PROGRAM MODEL OF

BUSINESS INTEGRITY
UNIT OF ETHICS, PUBLIC INTEGRITY AND
PREVENTION OF CONFLICTS OF INTERESTS
In order to contribute to the design and implementation of Corporate Integrity Policies, according to
According to the provisions in articles 21 and 25 of the General Law of Administrative Responsibilities,
The Secretariat of the Public Function, through the Unit of Ethics, Public Integrity, and Prevention
of Conflicts of Interest, makes available to society the Integrity Program Model
Business.

This document was prepared with the participation of the main business chambers of
our country, and the institution presented it on June 12, 2017, to the various groups
businesses that make up the private sector in Mexico; it contains suggestions for best practices
the general guidelines on the subject, which aim to promote a greater culture of ethics.

Convinced that integrity is a collective commitment, the aim of this document is

provide advice to the private sector on compliance with guidelines for design and application
of integrity policies.

DOWNLOAD THE
DOCUMENT HERE:

http://bit.ly/UEEPCI21

The Secretary of Public Function thanks the Business Coordinating Council of the Mexican Republic,
to the International Chamber of Commerce, to the United Nations Office on Drugs and
Crime and the United Nations Development Programme, its comments to enrich the
present document.
 INDEX

MODELO DEPPROGRAM OFIINTEGRITYEBUSINESS................................................................... 1

I. A clear and complete manual of organization and procedures ................................... 2
II. A duly published and communicated code of conducto................................................... 3
III. Suitable and effective systems of control, surveillance and auditinga .
IV. Appropriate reporting systems .................................................................................. 6
V. Appropriate training and capacity building systems and processes............................................ 8
VI. Human resources policies aimed at preventing the incorporation of people who may
generate a risk to the integrity of the corporation ............................... 8
VII. Mechanisms to ensure at all times the transparency and publicity of their interests
ACTIONS IMPLEMENTED BY THE SFP................................................................................................. 11

ADDITIONAL ACTIONS THAT IT IS SUGGESTED THE PRIVATE SECTOR CAN IMPLEMENTO .................... 12

BIBLIOGRAPHY.................................................................................................................................... 13
 MODEL OF CORPORATE INTEGRITY PROGRAM

Article 12 of the United Nations Convention against Corruption (2003), of which

Mexico states that countries must take measures to prevent corruption, improve the
accounting and auditing standards in the private sector, as well as foresee the corresponding sanctions
in case of non-compliance, among other commitments made.
Likewise, based on what is established in the General Law of Responsibilities
Administrative (LGRA) in its Articles 21 and 25, and in order to guide the private sector in the
regulatory framework in anti-corruption matters, a Model of Integrity Program is proposed
Business to facilitate compliance and installation in the private sector.
Article 21 of the LGRA establishes:
The Secretariats may enter into collaboration agreements with individuals or
morals that participate in public procurement, as well as with business chambers
and industrial or trade organizations, with the purpose of guiding them in the
establishment of self-regulation mechanisms that include the implementation of
internal controls and an integrity program that allows them to ensure the development of
an ethical culture in your organization
In the case of Article 25 of the same Law, the specifications that the Policy can be found.
of Integrity must contain:
In determining the responsibility of legal entities referred to in the
The present law will assess whether they have an integrity policy. For the purposes of this
Law, an integrity policy will be one that has at least the
following elements:
I. A clear and complete manual of organization and procedures, in which it
define the functions and responsibilities of each of its areas, and specify
clearly the different chains of command and leadership throughout the structure;
II. A code of conduct that is properly published and socialized among all members of
the organization, which has systems and mechanisms for real application;
III. Adequate and effective systems of control, monitoring, and auditing, which examine
constantly and periodically ensuring compliance with integrity standards throughout the
organization
IV. Adequate reporting systems, both within the organization and towards the
competent authorities, as well as disciplinary processes and concrete consequences
regarding those who act contrary to internal regulations or legislation
Mexican
Appropriate training and education systems and processes regarding the measures
of integrity that is contained in this article;

Unit of Ethics, Public Integrity and Prevention of Conflicts of Interest 1

 VI. Human resources policies aimed at preventing the incorporation of people who
may pose a risk to the integrity of the corporation. These policies under no circumstances
they will authorize the discrimination of any person motivated by ethnic or national origin, the
gender, age, disabilities, social condition, health conditions, religion,
opinions, sexual preferences, marital status, or any other that goes against the
human dignity and is intended to annul or undermine the rights and freedoms of the
people, and
VII. Mechanisms that ensure the transparency and publicity at all times of its
interests
The following are a series of actions and guidelines that the private sector will be able to
implement in accordance with the provisions established in each of the fractions of Article 25 of the LGRA.

