Dear collaborator:

Spanish version

Who are part of Modas y Tendencias, S.A. de C.V. (named as follows as MYT), we work in one of the most respected companies in Jalisco, with a reputation that has been improved and safeguarded over the years, through a broad culture of integrity and ethical conduct.

Our company grew based on its trust and reputation. This influences how those who hire us appreciate our services and the final product we deliver.

Because our success is so closely tied to our reputation, it is everyone's responsibility to protect that reputation.

Acting with integrity is more than protecting the image and reputation of our Company, or avoiding legal problems. It is to maintain a place where we are proud to work. It is about each of us being aware that we are doing the right thing. This means acting honestly and treating each of us, our clients, partners, suppliers and consumers, in a fair and dignified manner.

The Code of Conduct is our guide to appropriate behavior. Along with other guidelines, such as the Internal Labor Regulation, we have established standards to ensure that we do the right thing.

Keep the Code with you and consult it frequently. Keep up with the ethics training. When you have questions, look for guidance.

With your help, I am sure that our Company will continue to deserve the trust you have for us. Our reputation for integrity will endure.

I thank you for joining me in this effort.

Sincerely,

Carlos Guillermo Cervantes Fernandez
MANAGING DIRECTOR
Marcas y Tendencias, S.A. de C.V.

Acting with Integrity
Integrity is fundamental for Marcas y Tendencias, S.A. de C.V. (named MYT as follows)
Together with our values of responsibility, collaboration, quality and communication, we have one that must guide the daily actions of each of the collaborators of our company, which is Integrity.
Integrity means doing the right thing. By acting with integrity, we positively reflect the reputation of the Company in the places where we work. We want to do the right thing, for ourselves and for the company.
The Code of Business Conduct will help guide us.
The Code defines how employees should behave as representatives of this company. The Code deals with our responsibilities to the Company, to each of us, to customers, suppliers, users and the government.
We must comply with the law, act with integrity and honesty in all aspects and be responsible for our actions.

What is expected of each one
Comply with the Code and the law wherever you are.
It uses good judgment and even prevents misconduct from occurring.
Consider your actions and ask for advice
The Code tries to contemplate many of the situations that collaborators will face, but can not consider all the circumstances. You can try to get help from:
• Your management.
• The legal advisor or the managerial staff, or the finance management that supports the company.
• Some Local Ethics Officer.
• The head of Human Resources.

What is expected of the Managers and Heads of departments
That promote a culture of ethics and compliance.
Managers should be models of appropriate behavior.

When written approval is required
Some measures specifically referred to in the Code, the use of the Company's assets outside their workplace and situations of conflicts of interest require the prior written approval of the Ethics Committee. This approval must be renewed annually if the situation persists.

Who should follow the Code?
The Code of Conduct applies to all MYT employees
Employees are expected to comply with the applicable Code, laws, rules and governmental regulations. If any procedure stipulated in the Code contradicts the Law, the Law shall govern the Code.
Because MYT is a company incorporated in the United Mexican States, our collaborators, works, contracts, etc ... are subject to Mexican laws.

About concerns
We all have an obligation to uphold the ethical standards of MYT. If you observe behavior that you are concerned about or that may be a violation of our Code, report the problem immediately and provide the Company with an opportunity to address the problem and resolve it, preferably before it becomes a violation of the law. or a risk to the health, safety or reputation of the Company.

Anonymity and Confidentiality
When you submit a report to the Office of Human Resources or through the Ethics Committee, you can choose to remain anonymous, although we encourage you to identify yourself to facilitate communication. If you disclose your identity, the Ethics Committee and investigators will take precautions to keep your identity confidential, conducting a thorough and fair investigation.
To help maintain confidentiality, avoid discussing these issues or any investigation with other collaborators. Because we strive to maintain strict confidentiality in investigations, we can not inform you of the outcome of an investigation.

