Corporate Conduct Compliance Program

Ternium acknowledges integrity, transparency and law compliance as fundamental values in the company; therefore, they must be part of the actions that everyone does daily.

Ternium has developed a Corporate Conduct Compliance Program regarding the prevention of bribery and the mitigation of corruption. The Compliance Program involves every employee and seeks to ensure the best behavior in business practices internally and regarding the relations with clients, providers, government entities and third parties.

The Compliance Program includes an evaluation of bribery risks in places where Ternium is operating. This allows us to guide our prevention efforts and to have control over the processes that are at a higher risk or exposure.

In matters of anti-corruption regulations, our Code of Conduct and our Corporate Conduct Policy establish guidelines, integrity and transparency standards which are based on the respect to the internal rules and applicable laws by the employees as well as any third party that acts on behalf of the Company.

These essential documents clearly define that any payment done by bribery is strictly prohibited and will not be tolerated; it also includes specific guidelines regarding the required preliminary integrity verification when hiring representatives that act on behalf of Ternium. All political contributions, donations and hospitality (travel) expenses made to third parties (food, gifts and business trips) are also regulated in the internal processes.

Ternium developed a Code of Conduct for Providers for third parties based upon the best market practices. Issues such as conflicts of interest, bribery prohibition, law-abiding, security, work relations, and human resources are presented in it.

The central concepts of the Compliance Program comprehend disclosure and preparation; this is demonstrated by the required face to face and online training. The anti-corruption training also includes support from the management department by exposure actions and with clear guidelines, and it reaches third parties as part of the due diligence process, to outline Ternium’s expectations concerning the compliance of our company’s regulations by third parties.

Furthermore, Ternium has a Transparent hotline, in which people can send reports anonymously. It is available to employees as well as to third parties by web, e-mail or phone. Fair and confidential treatment is guaranteed, and there will not be any retaliation or penalty whatsoever towards people who file the complaints.

Our Compliance Program tries to motivate, inspire and commit all employees and third parties into our corporate culture, thus reducing the risk of corrupt activities associated with the name of the company and takes all preventive measures to protect Ternium from improper practices with no tolerance to any gray areas in this behavior.