I. A manual of organization and procedures that is clear and complete

A manual of organization and procedures that is clear and complete in which the boundaries are defined
functions and responsibilities of each of its areas, and that clearly specify the different
chains of command and leadership throughout the structure:
Promote the adoption and respect for the internal rules and accountability of the company.
the same that must be in accordance with national and international legislation,
such as the commitments made in the United Nations Convention against
Corruption (UNCAC); the Inter-American Convention against Corruption of the
Organización de Estados Americanos; Foreign Corrupt Practices Act (FCPA); Cumbre
London Anti-Corruption; Convention to Combat the Bribery of Public Officials
Foreigners in International Trade Transactions of the Organization for
Cooperation and Economic Development (OECD); G20 Anti-Corruption Working Group
among others.1

Ensure commitment from executives and senior management of the company to prevent
and inhibit corruption.
The companies or providers contracted by the company must adhere to the policy of
integrity, for this purpose, the mandatory inclusion of anti-corruption provisions is suggested in
internal contracts or with other companies or suppliers.

1 United Nations Office on Drugs and Crime, United Nations Convention against Corruption, 2003. Available
en: Unable to access external content
Organization of American States, Inter-American Convention against Corruption, (1996). Available at:
http://www.oas.org/en/sla/ddi/multilateral_interamerican_treaties_B-58_against_Corruption.asp
Criminal Division of the Department of Justice, Securities Commission Enforcement Division. Resource Guide to the U.S. Foreign
Corrupt Practices Act. Washington, D.C. 2010, pp. 130. Available at:
Unable to access external documents or URLs.
London Anti-Corruption Summit, (2016). Available at:
Content from external links cannot be accessed or translated.
OECD, Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, (1997).
Available at: https://www.oecd.org/daf/anti-bribery/ConvCombatBribery_Spanish.pdf

2
 Good practice: The ICC Anti-Corruption Clause can be taken as a reference.
Mexico, which seeks to promote the inclusion of businesses of all sizes
text in all contracts or agreements they enter into. The text is as follows:
The parties state that during the negotiations and for the celebration of
This contract has been conducted in accordance with the Code of Conduct for
combat extortion and bribery published by the Chamber of Commerce
International (The Rules) and who commit to act in accordance with them
during its execution towards its counterparts and towards third parties. The parties
they expressly accept that the violation of these statements or 'The Rules'
it implies a substantial breach of this contract.2
It is a priority to facilitate and provide greater openness in information to minority partners with
the purpose of communicating the company's results in promoting and developing a culture
internal ethics.
Good practice: 'Rio Tinto', a mining company from Great Britain, applies a questionnaire.
annual to the middle management executives in which they must answer how they are complying with
its obligations and objectives of the company. Such obligations address issues such as
financial, environmental, security, human resources and ethics and corruption. The merit of
the application of this questionnaire lies in the importance given to the need for
interrelate organizational and financial goals with integrity and ethics objectives
from the company.3

II. A code of conduct properly published and socialized

A code of conduct properly published and socialized among all members of the
organization that has real application systems and mechanisms:
Develop general guidelines for Codes of Ethics, Integrity, and Conduct for the
Mexican entrepreneurship, with the aim that companies -according to their sector,
needs and circumstances - take these guidelines as a basis.
It is recommended to use the phases as a reference for the preparation of a Code of
Conduct, established by COPARMEX in the document 'Guidelines for the
implementation of an integrity policy for companies (legal entities).
Minimum requirements for its implementation from 2016.4

2InternationalChamber of Commerce - Chapter Mexico, ICC Manual: Combating Corruption, Mexico City, 2007. Available at:
Unable to access external documents or URLs.
3
Price Waterhouse Coopers
Available en The provided text is a URL and does not contain translatable content.
corruption-effective-anti-corruption-programme.html
4
COPARMEX. Guidelines for the implementation of an integrity policy for companies (legal entities). Requirements
minimums for its implementation. (Art. 24 and 25 of the General Law on Administrative Responsibilities). Mexico. 2016.