Research
The Company seriously considers reports of possible misconduct.
We will investigate the matter confidentially, determine if the Code or the law has been violated, and take corrective action. If you participate in an investigation related to the Code, cooperate and respond with integrity and honesty.

There will be no reprisals
The Company values the help of the collaborators that identify the problems that the Company needs to address. Any retaliation against a collaborator who presents a problem with honesty constitutes a violation of the Code. That a collaborator has reported a concern honestly or participated in an investigation can not be the basis of an action that harms their employment, including separation, demotion, suspension, loss of benefits, threats, harassment or discrimination.

False accusations
The Company will protect the collaborator who presents a concern honestly, but it is a violation of the Code to knowingly make a false accusation, lie to investigators or refuse or refuse to cooperate with an investigation related to the Code. Honest information does not imply that you are right when you report a concern, you just need to make sure that the information you provide is accurate.

Integrity in the Company
Acting with integrity includes managing commercial and financial records, company assets and use of information
a) Commercial and financial records
* Ensure the accuracy of commercial and financial records include financial statements and other records such as: quality reports, schedules records, expenses and presentation of claim forms for benefits, curriculum vitae.
b) Company assets
Protect the assets of the Company and use those assets in the manner intended.
Do not use them for your personal benefit or for someone other than the Company.
• Use your common sense. For example, the occasional telephone call or personal email from your workplace is acceptable, if excessive it is an improper use of the goods.
• Company policy may allow additional personal use of certain assets, such as a Company vehicle or wireless communication device. Always check the relevant local policies to ensure that you use them as intended.
c) Use of time, equipment and other goods
• Do not participate in personal activities during work hours that interfere or prevent you from fulfilling your work responsibilities.
• Do not use computers and equipment for outside business, or illegal or unethical activities such as gambling, pornography or other offensive subject matter. Consult the Systems Policy for additional information and guidance.
• Do not take advantage of a financial gain opportunity for which you were aware due to your position, or to the information of the Company.

Loans
Loans to officers and collaborators must be approved in advance by the Board of Directors or personnel designated to perform such functions or make such decisions.

Non-public information
What is meant by non-public information?
Information that the Company does not disclose or is not available to the public includes information related to:
• Collaborators
• Inventions
• Contracts and Tenders
• Strategic and business plans
• Important changes in the Management and / or Management
• New product launches
• Fusions and acquisitions
• Technical specifications
• Prices
• Proposals
• Financial information
• Product costs

Use of inside information
Negotiating stocks or securities based on substantial non-public information, or providing it to others so that they can negotiate is illegal and may result in legal action.Consult the Ethics Committee for additional information.

Privacy
The privacy of collaborators, business partners and suppliers is respected. We must treat personal data responsibly and in compliance with applicable privacy laws

Conflicts of interest
This section provides the rules for some situations of conflicts of interest. The Code does not contemplate any possible conflict of interest, so use your conscience and common sense. When you are not sure, go to the Ethics Committee.
• External investments
• External employment, speeches and presentations
• External service as Officer or Director
• Family and friends
• Gifts, meals and hospitality
Act on the best interest of MYT while doing your work.
A conflict of interest arises when your activities and personal relationships interfere or appear to interfere with your ability to act in the best interest of the Company.
Exercise special care if you are responsible for selecting or negotiating with a supplier.

a) External investments
Avoid investments that could affect your decision making. Specific guidelines apply to the ownership of the shares of a client, supplier or competitor of Construcciones y Carreteras, S.A. of C.V
• If you have discretionary authority to negotiate with a company as part of your work at MYT, you can not have another financial interest in the company without the prior written approval of your General Manager, who will make the necessary to the Head of Human Resources.
• If you do not have discretionary authority to negotiate with a company as part of your work, you can own up to 1% of the company's shares.
• May hold more than 1% of the shares of any client, supplier or competitor only with the prior written approval of its General Director.
• The Director General's approval must be renewed annually if he continues to hold the shares.

