Company Ethics

Message from the partners

The Lift’s Code of Ethics and Conduct is the core document of the organization and from which all policies, rights and legal and ethical obligations of behavior are derived. It is a guide that encourages and observes that our behaviors, both institutional and individual, are carried out within the framework of our values that allow us to move towards our purpose:

Extraordinary service bringing inspiring, stunningly crafted stories to life, positively impacting the world around us.

A company’s reputation is measured by its co-workers’ conduct and their conviction that when the time comes, they will always know how to make the right decision.

Corporate philosophy

The Lift has a deep interest in creating value and wealth in our ecosystem through the investment, development and management of a portfolio of excellent solutions and services for the creative industry.
In addition, The Lift exists to empower creativity through corporate governance based on environmental and social sustainability and compliance with the code of ethics.

At The Lift we are all committed to upholding the highest ethical standards to build a strong corporate culture that leads to better results, both as individuals and as an organization. These standards must outline our way of working and become the triggering element of a unique and differentiated DNA that generates pride, satisfaction and a great sense of belonging.

The Lift as a company is committed to its co-workers, the industry and its stakeholders to be a productive, positive and socially responsible company for the construction of a more prosperous country. Its leadership in the industry certainly makes us responsible for promoting, strengthening and supporting a culture of ethics and professionalism.

It is essential that our co-workers perform their duties with independence, honesty, impartiality and incorruptibility. The long-term success of our company depends on maintaining the respect and trust of our customers, suppliers and the entire ecosystem we influence.


Commitment is the cornerstone of all other principles. We uphold the original promise that brought us here with determination; we love what we do and have the strength to persevere in the face of adversity.

The commitment we have in and towards The Lift and towards Mexico has an immense sense of purpose, and it is the axis that drives us every day to seek excellence and the highest quality standards.

We at The Lift have the integrity and willingness to honor our agreements, thus building an environment of trust.

We are people without prejudice of race, ethnicity, age, nationality, gender, sexual orientation or religion, and thus we are committed to creating safe, equitable and respectful spaces based on the power of creativity.


For us, honesty is not only about telling the truth, but also about being honest with ourselves, with others and with the whole system.

Honesty promotes transparency and openness; it encourages us to be congruent and to develop consistency in our actions.

We at The Lift are honest in our thinking and in our acting. We raise our voice when something or someone poses a threat to our values, we act righteously, we speak the truth and we know, deep down, the difference between right and wrong.


At The Lift, we are aware that no two people have the same qualities or characteristics. However, we start from the premise that all people have the same value, both inside and outside the organization. We at The Lift embrace equal treatment, respect personal boundaries, encourage inclusion, and value single-mindedness.

We work to foster an environment of shared freedom, honoring individual character and positive interpersonal relationships, being empathetic and conscious, always keeping in mind that everything begins with self-respect.


Keeping a solid set of internal values and clear personal standards gives us greater certainty in our behaviors, which builds stronger, long-term trusting relationships.

All of us who work at The Lift are congruent to always act according to our values, honoring what we say, and being true to what we believe in.


At The Lift, we put principles before personalities. We seek the common good as a daily practice, recognizing results as the consequence of teamwork and collective talent.

We collaborate in all projects with openness, solidarity, enthusiasm and camaraderie, knowing that we are a team.

We have the ability to respond as one, to work as a team and to honor each other’s capacity as individuals belonging to the same organization.


At The Lift, we understand that we are responsible for our ecosystem. We seek to carry out actions and behaviors that have a positive impact on our ecological environment.

We are committed to society and to our industry, seeking to be a role model for positive change; we inspire our co-workers to contribute value and be excellent in all their tasks, while keeping a balance between their professional and personal interests.
Purpose of the Code of Ethics and Conduct

The Code of Ethics and Conduct describes, in very clear and practical terms, the minimum standards of behavior required of all co-workers. All of them must put into practice this framework of values and principles, which will serve as a guide when decisions are made and actions are taken.

To ensure the trust of THE LIFT’s stakeholders, all co-workers will respect and adhere to its specific Code of Ethics and Conduct, which broadly covers the following ten key elements:

Key elements

  1. Personal responsibility.
  2. Law enforcement.
  3. Stakeholder relations.
  4. Ethical limitations on the acceptance of gifts, rewards, hospitality and discounts.
  5. Avoiding conflicts of interest.
  6. Limitations on political activity.
  7. Conduct in money matters.
  8. Confidentiality and use of official information.
  9. Use of property and official services.
  10. Work environment.

