GRUPO BIMBO CODE OF ETHICS In Grupo Bimbo we believe that

GRUPO BIMBO CODE OF ETHICS
In Grupo Bimbo we believe that Integrity is the highest value that characterizes us.
To live according to these Principles and Values, and thus comply with this Code, it is essential that
we are high moral quality persons and naturally abide by it, practicing what we preach.
Living up to the provisions within this Code of Ethics, will always make us feel the satisfaction of
having acted loyally to our Company and our stakeholders in a clear and honest way, within an
environment of trust and cordiality in all aspects of our life, personally and professionally.
1.- With Our Customers and Consumers:
Our Customers and Consumers are the reason for our existence. Their satisfaction is essential for
our success; therefore, the quality and safety of our products, as well as the quality of our service
are the main commitment to them.
To the public at large, we offer a range of food products that go from staples to complementary
ones. We uphold the commitment to inform our consumers about the nutritional value of each of
our products.
We are committed to make our products available to the public in all channels where we operate in
enough quantity, guaranteeing their freshness and timely pick up.
Customers are our strategic allies, hence we strive for our business proposal to be one that’s
fosters their growth and development.
In our dealings with Customers, there is no room for any type of corruption, bribery, favoritisms or
any other activity contrary to decorum or that attempts against the good health of the population.
2.- With Our Shareholders and Partners:
We strive to give our shareholders total transparency and certainty by establishing best corporate
practices. We are convinced that good Corporate Governance strengthens the shareholder’s
mandate: be a well-managed, socially responsible, efficient and profitable company. That is why
we strive to be a role model in terms of management.
Our commitment is give our shareholders and partners a sustainable and reasonable return on their
investment, creating value in the long term.
Our Companies comply with information disclosure laws so that our Shareholders and Partners can
make their decisions based on consistent, homogenous and known bases. This information always
stems from transparent and clear accounting practices, and attached to applicable regulations.
All our business practices and transactions are done using resources in a prudent and profitable
way, and in compliance with the highest ethical behavior and legal standards.
3.- With Our Associates:
In Grupo Bimbo we strive for all Associates to be treated with respect in an environment that fosters
personal and professional development.
Our dealings with our Associates are based on the Golden Rule: be treated with Respect, Fairness,
Trust and Care.
Associates willing to make suggestions on how to better experience the Values in Grupo Bimbo,
may do so through the Línea Comenta (Comments Line.)
a) Respect to Individuality
Each person has a unique value and we acknowledge that his/her individual contribution is
essential for the performance of his/her work team. That is why we respect them and do not
allow any type of discrimination due to age, sex, race, sexual inclination or any other condition
protected by the laws of the communities where we operate. This provision applies to all
employment-related issues including recruitment, selection, promotion, change of position,
transferences, termination of the working relation, compensation, education, training and, in
general, all working conditions.
b) Self-development and Values
We are committed to foster our personnel’s development in a subsidiary way, as well as the
appreciation of the highest moral values and ethical standards. We convey and disseminate our
values and principles through our behavior.
We acknowledge that trust is the foundation for a close and long-lasting relationship, which in
turn is founded on the person’s integrity. In Grupo Bimbo we believe in the good will of others,
except there be proof of the contrary.
We do not tolerate any kind of personnel harassment or conditioning, nor that one person’s
success depends on favoritisms or bribery. Our commitment is to maintain a working
environment free of harassment, including language or behaviors that can be intimidating,
discriminatory and/or offensive.
We believe that this position of respect will grant our personnel employment certainty and allow
associates to trust the Company and fully dedicate themselves to do their tasks.
We provide our personnel pertinent means to develop their talent and competencies, and use
them to assume greater responsibilities when opportunities present to them.
c) Safety
We deeply appreciate and respect the life and health of all our Associates.
Our personnel’s physical integrity is given priority over operation efficiency and Company
results. Hence, we commit to provide a safe working environment and continuously generate a
culture that preserves the associates’ physical and mental health.