b) External employment, speeches and presentations
In general, you may have a job outside of MYT, as long as it does not interfere with your ability to do your job.
You can not collaborate and provide services or receive payments from any client, supplier or competitor of the Company without the prior written approval of its General Director. You must renew this approval annually.
You must have the prior written approval of your General Manager before accepting payments, reimbursement of expenses, or any other payment for speeches or presentations outside of MYT, if:
• Give a speech or presentation as part of your work with the Company;
• The speech or presentation describes your work in the Company; or
• You are formally identified in the speech or presentation as an employee of the Company.

c) External Service as Official or Director
He may serve as an officer or member of the board of directors of another for-profit company, with the prior written approval of his General Director. You must renew this approval annually.
The approval of the General Director will not be necessary to:
• Perform as an officer or director of another company, for example, a provider, at the request of MYT (however, other approvals may be necessary in that case, according to the Delegation of authority).
• Perform as an officer or director of a charity or other nonprofit or business organization, officer or director of a family business, unless the company is a customer, supplier or competitor of MYT

d) Family and friends
Who is my "relative" according to the Code?
A spouse, parent, sibling, grandparent, child, grandchild, mother-in-law, father-in-law, or same-sex or opposite-sex partner are considered family members;
Include another family member who lives or depends financially on you or on whom you depend financially. Even when negotiating with family members beyond this definition, be careful to ensure that your relationship does not interfere or appear to interfere with your ability to act for the benefit of MYT.
Many collaborators have family members who are collaborators or have some relationship with clients or suppliers of MYT.

e) Gifts, meals and hospitality
Do not accept gifts, meals or other kind of attention or any other favor from clients or suppliers if doing so could compromise your ability to make objective business decisions for the benefit of MYT.
The acceptance of gifts, meals or other kind of attention that exceeds the following limitations must be approved in writing by your Administrative Manager and made known to the Head of HR as Ethics Officer of the company.
• Do not accept gifts greater than a modest value. Examples of acceptable gifts include a pen or logo t-shirt or a small gift basket at the end of the year parties.
• Gifts or discounts offered to an important group of employees as part of an agreement between the Company and a customer or supplier can be accepted and used as provided by the customer or supplier.

Integrity in negotiations with foreigners
The external relations of MYT are fundamental to our success. We must negotiate reasonably and legally with those we meet.
• Negotiations with Government
• Negotiations with customers and suppliers
• Negotiations with competitors

a) Negotiations with Government
The nature of our business requires that we interact with officials from different levels of government, mainly in our country and we hope, with governments from other countries. Transactions with governments are covered by special legal rules and are not the same as conducting business with individuals.
- Anti-bribery
Bribes are prohibited. A bribe is to give or offer something of value to a government official to influence a discretionary decision. Some bribes include a payment to an official to favor a decision to grant or continue business relationships, to influence the outcome of an audit or government inspection or to influence tax or other legislation. Other payments to officials may constitute bribes in some jurisdictions. Consult with the Company's legal counsel regarding local anti-bribery laws.
Certain payments may be acceptable
A payment can be allowed to a government official in certain and few exceptions. When this is the case, consult with MYT's legal advisor and obtain your approval before making such payment.
Hiring of government officials
The Company may hire government officials to provide services that have a legitimate business purpose and do not conflict with the functions of the government official, such as hiring an off-duty police officer to provide security at a Company event. All such decisions must be approved in advance by the legal counsel of the Company.
Undue payments from third parties
The Company may be held liable for bribes paid by an external agent or consultant acting on behalf of the Company. When evaluating a potential third party that could interact with the government on behalf of the Company. You should not hire an agent or external consultant if there is reason to believe that you may try to bribe an official.

a) Commercial restrictions
The Company must comply with the applicable commercial restrictions and boycotts imposed by the Mexican government that prohibit participating in certain commercial activities in specific countries, persons and entities. These restrictions include, prohibitions in the interaction with identified terrorist organizations or drug traffickers. Penalties for non-compliance can be severe, including fines and prison sentences for those responsible.
It complies with the anti-boycott laws of our country, which prohibit companies from participating in any international boycott not sanctioned by the government of Mexico.

b) Negotiations with clients, suppliers
The Company values its partnerships with customers and suppliers. Treat these partners in the same way that we expect to be treated. Always negotiate honestly with clients and suppliers and treat them with honesty and respect:
• Do not engage in unfair, deceptive or confusing practices.
• Always present the Company's products in an honest and direct manner.

c) Negotiations with competitors
Be careful when negotiating with competitors and gathering information about competitors. Different laws govern these delicate relationships.