Unit of Ethics, Public Integrity and Prevention of Conflicts of Interest 3

 A code of business conduct must contain as a sine qua non condition
anti-corruption clause or guidelines that prevent it, as well as mechanisms of
prevention of conflicts of interest. Additionally, it must promote the correct, honorable and
due to the exercise of commercial activities, as well as being accompanied by values
explicit integrity and ethics to provide guidelines for employee conduct.
The Secretariat will promote the dissemination of 'best practices' regarding the codes of
conduct or ethics that can be considered as a reference point for private initiative.
Companies are advised to conduct periodic reviews of their codes of conduct or
integrity taking into account national or international cases that represent
a "best practice".
The code of conduct must be communicated to all employees, partners and
suppliers and the company will commit to implementing measures for its dissemination,
knowledge and internalization, either through training or staff development
in the subject. The mechanisms of understanding and are at the company's discretion
understanding of the Code of Conduct.
In order to prevent a Code of Conduct from ending up as a merely declarative document, it is
of great relevance that measures are taken for their applicability and sanction procedures
in cases of non-compliance, as well as to refer serious cases to the authorities
corresponding.
It is recommended for large companies with multiple areas of risk within the same one.
organization - that in addition to the Code of Conduct, a protocol is developed
performance for each area that has the most contact with factors that involve risks to the
integrity. This action protocol may include measures that employees
they must observe in their dealings with public servants, suppliers, investors, clients,
another type of audiences and that increases the potential to incur in possible acts of corruption.
Good practice: COPARMEX, in its previously cited document, refers to, in a manner
illustrative, to the Codes of Conduct of 'The Coca Cola Company' and 'Grupo Bimbo':

The Coca Cola Company:

Invalid URL provided. Please provide a text for translation.
colacompany.com/content/dam/journey/us/en/private/fileassets/pdf/2012/11/COBC
Spanish.pdf
Bimbo Group:
The provided text is a URL and does not contain translatable content.
No translatable text provided.5

5Same here.

4
 III. Adequate and effective systems of control, surveillance, and auditing
Adequate and effective systems of control, monitoring, and auditing that examine continually.
and periodically the compliance with integrity standards throughout the organization:
An Anti-Corruption or Business Integrity Program must start with the development of a
Risk Analysis within the company. To this end, it is important to consider the risks.
externals to companies, noted by the 'Guide for the Application of the Bribery Act' of the Kingdom
United
country risk
Sectoral risk
transaction risk
Risk of business opportunity
Risk of commercial association
In this regard, it is recommended to refer to the Internal Control Model.
International 'COSO', which arises with the objective of preventing financial fraud and consists of
in five components: control environment, risk management, activities of
control, information and communication, and finally, supervision.
Based on the results of the risk assessment and after identifying the most
prone to these, the company must adjust its control, surveillance, and audit systems to
mitigate the identified risks, according to the particular needs you have.
The United Nations Convention against Corruption recommends that the elements
The basics of an audit consist of examining the effectiveness with which assets are controlled.
revenues are accounted for and expenses are recorded; a global audit must also
examine the identity and effectiveness of financial and operational control systems,
administrative; as well as examining the legality of operations and safeguards against
fraud and corruption.
In the same vein, COPARMEX points out the three guidelines that it recommends.
Deloitte consultant for the effective implementation of internal control measures in
the companies, which consist of:
. The Single Circular of Banks (Chapter VI of Title Two)
. The Single Circular of Brokerage Houses (Chapter I of Title Five)
. The Sarbanes-Oxley Act (Sections 302 and 404)6

6Ibid.

