TelevisaUnivision is committed to conducting business with integrity, doing what’s right, and complying with the law everywhere we operate. This Code of Conduct for Suppliers and Business Partners (“Code”) documents the principles, guidelines, and expectations for establishing and maintaining a business relationship with us.
Applicability
The Code applies to any employee, agent, or other representative of a company, corporation or other entity that provides any goods or services on behalf of, at the request of, or in connection with work completed for TelevisaUnivision (“you”). By performing work for and on our behalf, you acknowledge that you will conduct yourself in accordance with this Code and its requirements. You are also responsible for ensuring that any subcontractors that you employ to supply goods or services to TelevisaUnivision comply with this Code.
Where this Code sets higher standards than what the law requires, we expect you to adhere to our standards. It supplements, but does not supersede, your contract with us. To the extent there is any inconsistency between this Code and any provision of your contract with us, the contractual provision will control.
Promoting and Monitoring Compliance
We expect you to establish processes, policies, and procedures designed to promote and monitor compliance with applicable laws and regulations, as well as the expectations set forth in this Code. You must take appropriate steps to ensure that the principles in this Code are communicated to your workers and throughout your own supply chain. We may ask to periodically acknowledge that you have reviewed and understand this Code and are willing to comply with its standards.
Compliance with this Code is subject to an audit at the discretion of TelevisaUnivision. Failure to comply with the Code may result in discontinuance of current and/or the prevention of future
business relationships between you and TelevisaUnivision.
Principles of Business Conduct
You must be committed to the highest standards of ethical conduct when dealing with workers, their suppliers, customers, and other third parties. We expect you to always operate in full compliance with applicable laws and regulations, including but not limited to anti-corruption laws, antitrust and competition laws, anti-money laundering and anti- terrorism laws, laws prohibiting tax evasion. We expect you to follow global trade laws and avoid doing business with counterparties that are sanctioned or restricted by the United States and Mexican governments, or by any other jurisdiction where we conduct business.
Respect Human and Labor Rights. We expect you to ensure that all workers meet applicable legal minimum age requirements, and that all labor is voluntary. You must prohibit abusive, exploitative, and illegal conditions in your hiring practices and workplace, including but not limited to forced labor, modern slavery, and human trafficking. You must also respect the rights of workers to join, associate, and participate in worker organizations, such as unions, and to collectively bargain.
Treat People Fairly and with Respect. We expect you to foster an inclusive and non-discriminatory workplace. You must comply with anti-discrimination and anti-harassment laws and
are prohibited from engaging in any form of harassment or discrimination based on an individual’s race, ethnicity, sex, sexual orientation, gender identity or expression, religion, age,
marital status, national origin, ancestry, pregnancy or maternity, medical condition, physical or mental disability, or any other trait or status that is protected by law.
Maintain a Safe and Healthy Work Environment. We expect you to implement appropriate procedures, controls, and safeguards to provide a safe, secure, and healthy working environment to your employees. To ensure a safe and healthy work environment, you must ensure that you are complying with applicable law and regulations on health and safety procedures.
Never Offer or Accept a Bribe. TelevisaUnivision has zerotolerance for corruption and bribery, and we require that you abide by all applicable anti-corruption laws and regulations.
Interactions with government officials pose special risks under anti-corruption laws, and you should therefore always approach any interaction with government officials that you have on behalf
of TelevisaUnivision with heightened caution. Corruption, extortion, embezzlement, bribery, and kickbacks in any form are strictly prohibited.
Under no circumstance should you give, pay, offer, promise to pay, or authorize the giving or payment of anything of value to any government official or TelevisaUnivision employee to improperly obtain or keep business, obtain a permit or license, secure some other improper advantage, or to improperly influence the decisions and/or actions of a government official or TelevisaUnivision employee. You must also avoid any conduct that creates even the appearance of an improper interaction with a government official or TelevisaUnivision employee, as such an interaction could compromise our reputation and values. You also may not use a third party to engage in conduct that would otherwise be prohibited by this Code.
Maintain Financial Integrity. We expect our Suppliers and Business Partners to ensure accuracy and integrity in their financial record-keeping, reporting, and public disclosures, in compliance with accounting, tax, and other applicable laws and regulations, particularly in your contractual relations with TelevisaUnivision. You should maintain books and records that accurately and completely reflect all transactions related to your business with us. You should never alter, conceal, or destroy any document to misrepresent any fact, circumstance, or transaction. We expect you to always have supporting documentation for any transaction between you and TelevisaUnivision.
Safeguard our Information and Assets. TelevisaUnivision requires that you maintain information security programs that are reasonably and appropriately designed to protect TelevisaUnivision’s confidential information and assets. If you become aware of a breach involving any of our data, you must promptly notify TelevisaUnivision. You must safeguard and protect the confidential information you obtain from TelevisaUnivision. We value the privacy of our customers, employees, and partners, and we are dedicated to earning and maintaining their trust. TelevisaUnivision expects you to operate in compliance with privacy laws, and to respect the privacy rights of individuals. Confidential information must not be copied or disclosed to any third party except as expressly permitted in writing by TelevisaUnivision.
Protect Intellectual Property. TelevisaUnivision’s intellectual property is highly valuable, and we expect you to comply with all applicable intellectual property and copyright laws and regulations. TelevisaUnivision’s intellectual property may not be taken, assigned, licensed, loaned, or otherwise disposed without first obtaining written authorization from the Company, and you exercise care to ensure that you only use TelevisaUnivision’s intellectual property, including trademarks and copyrights, as expressly authorized by the Company. It is your responsibility to safeguard TelevisaUnivision’s intellectual property from unauthorized use or access and to promptly inform us about any unauthorized use, exploitation, or access detected.
Think and Act Sustainably. TelevisaUnivision is committed to minimizing our impact on the environment. This includes collaborating with Suppliers and Business Partners that are committed to preventing, mitigating, and correcting the adverse effects we have on the environment. We expect you to operate in an environmentally responsible way, in compliance with environmental laws and regulations.
We also seek to collaborate with Suppliers around the world to prevent, mitigate, and remedy adverse human impact, as well as to reduce the environmental impacts of our operations, products, services, and supply chains.
Be Loyal and Transparent. TelevisaUnivision awards business and forms business relationships based on cost, quality, and market studies. To avoid any potential or actual conflicts of interest, you must always disclose any personal or familial relationship with any of TelevisaUnivision’s employees, which could affect or appear to affect the work performed on behalf of TelevisaUnivision. You must also refrain from using confidential information obtained through your work for TelevisaUnivision for a personal benefit or to benefit one of our competitors.
Respect Post-Employment Restrictions. Post-employment restrictions might apply to some of our former employees. We expect you to refrain from offering employment to any of these employees for a period of one year following their separation from TelevisaUnivision consistent with applicable laws and regulations.
Reporting Violations or Concerns
We encourage you to reach out to your TelevisaUnivision contact with any questions pertaining to this Code or whenever there are questions related to the appropriateness of any activity connected to your relationship with TelevisaUnivision and associated business conduct. In addition, reports of any ethically questionable behavior may be made using the TelevisaUnivision Listens helpline or web portal. For more information on the available reporting channels, visit www.TelevisaUnivisionListens.com.
Nothing in this Code or any other Company policy limits your ability to communicate with or provide information to any governmental agency or commission regarding possible legal violations without disclosure to the Company, as protected under applicable whistleblower laws.
February 2023
