

We are committed to maintaining accurate financial records, robust internal controls, and transparent auditing practices. Our framework ensures compliance with applicable laws and regulations, while promoting accountability and ethical financial management. We encourage open reporting of any concerns related to accounting, financial integrity, or auditing matters, and we have established procedures to investigate and address such issues promptly, fairly, and confidentially.

How we manage enterprise risk

We take a proactive and structured approach to enterprise risk management, integrating risk awareness into every aspect of our strategy and operations. Through continuous identification, assessment, and monitoring of potential risks, we safeguard our business, stakeholders, and long-term objectives. Our framework combines strong governance, internal controls, and compliance practices with a culture of accountability and transparency. By anticipating challenges and preparing effective responses, we ensure resilience, protect value, and support sustainable growth.

Antitrust

Corruption

Data Privacy and Security

Government Contracts

Global Trade

How we pursue anti-corruption initiatives

Winning Business Solely on the Merits

Books and Records

Third-Party Intermediaries

Training

Assessment

Reporting and Investigations

We are fully committed to conducting business in strict compliance with all antitrust and competition laws. Our practices are designed to promote fair competition, protect consumer trust, and ensure transparency in the marketplace. We prohibit any form of collusion, price-fixing, bid-rigging, or unfair trade practices, and we expect all employees and partners to uphold these principles. By fostering open and fair competition, we safeguard our integrity and create long-term value for our clients and stakeholders.

We maintain a zero-tolerance policy toward all forms of corruption, including bribery, extortion, or any improper advantage. Our commitment is to operate with integrity, fairness, and transparency in every market where we do business. Employees, partners, and third parties are strictly prohibited from engaging in corrupt practices, whether in dealings with government officials or private entities. Through clear policies, training, and oversight, we ensure compliance with anti-corruption laws and uphold the highest ethical standards in every transaction.

We are committed to protecting the confidentiality, integrity, and availability of all information entrusted to us. Our Data Privacy and Security framework ensures compliance with applicable laws and industry standards, while safeguarding personal and business data against unauthorized access, misuse, or breaches. We apply strict policies, advanced technologies, and continuous monitoring to protect sensitive information. Every employee and partner shares responsibility in maintaining these protections, ensuring trust, accountability, and resilience in our operations.

We are dedicated to delivering high-quality solutions and services in full compliance with government contracting requirements. Our approach emphasizes transparency, accountability, and strict adherence to all applicable laws, regulations, and ethical standards. We maintain robust internal controls to ensure accuracy in reporting, integrity in procurement, and excellence in performance. By upholding these principles, we build trusted partnerships with government agencies and contribute to mission success with reliability and integrity.

We are committed to conducting international business with integrity, compliance, and efficiency. Our Global Trade practices ensure adherence to all applicable trade laws, regulations, and sanctions, while promoting ethical and responsible sourcing, export, and import activities. By maintaining robust policies, internal controls, and continuous monitoring, we minimize risk, foster trust with partners worldwide, and support sustainable growth across international markets.

We actively implement anti-corruption initiatives to ensure integrity, transparency, and accountability across all our operations. Our approach includes comprehensive policies, employee training programs, risk assessments, and robust monitoring mechanisms. We promote ethical decision-making, enforce strict compliance with anti-corruption laws, and provide clear channels for reporting suspicious activities. By embedding these initiatives into our corporate culture, we prevent corrupt practices, protect our reputation, and foster trust with clients, partners, and stakeholders.

Support of Industry Best Practices

We are committed to competing fairly and ethically, earning business based solely on the quality, value, and performance of our products and services. Our decisions are guided by integrity, transparency, and adherence to legal and ethical standards, ensuring that every opportunity is pursued on its true merits. By focusing on excellence and accountability, we build trust with clients, partners, and stakeholders while fostering sustainable, long-term success.

We are committed to maintaining accurate, complete, and timely records in all aspects of our business. Our books and records reflect the true nature of transactions and comply with all applicable laws, regulations, and internal policies. Proper documentation and transparent reporting support accountability, effective decision-making, and trust with our stakeholders. Employees and partners are expected to uphold these standards to ensure integrity and reliability in all financial and operational reporting.

We carefully select and manage all third-party intermediaries to ensure alignment with our ethical standards, legal requirements, and corporate values. Our due diligence process evaluates potential partners for integrity, compliance, and reputation, minimizing risk and safeguarding our business. We require intermediaries to adhere to our policies, maintain transparency in all dealings, and operate with the same commitment to ethical conduct and accountability that defines our organization.

We are committed to adopting and promoting industry best practices to ensure excellence, efficiency, and ethical standards in all aspects of our operations. By benchmarking against leading standards, continuously improving our processes, and sharing knowledge across teams and partners, we drive innovation, enhance performance, and maintain the highest levels of quality and compliance. Supporting best practices strengthens our reputation and fosters trust with clients, partners, and stakeholders.

We invest in comprehensive training programs to ensure that all employees and partners understand and uphold our ethical standards, compliance requirements, and operational best practices. Ongoing education equips our team with the knowledge and tools to make informed decisions, mitigate risks, and perform their roles effectively. By fostering a culture of continuous learning, we strengthen accountability, integrity, and excellence across the organization.

We conduct regular assessments to evaluate the effectiveness of our policies, procedures, and controls. These evaluations help identify risks, ensure compliance with laws and regulations, and support continuous improvement across the organization. By systematically measuring performance and addressing gaps, we reinforce accountability, transparency, and operational excellence in every aspect of our business.

We encourage open and confidential reporting of any concerns related to ethics, compliance, or business practices. All reports are taken seriously and investigated thoroughly, fairly, and promptly. Our procedures ensure protection from retaliation and support transparency, accountability, and integrity. By maintaining robust reporting and investigation processes, we uphold trust, reinforce ethical behavior, and safeguard the organization and its stakeholders.