Unit of Ethics, Public Integrity and Prevention of Conflicts of Interest 5

 It is recommended to pay special attention to the areas of sales, hiring, resources
humans, contact or relations with the public sector, contact or relations with other sectors
or companies, opening markets in an unknown country or area, among other risky areas.
To ensure proper risk management, it is also recommended
take as a reference the ICC Rules to combat Corruption
Requirement of integrity for business partners or associates, such as subsidiary companies.
or joint ventures, temporary unions, intermediaries and representatives, suppliers and
contractors, service providers, managers, consultants, and professionals such as lawyers and
accountants. In the same vein, the Guide for the application of the UK Bribery Act
advises the implementation of due diligence:
Due diligence [...] must be carried out using a risk-based approach.
In higher risk situations, due diligence may include carrying out
direct interrogative inquiries, indirect investigations or research
general about the proposed associated persons. It may also require the
continuous evaluation and monitoring of the 'associated' people recruited or
hired, in proportion to the identified risks [...]7
Good practice: The company SASOL from South Africa has a 'forensic team' that is
charged and authorized to investigate any signs of corruption or activities
suspects. This team has been able to prevent acts of corruption while at the same time has
recovered resources that could have represented high costs due to bribes or
equivalents. The importance of this good practice lies in that this forensic team
contributes to research processes, whether to prevent or correct acts related
to corruption, for this they resort to elements such as auditing or other mechanisms of
research.8

IV. Adequate reporting systems

Appropriate reporting systems both within the organization and to the authorities
competent authorities, as well as disciplinary processes and concrete consequences regarding those who act
in violation of internal regulations or Mexican legislation:
In order to comply with this provision, it is of great importance to encourage and
maintain cooperation between the public and private sectors, especially in matters of
compliance with the legislation. In order to break the cycle of corruption and impunity, the
companies and public entities and dependencies must contribute to the dissemination of
knowledge about where and how to report or denounce a possible act related to corruption.
Establish reporting channels that allow for the maintenance of confidentiality and integrity of
complainant. An example of a complaint reception mechanism may consist of a

7UK Bribery Act, cited in CoparmexOp. Cit.

8PriceWaterhouse Coopers, op. Cit., Ibidem

6
 telephone line where customers, employees, or other parties can call without fear of
reveal their identity. Online mechanisms or an email can also be implemented.
electronic device created exclusively for these purposes.

It is important to note that the mechanisms for receiving complaints must be

accompanied by policies that ensure the follow-up and resolution of complaints,
ensuring confidentiality and protection for the whistleblower, especially in matters of the
personal data and identity.
Having an adequate process (for example, a "forensic team" like that of SASOL) to
to prevent the misuse of these mechanisms, which can be used as means to
discredit or raise false statements. In this regard, it is recommended simultaneously
protect the rights of the accused and the complainant. To do this, it will be necessary to have a
mechanism for tracking and investigating complaints and channeling grievances to the
corresponding instances in case they lead to possible violations of the regulations
national or international.
It is recommended not only to implement complaint reception systems but also to
advisory and timely monitoring of the eventual presentation of corruption cases, as well as
the presentation of internal research results at the highest level of the company and in its
case, to the corresponding authorities.
Disseminate and socialize the Code of Conduct to promote vigilance, cooperation and
generation of an ethical culture and shared responsibility among the people of the same company.
It is recommended that each company, depending on its size, sector, and circumstances,
implement measures to promote the exercise of reporting without prejudging on the
the seriousness that it must maintain. At the same time, the importance of
implement actions that aim to strengthen and dignify the figure of the whistleblower and prevent
negative signals or prejudices against people who, in good faith, report actions that
may involve abuses or violations of national, international, or
integrity.
Good practice: 'Rio Tinto', the mining company from Great Britain that was mentioned
previously, it has a confidential hotline for complaints, these lines are
managed by personnel independent from the company and the interviews or conversations are
delivered each month to the directors. The above guarantees that serious incidents are
reported to the relevant executives and upper management for subsequent action
actions in case of affirming the truth of the facts.9

9The same place.