Each of these elements is described on detail later in the text, along with indispensable policies on the implementation of some of these elements in certain particularly sensitive areas.

We encourage all members of THE LIFT to review and reflect on ways in which they could add value to this Code of Ethics and Conduct, particularly on the evolving issues related to integrity.


General rules

All THE LIFT co-workers must accept personal responsibility for compliance with the Code of Ethics and Conduct. In particular, all co-workers must:

Perform their duties with honesty, commitment, creativity, care, diligence, professionalism, impartiality, and integrity;

— Implement ethical standards in the strictest and broadest manner, in order to maintain the certainty and trust of the stakeholders they serve;
— Take the time to read and understand the Code of Ethics and Conduct, and the consequences of non-compliance;
— Refrain from engaging in financial transactions that conflict with the strict and accurate performance of the duty;
— Refrain from engaging in financial transactions by virtue of confidential official information, or allowing the misuse of such information for the benefit of any particular interest;
— Observe all relevant legal provisions, acts, laws, regulations, decisions and instructions relating to the performance of official duties and avoid any actions that may create even the appearance of violating any provisions, acts, laws, regulations, decisions or instructions;
— Treat colleagues and the public in a professional manner, with courtesy, integrity, respect and empathy;
— Act with impartiality and not treat any private individual or organization preferentially;
— Avoid waste or misuse of organizational resources;
— Carry out sustainable practices;
— Demonstrate honest endeavor in the performance of their duties in accordance with all laws, policies, statutes, rules, regulations and the Code of Ethics and Conduct;
— Avoid making commitments or promises of any kind without authorization, which knowingly involve liability or commitment for THE LIFT;
— Sign a Non-Disclosure Agreement to protect confidential company information to which he/she has had access during the performance of his/her official duties;
— Refrain from using the co-worker’s position for personal interest;
— Protect and preserve the organization’s property and use it only for authorized activities;
— Do not engage in outside employment or activities, including seeking or negotiating for employment, that are in conflict with the official duties and responsibilities of the organization;
— Bring to the attention of the Ethics Committee any act involving waste, fraud, abuse and corruption;
— Fulfill their obligations as citizens in good faith, including duties in financial matters, especially taxes, which are set by law;
— Behave in ways that positively affect both THE LIFT and its co-workers so that its reputation is strengthened;
— Following the Three Rs: Reduce, Reuse and Recycle;
— Say NO! to single-use plastics;
— Prioritize local consumption;
— Incorporate the principles of sustainability into our daily lives;
— Separate your waste properly, and
— Do not use plastic bottles and always bring a thermos.


Criminal offenses

All co-workers of THE LIFT must comply, with no exception, with any law applicable to THE LIFT, as well as to any conduct of any activity relevant to its development, operation, profit or otherwise.
Co-workers who commit offences involving, in particular, prohibited drugs, fraud, solicitation or acceptance of bribes or illegal import or export of goods, shall be subject to disciplinary measures, irrespective of any other penalties that may be applicable as a result of criminal proceedings.
All co-workers of THE LIFT must report to senior management any violations of applicable laws, as well as any instances where they become aware that they will be subject to criminal prosecution or possible criminal prosecution. Upon receipt of such information, senior management shall decide on the form in which the co-worker may be retained in his or her normal duties or, as the case may be, on the form in which the co-worker’s activities shall be modified to comply with applicable law, court order or any other applicable regulation or legal provision.
Co-workers must not use their positions or relationships in the course of their work inappropriately or interfere with actions planned by THE LIFT co-workers in charge of internal investigations or external law enforcement authorities.

Complaints against THE LIFT

It is very important that the public has complete confidence in the integrity of THE LIFT and its co-workers. In order to maintain such trust, complaints against the organization or its co-workers should be investigated promptly and objectively.

The Lift Whistleblower line:
Telephone: 800 01 ÉTICA (38422)

Charges brought in-house

If THE LIFT co-workers believe that a manager or colleague is requiring them to act in the performance of their official duties in an illegal, improper or immoral manner; or in any way violates the Code of Ethics and Conduct, they have a responsibility to report such a matter to a member of senior management or the investigations service of their department or section.
In this regard, information exchange mechanisms, if any, should be free from any undue influence.

