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Division

GMS Infrastructure Transport ASARCO Los Frailes Mining Mexico Mining SPCC

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Ferromex Ferrosur IMEX

Location where the reported events occurred

Center and South Corporate North Pacific Highways Fuels Construction Corporate Energy Engineering Real Estate Oil Amarillo Copper Refinery Copper Basin Railway Corporate Hayden Operations Mission Complex Ray Mine Silver Bell Mine Agua Prieta Baja California Sur Cananea Chihuahua Mexico City Coahuila Port Station Hermosillo Nacozari San Luis Potosí Santa Cruz Zacatecas Cuajone ILO Lima Offices Toquepala

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Mexico Projects & Developments Services Mexico Administrative Support Services Infrastructure

Operating Units

Lime Plant El Arco Cananea Santa Barbara Santa Eulalia Central Workshop Mexico Offices Nueva Rosita Plant Guaymas Corporate Offices Metallurgical Complex La Caridad Corporate Copper Smelter Zinc Electrolytic Refinery Charcas Unit El Pilar - Stingray San Martin Unit

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Irapuato Veracruz Chihuahua Monterrey Guadalajara Hermosillo

Area where the reported events occurred

Administration Administration and Finance Internal Audit Corporate Digital (Information Technology) General Management Motive power and traction units (workshops) Infrastructure Legal Human Resources Customer Service Information Technology Transport Operations Other

Administration

Supply Chan Administration and Control Internal Audit Commercial Shopping Comptroller's Office Comptroller and Finance Community Development Sustainability Explorations Finance Engineering and Construction Legal Legal New business Executive Chairmanship Hydraulic resources Human Resources Information Technology Treasury

Supply Chan

Strategic Supplies Warehouses Foreign Trade Purchasing Contracts Contracts and Services Logistics and Sales Planning Traffic

Administration and Control

Risk Management Comptrollership Internal Control CSC Tax Treasury

Internal Audit

Cuajone ILO Lima Toquepala

Commercial

Commercial Billing Commercial Traffic

Comptroller and Finance

Comptrollership Internal Control Direction Finance Financial Approach Insurance

Comptroller's Office

Fixed Assets Accounting Costs Costs and Budgets Taxes

Sustainability

Environmental Affairs Community Development Sustainable Development Safety and Hygiene

Engineering and Construction

Project Control and Supervision Investment Projects

Legal

Legal and Compliance Legal Institutional Relations

Community Development

Communications Public & Community Relations Cuajone Community Development Community Development ILO Community Development Toquepala Impact Measurement Social Promotion Proyectos Relaciones Públicas & Comunitarias

Explorations

Technical Management

Legal

Legal Contingencies Lima Legal Contingencies South Legal Properties Legal Natural Resources Legal and Compliance Legal Institutional Relations

Executive Chairmanship

Internal Affairs Air Operations Institutional Relations

Human Resources

TIC Personnel Administration Camps Compensation and Organization Human Development and Competencies Hospitals Spreadsheets Occupational Health Program Labor Relations

Direction

Compliance

Operations

Supplies Sulfuric Acid Warehouses Internal Affairs Road Calcination Commercial Concentrator Operations Management Exploration Railroad Smelter Hydrometallurgy Plant Engineering Engineering and Construction Laboratory Maintenance Mine Operations Wind Farm Diamond Drilling Combined cycle plant Plants LESDE Plant Planning and Technical Services Agglomeration, Crushing and Leaching Program Industrial Safety Program Plant Protection Investment Projects Quebrada Honda Water Resources Refining Refinery Sectors in operation Corporate Security Industrial Safety Plant Security Environmental Services Technical Services Control & Communication Systems SXEW Fuel Storage Terminals Mexico GM Nurseries Locomotives, Railcars and Tracks

Operations

General Operations Direction Cuajone Operations Direction ILO Operations Direction Toquepala Operations Direction

General Operations Direction

Cuajone Operations Direction

ILO Operations Direction

Toquepala Operations Direction

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Sulfuric Acid Warehouse Warehouses Wire rod Maintenance Crews ESDE Precious Metals Pedestrians Planning Platform Dusts and Effluents Port Operations Earth Traffic and Imports Transfer

Delicate GMI

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Subject of the complaint

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Working conditions Innappropiate handling of confidential information Asset and property protection Safety, health and environmental issues Relations with third parties ( customers and suppliers) Other Employment Status Business resources Relations with third parties

Protection of assets and property

Theft of company assets Misuse of assets and / or resources Trade with internal information

Working conditions

Abuse of authority Unjustified dismissal Working day Extortion Discrimination Sexual harassment Consumption of alcohol or prohibited substances Conflicto de Interés Otros