We must also consider the safety of our clients, suppliers and the social environment in which
we operate, in order to maintain the physical integrity of all
d) Function Responsibilities and Clarity
We acknowledge the importance of transmitting to our Associates the information they require to
comply with their functions, since only in this way, can they become professionally and
enthusiastically engaged in the attainment of the Company’s objectives and priority projects.
e) Labor Organizations
It is our fundamental commitment that where a labor organization exists, its independence be
respected, if and only if it represents the legitimate interests of workers, seeking to establish a
relationship of collaboration and of mutual benefit.
All relationships with Labor Organizations must strictly conform to the legal provisions of the
community where the Company operates.
f) Information and Confidentiality
When an Associate becomes part of Grupo Bimbo, he/she assumes the commitment to make a
responsible and legitimate use of the intellectual property and industrial secrecy information
among others that he/she may have access to, keeping it safe and maintaining its
confidentiality at all times.
Even when an Associate ceases to work for GB, for whichever cause, he/she must abide by
this commitment due to professional ethics and in compliance with the laws of the countries
where we operate.
g) Conflict of Interests
We expect all personnel to devotedly work for the benefit of the Company, and that all of us, who
are part of it, make our decisions independently from any factor favoring interests alien to the
Company’s productivity, efficiency, efficacy and the attainment of our goals.
In order to avoid conflicts between personal interests and those of GB, and in order to foster a
solution –if required- all GB Associates have the responsibility to declare any financial interest or
of any other kind, that could cause conflict regarding his/her function in the Company. If an
Associate considers that there are personal interests that can influence his/her decisions or
performance at work, he/she must communicate it to the immediate supervisor in writing. Every
year, all GB personnel must make a written report of all existing conflicts of interest they may
have (there is a specific policy to that effect.)
No Associate is allowed to have financial or any other kind of interest, work or be a consultant in
a Competing Business, a Supplier or a Customer.
h) Integrity any Corruption
In Grupo Bimbo we do not bribe, nor do we accept favors or money to grant benefits to anyone.
We clearly understand that to avoid these acts, we have to eliminate any anomaly so there is
no motive at all to fall into corruption.
Bribing to gain a benefit does not help GB at all; it puts it in a very serious situation and
prevents its progress.
Receiving money, presents or favors has a profound impact on results and casts doubts upon
the reputation of the Company and our own.
These are illegal actions and may be considered a crime.
I) Work of Family Members
Grupo Bimbo Associates’ family members can work in the Company only if the nature of their
kinship does not affect his /her performance at work, or the Associate – Company working
relationship. Therefore, the following situations between family members are to be excluded:
 working relations in which there are process interactions between relatives.
 Supervisor-Associate relationship.
 If in the family relationship one of them holds an executive or management level position,
his/her relative must not work in the same department; more so, must work in a different area
and/or work center.
To enforce the abovementioned, anyone in a supervisory position has the responsibility to be
watchful of this issue to prevent any possible conflicts and take timely action.
4.- With Our Suppliers:

Dealings
Our commitment to tour suppliers is to have honest and equitable negotiations free of
discrimination and/or impositions. All suppliers are always to be treated according to the
Golden Rule: Respect, Fairness, Trust and Care.
Our commitment is a deal that includes not only respect for the persons representing suppliers,
but to also provide the necessary information pertaining to the results of the biddings and
tenders, so that these processes are transparent and fair.

Selection and Development
All proposals made by our Suppliers will be comprehensively reviewed considering price, added
value, quality and the service they offer.
We grant the highest value to fair competition during the evaluation process in order to choose
the best. We have to be consistent with the commitment assumed to build long-lasting,
equitable and fair business relationships.
We are also committed to protect the Suppliers’ rights in what pertains to confidentiality of the
information provided, expecting in return, that Suppliers also comply with GB policies
We engage our Suppliers, seeking their development and giving them support and information
in order to improve the materials and services we need from them through a long-lasting
relationship based on trust.