Senior management or investigation services should take effective measures to seriously investigate complaints. In some cases, particularly when allegations are made against leaders, it may be necessary to entrust the investigation to a third-party organization outside THE LIFT. In the interest of impartiality, no one in the leader’s close circle or working with the leader should participate in the investigation.

Behavior inconsistent with the Code of Ethics and Conduct should not be considered acceptable and should be dealt with in a timely manner. Such behavior could result in disciplinary action up to and including termination of employment, in accordance with the disciplinary guidelines, policies and procedures for THE LIFT and in accordance with the applicable provisions of the Mexican Federal Labor Law.


Relations with the Public

The public expects its dealings with co-workers to be conducted within a framework of integrity, courtesy, fairness, empathy, honesty and professionalism. In order to maintain a high quality of service, all co-workers must observe the highest standards of honesty, fairness, reputation and conduct to ensure the proper performance of the service and to ensure public confidence and trust.

Co-workers shall not engage in any discriminatory practices based on race, national or ethnic origin, religion, age, sexual orientation, disability, or any other.

Promotional activities on behalf of other organizations or companies

It is essential that the interaction of co-workers with the public remains impartial and they avoid even the impression of favoring one party over another.
Co-workers shall not use or permit the use of their official position or title, or any authority associated with their position, in any manner that could be construed as implying that the organization for which the co-worker works sanctions or endorses their personal activities or those of others; or endorses any product, service or enterprise. If co-workers have doubts about the nature of such requests, they should refer the matter to their line management.


Co-workers must always consider their own safety and the safety of their colleagues in the performance of their duties as a priority. If a situation arises in which it would be more prudent to withdraw and request supplemental support from trained personnel, then the co-workers should do so. In all cases, senior management must be immediately informed of such an action as soon as safety conditions allow it.

Deals with the business environment

The business environment must be aware of the ethical standards practiced by THE LIFT and must ensure that its own practices do not put pressure on co-workers to deviate from those standards.

Any attempt by any member of the business community to offer inducements or other benefits in exchange for favors or special treatment should be reported immediately in writing to the appropriate line manager or the service investigations section.


Gifts and hospitality

The co-worker’s functions often bring him or her into contact with people and organizations that do business, as well as with those that carry out regulated activities. While it is important to keep contact with external entities, it is essential that they have the perception that co-workers are not involved in any form of bribery or corruption.
Offering gifts and/or other advantages to co-workers by individuals or organizations may be, or may be seen as, an attempt by the outside party to influence a decision that is expected or required of a co-worker.

Therefore, in such situations the acceptance of gifts is improper, provided it is done for corrupt or bribery purposes. Co-workers are invited to apply the appropriate criteria to avoid situations of real or perceived conflict.

In doing so, they should handle the following criteria with respect to gifts, hospitality and other benefits, and interpret them in the framework of the whole context of this code.

Co-workers shall not accept or solicit gifts, hospitality or other advantages of any kind that may exert a real or apparent influence on their objectivity when carrying out their duties or that may place them in a position of obligation to the donor. This includes, for instance, free or discounted admission to sporting and cultural events that occur because of an existing or potential employment relationship directly related to the co-worker’s duties.

Acceptance of gifts must be clearly regulated and will be permitted only if:

— It falls within the ordinary rules of politeness, hospitality or protocol; and,
— It does not compromise or appear to compromise in any way the integrity of the co-worker in question or his or her organization.

When it is impossible to refuse gifts, hospitality and other benefits that do not comply with the principles specified above, or when it is believed that the organization would benefit from accepting certain types of hospitality, the co-worker shall seek for written instructions from his or her line managers. Senior management will then notify the co-worker in writing if gifts, hospitality and other benefits are to be refused or retained by the department, donated to charity, thrown away, or retained by the leader involved.

In the event that a more expensive item is accepted, e.g., offered by a foreign government, for cultural or protocol reasons, the item should be handed over to the organization’s management and should not be considered as the co-worker’s personal property, but as official property. If possible, an attempt should be made to diplomatically return the gift to the giver. In all cases, regardless of the value of the item received, co-workers must inform in writing to the senior service manager of the gifts or hospitality received and the item must be recorded in a register. The record should include the name of the co-worker receiving the gift or hospitality, the supplier, a description of the item and its precise value.