Safety, health and enviromental issues

Inadequate and/or unsafe working conditions Problems of Urban Living Pollution

Relations with third parties (customers and suppliers)

Bribery Conflict of interest Otros

Employment Status

Abuse of authority::<ol> <li>An arbitrary and capricious exercise of authority that is inconsistent with the mission of the executive agency concerned or the successful performance of a contract of such agency. <a href="https://bitly.ws/TCPn" target="_blank">Abuse of authority Definition: 241 Samples. (n.d.). Law Insider. Retrieved August 30, 2023 </a> </li> </ol> Workplace harassment::<ol> <li>Workplace harassment can include “offensive jokes, slurs, epithets or name calling, physical assaults or threats, intimidation, ridicule or mockery, insults or put downs, offensive objects or pictures, and interference with work performance.” <a href="https://www.businessnewsdaily.com/9426-workplace-harassment.html" target="_blank"> Schooley, S. (2020, June 15). Workplace Harassment: How to Recognize and Report It. </a> </li> </ol> Sexual harassment::<ol> <li>It is unlawful to harass a person (an applicant or employee) because of that person's sex Harassment can include "sexual harassment" or unwelcome sexual advances, requests for sexual favors, and other verbal or physical harassment of a sexual nature. <a href="https://www.eeoc.gov/sexual-harassment" target="_blank"> U.S. Equal Employment Opportunity Commission. (2020). Sexual Harassment. </a> </li> </ol> Consumption, use or sale of alcohol, drugs or controlled substances::<ol> <li>Consume, use or sell alcohol, drugs and controlled substances that affect conduct and/or safety and health at work. Ethics code </li> </ol> Wringful termination::<ol> <li>Wrongful termination happens when your employer fires you for an illegal reason. Learn what qualifies as wrongful discharge and the actions you can take. <a href="https://www.usa.gov/wrongful-termination" target="_blank"> Wrongful termination or discharge | USAGov. (n.d.). </a> </li> </ol> Discrimination::<ol> <li>Discrimination is the unfair or prejudicial treatment of people and groups based on characteristics such as race, gender, age, or sexual orientation. Grupo Mexico Mining (2021). Grupo Mexico Code of Ethics and Business Conduct. <a href="https://www.apa.org/topics/racism-bias-discrimination/types-stress" target="_blank"> American Psychological Association . (2022, October 31). Discrimination: What it is and how to cope. </a> </li> </ol> Excessive Workload::<ol> <li>Excessive workload is generally when one individual has far too much work to handle on their own. An increased or excessive workload can cause symptoms of stress at work, particularly where there is a lack of extra help or support. <a href="https://www.oakwoodsolicitors.co.uk/excessive-workload/" target="_blank"> Excessive Workload. (n.d.). Oakwood Solicitors. </a> </li> </ol> Workplace Safety and Health::<ol> <li>Acts or omissions that put the life, health and physical integrity of people at risk during the performance of their work. Ethics code </li> </ol> Human right violations::<ol> <li>The violation can be physically violent in nature, such as police brutality, while rights such as the right to a fair trial can also be violated, where no physical violence is involved. <a href="https://www.humanrightscareers.com/issues/what-are-human-rights-violations/" target="_blank"> Soken-Huberty, E. (2020, May 16). What Are “Human Rights Violations”? Human Rights Careers. </a> </li> </ol> Child labor:: :: Freedom of Association:: :: :: :: :: :: :: :: :: ::