Unit of Ethics, Public Integrity and Prevention of Conflicts of Interest 7

 V. Adequate training and development systems and processes
Appropriate training and development systems and processes regarding the measures of
integrity contained in this article:
It is recommended that the private sector establish and implement training programs.
educational for their employees in matters of ethics; company code of conduct;
compliance with national and international legislation in the field; the integrity policy
from the company; among other topics, periodically and to monitor compliance with
exposed in said training sessions. For the training sessions to meet their objective it will be
It is necessary to consider the preparation and delivery of material in training sessions for ease.
employee access in the organization.
The courses must include topics such as: compliance with the law and penalties; guidelines
general aspects of national and international regulations on anti-corruption and
anti-bribery; prevention and management of conflicts of interest; business ethics and integrity,
among others. The foregoing, always considering the organization's Code of Conduct.
It is recommended to provide special attention and training to the staff involved in
activities prone to greater risks to integrity.
Socialize the best practices in corporate integrity programs in the
cameras through forums, seminars, working tables, etc. to promote exchange
of experiences and learnings. The above will allow the private sector to present to the sector
public, civil society organizations and the general population, the practices that are being
carrying out.
Good practice: Transparency International – Colombia Chapter has implemented the
Business Direction Program – Integral and Transparent10that aims to generate
ethical practices in small and medium enterprises in Colombia, thus contributing
a way to combat and prevent corruption. The Program consists of a four workshop
basic modules and six thematic support modules. At the start of the program, a diagnosis is carried out.
of the ethical climate in the company and based on the results, the modules are selected.
necessary to strengthen the areas of opportunity for the company. To date, 761 companies
they have implemented the Program in 35 Colombian cities with an impact on more than 148
one thousand employees of the private initiative.11

VI. Human resources policies aimed at preventing the incorporation of people who
they can pose a risk to the integrity of the corporation
Human resources policies aimed at preventing the incorporation of individuals who may generate
a risk to the integrity of the corporation. These policies will not authorize in any case the

10Invalid
input. Please provide text for translation.
11
Transparency International–Colombia, Route Companies Program–Honest and Transparent. Available at:
The provided text is a URL and does not contain translatable content.

8
 discrimination against any person motivated by ethnic or national origin, gender, age, the
disabilities, social condition, health conditions, religion, opinions, the
sexual preferences, marital status, or any other that threatens human dignity and has
with the purpose of nullifying or diminishing the rights and freedoms of individuals:

Encouraging employees to follow regulations on anti-corruption and processes,

Similarly, the United States Department of Commerce recommends not to discourage.
the creativity and contributions of its employees. However, the difference between is highlighted.
making mistakes and the lack of ethics, the latter being a deliberate, intentional action or
negligent that directly affects the company and its reputation.
Companies and the private sector are responsible for hiring their staff based on the
principles of honesty, integrity, respect, and non-discrimination, through the methods
that they consider pertinent. In accordance with the above, it is recommended to carry out processes
due diligence in order to analyze or assess the risks regarding the
associations, contracts, sales, human resources, among other risk areas.
Hello ICC Mexico, in its document 'ICC Rules to Combat Corruption'
It is recommended to consider the rotation of personnel in positions or roles.
that carry risk functions to integrity.12
It is suggested to establish mechanisms to recognize personnel who excel in compliance with
the integrity policy, such as granting recognitions of probity to serve as
reference for the other employees of the organization. In this regard, the company SASOL of
South Africa calls this team 'Ethics Champions' and these employees seek
influence the behavior of their peers.
Good practice: As part of its human resources policy, BBVA Bancomer requests
to have its employees sign a Commitment Letter in which the guidelines are detailed
ethics to which the employee must adhere in the performance of their duties. That letter
also considers issues of conflict of interest, bribery, and other acts associated with
corruption which they commit to avoiding.

VII. Mechanisms that ensure transparency and publicity at all times.

interests
Mechanisms that ensure the transparency and publicity of their interests at all times:

Present the Manifesto of links or relationships with public officials as provided in the Annex.
According to the Protocol for Action on public contracting, granting and
extension of licenses, permits, authorizations, and concessions, when the legal entity wishes

12International
Chamber of Commerce - Chapter Mexico, ICC Rules to Fight Corruption, Paris, 2011, pp. 16. Available
http://www.iccmex.mx/uploads/anticorrupcion/herramientas/Reglas_de_la_ICC_para_Combatir_la_Corrupcion_edicion2011.pdf

Unit of Ethics, Public Integrity and Prevention of Conflicts of Interest 9

 participate in any of the mentioned processes. It can be done at the following link:
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Establish Integrity Pacts and Agreements with other companies and with the public sector to
ensure the commitment of companies to make their processes transparent as a measure to
the prevention of fraud and acts associated with corruption. In the same vein, it is recommended
that organizations or companies are transparent about the ethical model with their
respective partners.
Publish or make known the company's integrity policy, as well as its interests, in
in case they come into conflict with those in the public sector.