Personnel involved in procurement

Personnel involved in procurement must pay special attention not to violate existing rules and safeguards or behave in a manner that would subject them to accusations of unfair procurement practices. Therefore, staff should not accept, under any circumstances, gifts or hospitality from current or potential suppliers.

Windfall profits obtained as a result of goods and services purchased with government funds

Many commercial organizations offer gifts to everyone who uses their services. To the extent possible, all incidental benefits that would not be available to the general public under a similar contract should be used only by the organization and under no circumstances should individual co-workers take advantage of such benefits for personal use beyond the parameters provided.

Free travel offers for official purposes

Some commercial organizations such as airlines or ferry companies offer gifts in the form of free travel on vacant seats to organizations for use in official activities. Such offers should not be accepted without prior approval of appropriate senior management in certain specified instances, and strict agency accounting practices should be applied in full, because it may give rise to the suspicion that an improper relationship exists between the company making the offer and THE LIFT.

Concessions and discounts offered to members of THE LIFT

When companies offer discounts on their goods or services to all or a significant number of the organization’s personnel, and provided that the offer is made on the basis of the purchasing power of the personnel as individuals, the relevant senior leaders may approve the co-worker’s acceptance of such discount benefits. However, special care must be taken to avoid the possibility that any private benefit obtained could influence the award of a contract or decision made by THE LIFT. In addition, in such cases, the agency’s strict accountability practices should be used accordingly. Therefore, THE LIFT should not negotiate with organizations with which it has official relationships, offers of discounts and other similar benefits.


Personal association with those who do business with THE LIFT

Conflicts of interest, or the appearance of a conflict of interest, can arise from official dealings with, or decisions made regarding, individuals who share private interests.

For example, membership in corporations, clubs, other organizations, or even family relationships may create conflicts of interest or the appearance of a conflict of interest.

When an actual, perceived and/or potential conflict of interest arises, co-workers should advise their line managers in charge of ethics or other designated managers for such purpose, and ensure that their roles do not place them in a position where they could be accused of unfairness.

Challenge procedures, which should exist within THE LIFT, should be observed so as to avoid or withdraw from participation in any situation that could lead to a real or apparent conflict of interest. THE LIFT should set up easily applicable procedures that allow for a challenge of the collaborator in such cases. If a decision is made not to fully remove the staff member from the case, the procedures foreseen should also allow for the appropriate definition and management of the situation with a view to achieving a resolution under the best possible conditions.

Employment of family members

Any co-worker who has a family member employed in a category of employment in which the co-worker could not be hired as an outsourced co-worker due to the likelihood of a conflict of interest, must transmit a report through his or her line manager to the ethics service or the co-worker involved to determine whether the employment is a conflict of interest or appears to pose a conflict of interest with the co-worker’s performance of official duties.


Co-workers must follow the guidelines provided by the competent authorities so as not to compromise, or appear to compromise, official activities due to improper political activities or comments made in the workplace. The rules governing activities related to the policy must be clearly communicated to co-workers. Co-workers should be reminded not to make inappropriate comments in public on matters involving sensitive issues such as the organization’s internal policies and programs.


General rules

Co-workers must meet all legitimate financial obligations, especially those mandated by law, including the payment of their taxes.

Private financial transactions

Co-workers are urged not to engage in private financial transactions among themselves, and transactions between supervisors and their subordinates are strictly forbidden. This includes making loans to staff members and/or acting as guarantor or providing collateral on loans. Co-workers who are not in a relationship of superiority/subordination, and who undertake voluntary private transactions with other co-workers, do so at their own risk.

Those entering into such agreements must ensure that THE LIFT’s work and reputation are not damaged by their private arrangements, but (as a general practice) such transactions should be avoided altogether and shall not be undertaken during working hours or using the property or resources of the organization.

