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Dear Fortaleza Materiales collaborator:

Fortaleza Materiales has always embraced a strong commitment to the policy and compliance with the letter and spirit of all applicable laws and regulations in every country where we operate. Our three core values are Integrity, Respect and Commitment, and our philosophy is embedded in our Focus on Results, Innovation, Safety and Teamwork. As part of our commitment to our values and philosophy, Fortaleza Materiales has always strived to observe the highest standards of integrity and ethical conduct in our relationships with our shareholders, collaborators, representatives, suppliers, and competitors, and with the government and the general public. Each of us is responsible for continuing to uphold these high standards in all of our daily business activities.

This Code of Ethics (the Code) has been adopted by Fortaleza Materiales’ management team and applies to all its members and collaborators in every country where the company operates. The purpose of the Code is to outline in one document our current policies and practices relating to the conduct of our business and, in turn, to further promote lawful and ethical practices by Fortaleza Materiales’ collaborators and to discourage dishonest conduct.

The business landscape has never been more challenging or complex, particularly for a company like Fortaleza Materiales that operates in several countries. Now more than ever it is necessary for each of us to understand our own responsibility to strictly comply with all legal requirements and the highest ethical standards. We believe that by having a corporate culture that recognizes the urgency and value of meeting those standards we can expect to ensure our continued success as a business going forward. We encourage you to use this Code to help you address issues as they arise and to discuss any concerns or questions you may have, either through the hotline or other communication channels noted in the Code.

One of our stated guiding principles calls on each of us to "Fully comply with our obligations as a corporate citizen contributing to the well-being of society and the environment where we operate”. Thank you for standing with us to uphold Fortaleza Materiales' long tradition of ethical conduct and to continue to solidify its outstanding image of honesty and integrity.

Jaime Rocha Font


Fortaleza Materiales has established travel expenses policies for its operational needs, covering from planning to invoicing.


Collaborators will choose and deal with persons or firms doing or seeking to do business with the Company in a completely impartial manner, without any consideration other than the Company's interests.

Collaborators are expected to avoid any involvement or situation that could interfere, or even appear to interfere, with the impartial performance of their duties. This means that collaborators and no member of their families should ask or accept from any representative, supplier or other person doing or seeking to do business with Fortaleza Materiales any loan, gift, form of entertainment or benefit of a nominal value exceeding $100 or its equivalent in local currency, or that in any way is not in line with ethical business practices and customary local business practices in terms of value or cost. Certain Fortaleza Materiales’ business units or local markets may adopt more stringent policies regarding gifts, loans, or forms of entertainment. When in doubt, collaborators are encouraged to seek advice of their supervisors before accepting a gift.

In general, any collaborators who is offered or receives a gift of high nominal value should politely decline or return it to the sender explaining Fortaleza Materiales’ gift policy. Collaborators are cautioned to bear in mind the frequency with which gifts – including those of low nominal value – are offered and accepted when deciding whether or not accepting a particular gift is appropriate, avoiding any potential or apparent omission.


Books and records, proper accounting of transactions

It is essential that the Company's financial statements, as well as all books and records used for their preparation, be comprehensive and accurate to reflect the true standing of our business and to show the faithful nature of all disbursements and other transactions at all times. This is mandatory, regardless of whether such records reveal underwhelming results or a failure to meet expected earnings targets. It is a violation of the Code to do anything that compromises the integrity of Fortaleza Materiales’ financial statements or other business records.

Any attempt to conceal actual results by misrepresenting, for example, revenues, expenses, assets, or debts cannot and will not be tolerated. Failure to comply with these standards may be a violation of civil and criminal laws.

Protection and Proper Use of Company Assets

Each collaborator is responsible for protecting Company property from loss, theft, and misuse. Any loss, theft, and misuse of Company assets have an impact on its profitability.

Any theft (regardless of the monetary value involved) and any significant loss or misuse of Company property should be reported to the management, the Legal Department, the Corporate Internal Audit Department, or any member of the Compliance Committee.

All Company property, including its equipment, vehicles, supplies, and products must be used only for legitimate operational purposes.


Fortaleza Materiales is prohibited from making contributions or donations, directly or indirectly, to political parties, electoral campaigns, labor unions, public agencies, or government officials, in any country where it operates.


The Code of Ethics and Integrity Policy apply to collaborators, executive officers, dealers, and business partners.


A Conflict of Interest is a situation that occurs when a person's personal, work, professional, family, or business interest may affect their impartiality and objectivity when carrying out their duties; and occurs when a person's interests could interfere with the performance of their activities, gaining a benefit or advantage for themselves, their family members or a third party ("Conflict of Interest").


The payment of bribes and kickbacks to government officials, suppliers, and others is strictly prohibited. Casual gifts, forms of entertainment, and business favors to non-government employees as part of negotiations or business relationships are generally considered appropriate for the Company's business if they are (i) legal, (ii) occasional, (iii) not in cash or cash equivalents, (iv) of low nominal value, $100 or its equivalent in local currency, (v) in accordance with local customary practices, and (vi) would not cause any reputational damage to the Company if made public.


Fortaleza Materiales has training programs for its directors, executive officers, collaborators, dealers, and business partners on anti-corruption and integrity topics.


Fortaleza Materiales has a sanction policy to guarantee to society the honest, ethical, and professional behavior of its collaborators.


The Compliance Committee is responsible for dealing with questions, queries, feedback on the Code of Ethics, as well as for dealing with and investigating complaints or grievances received and taking appropriate actions in accordance with the sanction policy.

Directors and collaborators may submit a complaint to the Compliance Committee, if they have reason to believe that any collaborator has violated or appears to violate any internal regulation or applicable law, through the following means:

  1. a. By logging into the Whistleblower Mailbox available on the Company’s Intranet; or
  2. b. Sending an e-mail to the Company’s Compliance Committee: ""; or
  3. c. Sending the information by regular mail to the Compliance Committee at the corporate headquarters of Fortaleza Materiales, S.A.B. de C.V.: Fortaleza Materiales Comité de Cumplimiento, 245 Lago Zurich, 20th Floor, Delegación Miguel Hidalgo, Mexico City 11590

The whistleblower mailbox and the compliance e-mail, as well as the postal mailbox, are protected in such a way that only the members of the Compliance Committee may have access to the messages delivered by these means.

The Compliance Committee is the corporate body responsible for investigating the complaints submitted to it and, if applicable, taking the appropriate actions in accordance with the sanction policy.


Fortaleza Materiales will not tolerate retaliation of any kind by a director, executive officer, or other collaborator, or by an external supplier or contractor following a report made in good faith.

In addition, Fortaleza Materiales will not tolerate retaliation or other action taken against any collaborator who provides a law enforcement officer with truthful information relating to the possible perpetration of a civil or criminal offense or who participates in the investigation by Fortaleza Materiales or governmental authorities of actions that the collaborator reasonably believes constitutes a fraud under stock market regulations in Mexico, the United States, and the countries where the Company operates.