Terms
We think that one of our main commitments to our Suppliers is the timely payment for their
services and products. Therefore, we establish clear agreements relating to payment terms
and set up stable, simple and transparent processes, which do not lend themselves to
misinterpretations or malpractices.
We aspire to have Suppliers who, in each transaction, derive fair benefits that promote their
sustainable development and thus have their services evolve in all its elements and not only in
terms of price.
Since we are committed to promote the legality of operations, we will be mindful that our
Suppliers do not fall into illegal practices, such as money laundering, lack of compliance with
tax, environmental or social laws, such as social security and tax payments, and underage
labor pertinent to the legislation of the country. Grupo Bimbo will not have any commercial
relationship with Suppliers that incur in these kinds of practices.
We seek that our Suppliers help us to offer excellent products; hence, we work with those that
guarantee the highest food quality and safety standards.
Grupo Bimbo fosters caring for the environment and biodiversity; hence, it expects its suppliers
do it as well.

Anticorruption
In Grupo Bimbo we seek to obtain from the Supplier only the benefits that pertain to the
negotiation in question, without gaining personal advantages for assigning contracts and for the
acquisition of goods and/or services. We will seek that the relationship with our Suppliers will
always be one in which both parties win.
The best acknowledgement GB can receive from a Supplier is complying with what was agreed;
therefore, we and our families do not accept money, presents, services, travel discounts and
tickets for entertainment. However, we understand that our suppliers make efforts to promote
their brands and products; hence, it is acceptable for them to give promotional items only if their
value is symbolic.
In general, our relationships with Suppliers are based on mutual trust and we hope that the
commercial experience to be satisfactory and free of all sorts of corruption. Any questionable
situation must be reported in writing right away to the immediate supervisor and before any
transaction takes place.
To support this concept, we let our suppliers know about our Personal Integrity Principle and
request that they not give our Associates any gifts or retributions.
We also place at their service our Línea Comenta (Comment Line) so they can have a space to
express, in a framework of confidentiality, their comments, suggestions and complaints. We
assume the commitment to thoroughly review each case and take action in consequence. This
space is available before, during and after the Supplier-Customer relationship, understanding that
we will act in all fairness, without negatively affecting the interests of both parties if complaints
proceed
5.- With Our Competitors:
GB is committed to compete in the market on the basis of price, quality and service, within a
framework of integrity and respecting our Competitors in all regards.
Advertising and promotions are all based on the truth and in compliance with competition related
laws in force in each country. We will compete based on quality, service and a commercial strategy
in line with our Principles and Values.
We respect our Competitors and, whenever we have to speak about them, we will always use factbased information. Comparisons with Competitors will be done using exact terms, free of
descriptions or labels, and never using deceiving information or arguments.
6.- With the Government:
 Observance of laws
We will remain informed about the laws in force in each country in which we operate and will
make any necessary adjustments to prevent any transgression.
This principle applies to all business areas without exception. Infringing the law is a crime that
may entail severe economic damages for the Company, and the deterioration of its image.
We participate, as much as possible, in Organizations relevant to the analysis of, understanding
and, in due case, for suggesting improvements to the legislation, always in the most respectful
way, and with the spirit of collaborating towards the development of the corresponding country.
 Respect to Local Customs and Mores
Since we are present in countries with different cultures and laws, we seek to understand and
respect local customs, mores and practices, as long as they do not violate the law or contradict
our principles and values, or go against what is set forth in this Code.
In case of doubt relative to the congruence of our Values with local mores, the President of the
Organization must be consulted in order to decide the course of action.
 Participation in Political Activities
We make no ideological or party affiliation pronouncement, but we encourage civic collaboration
in professional associations and citizen organisms, and at the same time, we encourage the
responsible exercise of political rights. The participation of our Associates in political and/or
election processes will be purely done on a personal basis, and cannot include contributions in
terms of time, financial support and resources that belong to GB. When an Associate chooses
to participate in politics, make contributions and give his/her opinion, it will be done as an
individual, and will not give the impression of acting on behalf and/or in representation of Grupo
Bimbo.