Handling official money

The receipt and custody of any payment to official bodies should be the sole responsibility of those who are required to do so in the course of their duties. Under normal circumstances, no other co-worker should accept money owed to THE LIFT unless they have been specially authorized to do so. When such authorization is granted, it must be confirmed in writing.
A co-worker who receives money or any form of payment must issue a receipt in the specified way. In the event that an official receipt cannot be issued immediately, a provisional receipt shall be issued and a copy of the receipt shall be signed by the payer as confirmation that the amount stated on the receipt is correct. The co-worker must keep a copy of this document. All monies accepted on behalf of THE LIFT must be accounted for immediately and in accordance with established instructions.

All co-workers have a responsibility to the public to use the money collected only for official purposes and to optimize the use of resources. In addition, co-workers must avoid creating the impression or the appearance that funds raised for official purposes are being used for the personal benefit of any member of THE LIFT.


All co-workers are under an obligation not to disclose (without appropriate authorization and without a lawful purpose) any information that has come to their knowledge in the course of their duties, such as internal management information and/or sensitive information retrieved from automated systems related to law enforcement. Official information includes any information known to the co-worker by reason of his or her duties, information that the co-worker knows or reasonably should know, which has not been made available to the general public. This rule extends to all documents, records and information stored electronically. In addition, co-workers are required to protect the private data of individuals and companies during processing.

Examples of the misuse of official information include the following:

— providing official information to someone who does not have the legal authority to receive such information;
— use the information for personal or private advantage; and,
— taking advantage of a person based on information known through consultation of confidential records.

Participation in any of the above activities is prohibited and may lead to disciplinary action and/or prosecution.


General rules

Use of official ID

THE LIFT co-workers must only use badges, credentials and IDs in the performance of their duties. Identity badges and security items are distributed to assist and identify co-workers in the performance of their duties and in the exercise of the powers entrusted to them. They must not be used for any other purpose. The co-worker must take care of the security badges, keys, passwords and the like that he or she has received, and must turn them in to THE LIFT upon termination of his or her employment.

Access to and use of the electronic network

Limited personal use of the Internet, intranet and e-mail will be allowed as long as it is in compliance with all related legislation, policies and guidelines and does not affect the co-workers’ productivity.

Examples of acceptable limited personal use include professional activities, career development, and reading or writing short e-mails after work hours or during breaks.

Examples of misconduct related to the use of official electronic networks include:
knowingly viewing, downloading, possessing or distributing pornographic images or material;
transmitting images, material or e-mails containing offensive language or inappropriate comments;
copyright infringement; and/or
interfering with and attempting to circumvent the security mechanisms of electronic networks.

Authorized collaborators may have access to restricted sites when conducting authorized research or when researching and developing approved training material.


General Principles

All co-workers have the right to enjoy a safe and healthy work environment, free from discrimination and harassment, in which they can achieve their individual goals, as well as those of the organization. A good working environment meets the following conditions:
Is fair and equitable;
Is safe and supportive;
Is alcohol and drug free;
Is free from harassment and discrimination;
Is inclusive, i.e., respects individual differences and cultural diversity;
Fairly informs the co-worker about the evaluation of his or her work, as well as about the opportunities for improvement available to him or her;
Supports staff participation in the decision-making process.

Fairness and non-discrimination

Commitment to fairness and non-discrimination is essential to uphold THE LIFT’s standards of fairness, ethical conduct and accountability. All co-workers must be proactive in ensuring that the work environment at THE LIFT is free from discrimination and harassment of any kind, including sexual harassment.


We at THE LIFT welcome diversity and are aware that each person has unique characteristics, skills and limitations that are different from others. We trust in the ability of our co-workers and we work every day to ensure that they develop in an environment where their differences and similarities are respected, thus guaranteeing equal opportunities.

Occupational Health and Safety

All co-workers should enjoy the expectation of finding a safe and healthy work environment as far as their assigned duties are concerned, as this has a direct impact on the public’s general perception of the professionalism of the management. Likewise, co-workers must take their own responsibilities seriously, contribute to the safety of the workplace and diligently report any safety or health concerns, as well as non-compliance with rules or regulations, to their manager.

Drug abuse

THE LIFT has the responsibility to prohibit illegal drugs crossing the borders. Illegal drug users will not, in principle, qualify for employment with THE LIFT and an investigation will be undertaken and appropriate disciplinary action will be taken with respect to any co-worker who uses, possesses, sells and/or distributes illegal drugs.

