Integrity & Anti-Corruption Handbook

Orbia rejects and prohibits bribery and any form of corruption of any kind (private or public). This is the position adopted by the Board of Directors and cascaded and enforced across the organization.

Orbia policy is to comply with the Mexican Ley General de Responsabilidades Administrativas and Ley General del Sistema Nacional Anticorrupción, the U.S Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and all other anti-corruption legislations applicable in those jurisdictions where Orbia conducts businesses. This Handbook provides guidance for compliance with anti-corruption law principles applicable around the world and to give you direction in business situations that you may encounter.

Compliance with Anti-Corruption and Anti-Bribery regulations is a serious issue both for you and Orbia.

Orbia prohibits the offering, promising, giving, receiving or soliciting an “Improper Payment” to anyone. An Improper Payment may consist of anything of value including any money, goods, property, privilege, compensation, object of value, advantage or any promise or undertaking to induce or influence any action, vote or other undertaking of the recipient.

Orbia can suffer devastating consequences to its reputation and its shareholder value simply by being the subject of a bribery or corruption investigation even if it is not convicted.

Companies may be fined millions of dollars for violations of Anti-Corruption statutes. Other potential consequences for the company would include:

  • Charges for money laundering;
  • Charges for mail and wire fraud;
  • Charges for conspiracy;
  • Charges for false books and records;
  • Material litigation and regulatory investigations;
  • Temporary debarment from participating in public procurement;
  • Temporary suspension of activities; and
  • Winding-up of

By violating Anti-Corruption laws you could face severe consequences including loss of employment with Orbia, substantial fines, and even prison, whether or not Orbia is prosecuted.

Despite your best efforts, it is always possible that you are confronted with bribery or other forms of corruption. In such cases, it is important to understand how to behave as a Orbia officer, employee or third party such as agents, distributors, consultants, contractors, or any other third party acting on behalf of Orbia. Although these Policies have been drafted as much as possible from a business and practical perspective and are intended to educate you about anti-corruption, you should not try to solve any anti-corruption problems on your own. In case of doubt, please consult immediately with the Legal Department.

Orbia has a zero-tolerance approach to bribery and corruption.


Deviations or changes to these Policies require the approval of Orbia Vice President & General Counsel.

Reporting a Concern

Because we all have a stake in Orbia’s success, it is in all of our interest to help ensure that our business are conducted to the highest ethical standards, and that our reputation remains untarnished. For this reason, we strongly encourage you to report any situation you know or suspect about that may involve illegal, unethical or otherwise improper business activity, as well as all instances of employee violations of this or any other of the Orbia’s policies. Doing so will allow the company to address the issue and take appropriate corrective action.

If you have a good-faith belief or concern related to improper or illegal conduct, you should immediately bring it to the attention of Orbia:

  • Here you can log in from any computer with an Internet connection and clicking on the company Whistleblower Line link to file a web report.

Orbia will not tolerate retaliation against you due to your report or participation in any internal investigations, as long as you have acted in good faith and believe what you reported to be true.

Retaliation may be grounds for discipline up to and including dismissal, subject to applicable local laws. The company will treat any good-faith reports or discussions in confidence consistent with legal requirements and subject to the need to conduct a thorough investigation where appropriate. In certain cases, and consistent with applicable laws, information may be shared with local law enforcement or other authorities.

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