As part of the integrity program, the obligation will be established that all
employees must cooperate in research or audit processes, especially in
those who require information about the operations of the organization, for example,
in a case of bribery.
Good practice: One of the first and most relevant Integrity Pacts established in
Mexico implemented it through the Federal Electricity Commission in contracting and management.
from the hydroelectric plant 'El Cajón'. Mexican Transparency participated as a social witness
in said tender, which was successful in terms of transparency, in addition to that it
awarded the contract to the proposal with the lowest costs, even below those budgeted
by the CFE.13

13
United Nations Office on Drugs and Crime, Resource Guide on State Measures to Strengthen Integrity
business, Vienna, 2013, p. 39. Available at: https://www.unodc.org/documents/corruption/Publications/2014/14-04939_eBook_S.pdf

10
 ACTIONS IMPLEMENTED BY THE SFP

Provides advice on anti-corruption legislation, especially the General Law on

Administrative responsibilities and recent reforms in the matter.
UNIDO14and UNODC15they recommend the creation of accessible guides and with language
simple that they make understandable the legislations and regulations that pertain to the
companies. For example, regulations related to hiring, acquisitions, construction
public, among others. Facilitating the understanding of the regulations will allow companies
small and medium enterprises can compete more fairly for contracts or
another type of processes in which they usually do not participate due to lack of information,
and not necessarily due to a lack of technical requirements.

Integrity programs and measures designed to prevent and detect corruption

consider, among other things, the following concepts:
Gifts
Hospitality, entertainment, and expenses
oTravel
Political contributions
Donations to charities and sponsorships
Facilitation payments
Request and extortion
oSoborno
Conflict of interest
Implement non-monetary incentives for companies that report detected risks.
in the procedures, contracting processes, bids through your contact with the
public administration; as well as those private organizations that implement actions
concrete measures to prevent corruption.
It grants certificates of 'Integrity' or 'Probity' to companies that stand out for the
implementation of Integrity Programs, and the demonstration and effectiveness of it.
The aim is to make better use of the list of sanctioned companies and to establish a new one.
list of companies (national and international) that follow up on a program of
integrity. With the support of organizations like the Mexican Institute for Competitiveness
(IMCO) and other academic and civil society associations, publish a "white list" and
a "blacklist" to encourage free competition for an ethical culture in the sector
private.

14United Nations Industrial Development Organization

15
United Nations Office on Drugs and Crime

Unit of Ethics, Public Integrity, and Prevention of Conflicts of Interest 11

 ADDITIONAL ACTIONS THAT IT IS SUGGESTED THE SECTOR CAN IMPLEMENT
PRIVATE

Incentive programs within the company: establish incentives (non-monetary)

to the employees who stand out for their probity, such as in the case of 'Ethics'
“Champions” of SASOL. Incentives can also be established for the “managers of
integrity" (internal whistleblowers).
Sanctions: ensure that the sanctions are implemented in accordance with the severity of the offense
internally and report to the appropriate authorities in case of non-compliance with the
Law. Reduce the spaces for impunity.
Agreements or collaboration pacts with the public sector: it is recommended to establish
of figures like the 'Business Ombudsman'; promote agreements or collaboration pacts
for the establishment of an ethical culture in the private sector; and at the same time, create spaces
new for the dissemination and exchange of best practices in integrity.
Criteria in tendering: establishment of minimum criteria that must be met
a company in order to participate in public tenders.

12
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Unit of Ethics, Public Integrity and Prevention of Conflicts of Interest 13

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Unit of Ethics, Public Integrity, and Prevention of Conflicts of Interest 15

 NOTES

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 UNIT OF ETHICS, PUBLIC INTEGRITY AND
PREVENTION OF CONFLICTS OF INTERESTS
www.gob.mx/ethics-unit
ueepci@funcionpublica.gob.mx