7.- With Society:
We recognize that our reason to be is the community we are part of; we owe ourselves to it and
we work for it. Hence, we promote volunteer work among our personnel and are committed and
support, through our daily work and attitudes, the principles and values of the community in
which we live.
 Job Creation and Permanence
We are committed to the economic and social growth of the communities where our Companies
operate by creating and maintaining worthy and productive employment sources.
As a Group, we invest in training our personnel and do everything possible to keep the jobs of all
those who perform their functions adequately and maintain a positive attitude.
 Advertising
Our commitment is to have advertising and promotion campaigns that promote the strengthening
of universal ethical values; i.e. family union, physical and emotional integrity of individuals,
respect for children’s universal rights; respect for persons with disabilities, senior citizens, or of
any ethnic group or social status.
We are aware of the impact that our advertising can have. Hence, we are care that it will always
be responsible and truthful, minding that it does not lend itself to misinterpretations regarding the
nutritional value, use and attributes of our products.

The Environment
We understand our operation has an unavoidable impact on the environment; therefore, we are
committed to permanently seek the means to reduce said impact by continuously improving
emission controls, waste management, water treatment, energy savings and all elements that
can potentially affect it.
We promote, amongst all our personnel, caring for the environment, and acknowledge
environmentally responsible practices in their daily work.
8.- Regarding Productivity:
In Grupo Bimbo we desire to build a highly productive and deeply humane company.
We understand that in order to live up to our internal and external responsibilities, we have to use
our resources in a productive and sustainable way.
 Austerity
We are convinced that GB’s daily business and operations must be done in a context of
simplicity. We are committed to undertake all our business processes in accordance to the
principle of austerity.
We make an efficient use of the resources available to us -are mindful of wastes- seeking to
keep them in perfect working conditions, maximizing their capacity and expanding their useful
life.
Our objective is the functionality of expenses always respecting the safety and dignity of our
Associates.
 Assets Protection
Our commitment is to protect and optimize the value of investments, mainly through the prudent
and profitable use of resources and ensuring that the corresponding security rules are complied
with..
Custody and conservation of GB’s assets is the responsibility of each and every one of us who
make up the Company.
We understand the Company assets are not only buildings, vehicles, machinery or fixtures and
furniture, but also blueprints, designs, formulas, processes, systems, technology, drawings,
business strategies, product launching plans, promotional campaigns and, of course, our
brands.
Associates have the commitment to safeguard said Company assets. We are especially
committed to protect the Company’s intellectual property, essentially represented by its
manufacturing processes, information systems and commercialization plans, as well as financial,
products and personnel information.
Assets are to be used for business purposes and it is strictly forbidden to make a different use of
them. All GB Associates have the obligation to report any deviation known to him/her.
Violations to the Code of Ethics:
Compliance with this Code is strictly mandatory.
Company Supervisors, at all levels, will be an impeccable example of compliance with it, will
disseminate its principles at all times, and will take disciplinary measures whenever one of his/her
Associates breach it.
Any Associate involved in business practices different from those set forth in this Code, will be
subject to disciplinary measures that may even result in the termination of the working relationship
and/or in a legal action
In an international company, situations apparently unforeseen in this Code could appear. In such
cases, compliance with the law, our Values, Principles and good faith must guide our actions.
GB associates will always have the freedom to ask their superiors about situations where there is
doubt
The Audit Department will include the review of compliance with this Code in its programs.
Every quarter, the Ethics Committee will report to the Board of Directors’ Audit Committee.
Functional Departments related to each of our Stakeholders (Suppliers, Customers, Associates,
Shareholders) are accountable for having them comply with this Code of Ethics.
The Institutional Relations Department will draft the plans for disseminating this Code
This Code of Ethics comes into effect in October.