Business resources

Conflict of interest::<ol> <li>A conflict of interest occurs when your personal interests or activities interfere (or appear to interfere) with the interests of the company as a whole. <a href="https://bitly.ws/TCUC" target="_blank"> Understanding Conflict of Interest. (2016, April). University Compliance, Ethics, and Risk. </a> </li> </ol> Forgery of financial information and technical reports::<ol> <li>Financial statement fraud is the deliberate misrepresentation of a company’s financial statements, whether through omission or exaggeration, to create a more positive impression of the company’s financial position, performance and cash flow. <a href="https://www.netsuite.com/portal/resource/articles/accounting/financial-statement-fraud.shtml" target="_blank"> Beaver. S. (2022, April 7). Financial Statement Fraud: Detection & Prevention. NetSuite. </a> </li> </ol> Documents forgery::<ol> <li>Document forgery is a crime that entails creating a document to give the appearance of legal significance to a fact that is untrue. <a href="https://www.mylawquestions.com/what-is-document-forgery.htm" target="_blank"> What is Document Forgery? (with pictures). (n.d.). My Law Questions. </a> </li> </ol> Fraud::<ol> <li>“Fraud” is any activity that relies on deception in order to achieve a gain. <a href="https://www.acfe.com/fraud-resources/fraud-101-what-is-fraud" target="_blank"> Association of Certified Fraud Examiners. (n.d.). Fraud 101: What is Fraud? Www.acfe.com </a> </li> </ol> Cyber fraud::<ol> <li>Cyber fraud is the crime committed via a computer with the intent to corrupt another individual’s personal and financial information stored online. Cyber fraud is the most common type of fraud and individuals and organisations need to be vigilant and protect their information from fraudsters. <a href="https://www.delta-net.com/knowledge-base/compliance/fraud-awareness/what-is-cyber-fraud/" target="_blank"> What is Cyber Fraud? (n.d.). DeltaNet </a> </li> </ol> Failure to comply with the functions and responsibilities::<ol> <li>Failure to comply with the commitments, functions and responsibilities in a timely manner, as well as exceeding the limits of the same. Ethics code </li> </ol> Disclosure of confidential and privileged information::<ol> <li>Privileged and confidential communication is the interaction between two parties having a legally protected, private relationship. <a href="https://www.upcounsel.com/privileged-and-confidential" target="_blank"> Privileged and Confidential | UpCounsel 2019. (2019). UpCounsel. </a> </li> </ol> Stealing of company assets::<ol> <li>Theft of assets refers to the actual theft of a person or entity’s assets. Causing an organization to pay for goods and services not actually received (for example fictitious vendors or employees) or using an organization’s assets for personal use are types of theft of assets. <a href="https://fraud.net/d/theft-of-assets/" target="_blank"> Theft of Assets. (n.d.). Fraud.net. Retrieved August 30, 2023 </a> </li> </ol> Misappropriation of Assets:: <ol> <li>When employees or third parties associated with a business abuse their power and authority and steal from the company through several fraudulent activities, this is known as misappropriation of assets. <a href="https://bitly.ws/TCZq" target="_blank"> Misappropriation of Assets Definition. (n.d.). Law Insider. Retrieved August 30, 2023, from </a> </li> </ol> Improper use of computer systems, communication and information security.::<ol> <li>Use of systems, communication and information security resources provided by the company that is not directly related to work and the performance of functions. <a href="https://www.investopedia.com/terms/c/computer-abuse.asp" target="_blank"> Frankenfield, J. (n.d.). What Is Computer Abuse? Investopedia. </a> </li> </ol> :: :: :: :: :: :: :: Disclosure of confidential and privileged information:: :: :: :: ::

Relations with third parties

Unfair competition practices::<ol> <li>The law of unfair competition is primarily comprised of torts that cause economic injury to a business through a deceptive or wrongful business practice. <a href="https://www.law.cornell.edu/wex/unfair_competition" target="_blank"> Unfair competition. (2019). LII / Legal Information Institute. </a> </li> </ol> Acts of corruption::<ol> <li>Corruption is defined as the abuse of entrusted power for private gain. <a href="https://www.lawinsider.com/dictionary/act-of-corruption" target="_blank"> Act of corruption Definition. (n.d.). Law Insider. Retrieved August 30, 2023 </a> </li> </ol> Dishonest acts in exchange for financial or in-kind benefits (among employees and individuals)::<ol> <li>Fraud is a term that refers to the use of intentional deception to gain something of value, usually money. Fraud is generally committed through the use of false statements, misrepresentation, or dishonest conduct intended to mislead or deceive. <a href="https://www.antibriberyguidance.org/guidance/5-what-bribery/guidance" target="_blank"> Transparency International UK. (n.d.). 5. What is Bribery? | Anti-Bribery Guidance | Transparency International. Www.antibriberyguidance.org. </a> </li> </ol> Gifts and courtesies outside of politics::<ol> <li>Request or authorize gifts or entertainment that may influence or appear to influence business decision-making. Ethics code </li> </ol> Money laundering::<ol> <li>Money laundering generally refers to financial transactions in which criminals, including terrorist organizations, attempt to disguise the proceeds, sources or nature of their illicit activities. Money laundering facilitates a broad range of serious underlying criminal offenses and ultimately threatens the integrity of the financial system. <a href="https://bitly.ws/TD5k" target="_blank"> What is money laundering? | FinCEN.gov. (n.d.). Www.fincen.gov. </a> </li> </ol> Impacts on the environment and sustainable development::<ol> <li>It potentially impacts or fails to comply with the protection and conservation of the environment. Ethics code </li> </ol> :: :: :: :: :: :: :: :: :: ::

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