THE LIFT may require all new recruits, upon written authorization, to undergo drug screening and may apply a random drug testing program to all co-workers, as well as supplemental testing measures to those co-workers who may reasonably be suspected of drug use.

Alcohol abuse

Co-workers shall not report to work or remain at work while under the influence of alcohol. Under no circumstances shall co-workers drive an official vehicle, whether on or off duty, while under the influence.

Co-workers shall not purchase or consume alcoholic beverages during working hours.

Confidentiality and anonymity policy

The identity of the complainant shall be considered confidential information, and no disciplinary action may be taken, directly or indirectly, due to the fact of the complaint, regardless of the rights that correspond, in accordance with the regulations in force, to the accused.
To ensure their full protection, THE LIFT and non- THE LIFT staff can report ethical misconduct by using our Whistleblower Hotline at the following address: or through the toll-free number 01800-4-Etica (38422).
Pending the investigation of a complaint, appropriate measures shall be taken to safeguard the interests of persons who provide information or cooperate in an investigation or audit.

THE LIFT places a high priority on maintaining the confidentiality of the information it handles. Therefore, it protects such information through physical, electronic and procedural safeguards.

Policy for protection against retaliation

As part of its ongoing efforts to promote ethical conduct, encourage a supportive work environment and resolve conflicts, THE LIFT has developed policies and allocated resources specifically aimed at guiding and assisting people in their daily work. It is critical to the success of these initiatives that everyone has free access to the use of all available resources, without limitations or fear of reprisals.
This policy is intended to reinforce existing provisions prohibiting retaliation for reporting conduct that may be unethical or constitute misconduct and to outline the steps they will take to address allegations of retaliation. It is intended to protect individuals who work at THE LIFT and those who disclose in good faith an ethical concern, inappropriate activity, suspected wrongdoing or participate in an internal audit or investigation.
Anyone who has a legitimate concern in this regard should be free to raise it without fear and should feel confident that their cooperation and assistance in reporting their suspicions of wrongdoing will not result in retaliation affecting employment conditions, working relationships, professional status or career prospects.

Under this policy, all persons working at THE LIFT are expressly prohibited from retaliating in any way against any person who in good faith reports suspected wrongdoing or who cooperates with an investigation or audit.

Under this policy, contractors, suppliers and employees who report in good faith suspected wrongdoing involving persons working at THE LIFT or who cooperate in an investigation or audit will also be protected, to the extent possible, from retaliation.

Acts of retaliation constitute misconduct that will result in disciplinary action up to and including termination or other appropriate action, in accordance with THE LIFT’s regulations, rules and policies.

Policy of Misuse of THE LIFT Whistleblower Line

The Lift Whistleblower Hotline may not be used improperly as a tool to create slander, to report actions with malice, or with the intention of obtaining any personal benefit.
Use of The Lift Whistleblower Hotline should be in compliance with the unethical conduct outlined throughout this Code of Ethics and reported in good faith.

Final Remarks

This Code of Ethics and Conduct endorses THE LIFT’s commitment to the highest standards of business, labor and social responsibility conduct. Each person is ultimately responsible for his or her actions. Our behaviors can directly or indirectly affect the image our customers have of us.
Each of us, as part of THE LIFT, has the duty to report to our line manager or through the Whistleblower Hotline: / Telephone: 800 01 ÉTICA (38422), any conduct in violation of this Code or any other legal standard, regulation, rule, measure, policy or procedure set forth by THE LIFT.


Any conduct incurred that is not allowed in the Company will be sanctioned in accordance with the Company’s policies. This Code of Ethics will be administered by THE LIFT’s Ethics Committee and will be overseen by the Audit Committee, through the Internal Audit department.

Any conduct contrary to what is specified in this Code will be considered a breach of the responsibilities assigned to the co-worker. Unlawful or unethical actions or inappropriate or improper conduct by anyone acting on behalf of THE LIFT is unacceptable.

Anyone who violates the rules of this Code of Ethics will be subject to disciplinary action, which may result in termination of employment with THE LIFT for cause, regardless of any other legal action that may be taken. If you find yourself in a situation that you believe may violate or lead to a violation of this Code of Ethics, report it to your line manager or through our Whistleblower Hotline: / Telephone: 800 01 ÉTICA (38422).