Competitive intelligence
Collaborators are asked to gather, share and use information about our competitors, but only do so in a legal and ethical manner. Just as the Company values and protects its own non-public information, we respect the non-public information of other companies.

Forbidden activities
The following basic restrictions apply to our ability to gather competitive intelligence or inside information:
• Do not participate in an illegal or illegal activity to obtain competitive information. This includes theft, unauthorized entry, eavesdropping, listening to phone calls, computer hacking, invasion of privacy, bribery, false demonstration, coercion, espionage or threats.
• Do not accept, disclose or use competitive information that you know or have reason to believe was revealed to you in violation of a confidentiality agreement between a third party and one of our competitors.
• Do not reveal or use competitive information that is classified as "patented" or "confidential" without consulting with the Company's legal counsel.
See the Competitive Intelligence or Inside Information Policy for more detailed guidance.

Code Administration
The Code of Conduct is designed to ensure uniformity in how employees behave within the Company and in their negotiations outside it. Procedures to address potential violations of the Code were developed for the entire organization.
No series of norms can contemplate all the circumstances. These procedures may vary as necessary, to comply with local law or a contract.

Responsibility
The responsibility for administering the Code lies with the Ethics Committee, with the supervision of the Financial Director and / or Administrative Manager and the General Director.

Investigation of potential violations of the Code
The Company seriously considers violations of the Code and is committed to confidentiality and investigation of the allegations. Audit, Finance, Legal and Strategic Security personnel can conduct or manage investigations. Collaborators investigated for a violation of the Code will have the opportunity to be heard before any final determination. The Company follows local grievance procedures where those procedures apply.

Decisions
The Ethics and Compliance Committee makes decisions on violations and discipline of the Code, but delegates certain decision categories to local management. Those who have violated the Code may request reconsideration and disciplinary decisions.
Consult the Ethics Committee, for additional information about the investigation and the decision-making process.

Disciplinary measures
The Company seeks to impose disciplinary measures that are adapted to the nature and circumstances of each violation, use a system of progressive discipline, issuing letters of reprimand for minor offenses that occur for the first time. Violations of a more serious nature may result in suspension without pay; loss or reduction of the increase by merit, granting of bonuses and options of actions or even dismissal.
When a collaborator is found to have violated the Code, the minutes of the final decision and a copy of a letter of reprimand will be placed in the Personnel file of the employee as part of the employee's permanent records.

Decision information and investigations of the Code
The Ethics Committee periodically informs the Company's top management about pending investigations for breaches of the Code and final decisions, including the disciplinary measures taken. The Ethics Committee publishes a representative sample of violations of the Code, eliminating the characteristics of personal identification, for the training of employees.

Signature and acknowledgment of receipt
New employees must sign an acknowledgment form confirming that they have read the Code of Conduct and agree to comply with its provisions. Collaborators will be asked to carry out similar surveys on a regular basis. Not reading the Code or not signing the acknowledgment form is not an excuse for a collaborator to violate the Code.

Exceptions
Exceptions to the provisions of this Code for officers of the Company must be approved by the Board of Directors or by the corresponding committee and will be immediately disseminated in the terms provided by law.

Office of the Ethics Committee
The Ethics Committee Office is represented by the Head of Human Resources and is available to answer any questions about the Code or Company compliance policies or to analyze any concerns you may have about possible Code violations.
To communicate with the Ethics Committee Office:
• Email: rebeca@myt.com