Corporate Integrity Policy: What It Is, Why It Matters, and How to Implement It Without Losing Your Mind

In Mexico, corporate ethics is no longer an abstract concept or something exclusive to large corporations. Today, even a small business looking to sell to the government, sign important contracts, or simply protect its reputation needs a well-implemented Corporate Integrity Policy.

Why? Because corruption doesn’t just destroy trust — it has serious legal consequences. And worse: one poor decision by a single employee or representative can put the entire company at risk.

What Is a Corporate Integrity Policy?

Put simply, it’s your company’s immune system against ethical and legal risks. It’s a set of internal rules, documented procedures, controls, and practices designed to prevent, detect, and sanction acts of corruption within the organization.

This concept is formally regulated under Article 25 of Mexico’s General Law of Administrative Responsibilities (LGRA), which outlines what a valid integrity policy must include to have legal weight.

Here’s a key fact: if your company is ever investigated for serious administrative violations, having an integrity policy in place can be considered a mitigating factor, potentially reducing your liability. It’s not just a formality — it could mean the difference between a million-peso fine or a favorable outcome.

What Should an Integrity Policy Include?

According to the LGRA and guidelines from the Secretaría de la Función Pública (SFP), every integrity policy must include these seven core components:

1. Organization and Procedures Manual

Defines who does what within the company. It outlines responsibilities, hierarchies, and workflows — essential to maintaining order and identifying issues early.

2. Code of Conduct

A clear, practical, and well-communicated document that states: this is acceptable, this is not. It must apply to everyone — owners, executives, and staff — and carry real consequences when violated.

3. Control, Oversight, and Audit Systems

Good intentions aren’t enough. You need concrete mechanisms to ensure compliance: internal audits, reports, periodic reviews — everything counts.

4. Whistleblower System

Internal and external (even anonymous) channels for reporting irregularities. Crucially, it must protect those who report in good faith from retaliation.

5. Ongoing Training

Your team needs to understand what integrity means, how to apply it daily, and what happens if it’s breached. It’s not a once-a-year workshop — it’s part of your company culture.

6. Human Resources Policy

Hiring and onboarding processes that avoid bringing in high-risk individuals. By law, this must also prevent all forms of discrimination — gender, age, religion, marital status, or social condition.

7. Transparency and Conflict of Interest Disclosure

Your company should clearly communicate which interests it represents, who makes the key decisions, and how it avoids conflicts. Especially relevant when dealing with public entities or managing sensitive funds.

What Are the Benefits of Doing It Right?

Far more than you might think. Implementing a solid integrity policy offers legal, reputational, and operational advantages:

• Reduced risk of sanctions during administrative or criminal investigations.

• Increased trust from clients, suppliers, investors, banks, and regulators.

• Stronger company culture: fewer internal conflicts, more shared values.

• Competitive edge in public procurement and government contracts.

• Better ability to detect and resolve issues before they become scandals.

In short: it's a strategic investment with measurable returns.

Is It Mandatory?

Yes, if your company engages in public contracts or government agreements, having an integrity policy is a legal requirement. But even if you’re in the private sector, it’s highly recommended.

Without it, you’re exposed. Today, courts, auditors, the media — and even your own clients — expect companies to have clear ethical controls.

How Do You Get Started?

You don’t need to start from scratch. The SFP has published an official Integrity Policy Guide with formats, model clauses, and examples you can tailor to your industry and company size.

But here’s the catch: just copying a template won’t cut it. For the policy to be legally effective, it must:

• Be customized to your business,

• Be known and understood by your entire team,

• Be implemented in day-to-day operations, and

• Be reviewed and updated regularly.

In other words, it must be a living document, not something filed away and forgotten.

Final Thoughts

A well-designed Corporate Integrity Policy is one of the most valuable assets your company can have today. It’s not about paperwork — it’s about building a solid framework to prevent risks, comply with the law, and operate with ethics.

In an era where corruption is punished with increasing severity, having an integrity policy isn’t just defense — it’s future-proofing your business. And for many companies, it could be the line between growth… or being shut out of the game.

Want to Implement Your Own Integrity Policy Without the Headache?

At UPLAW Abogados | Attorneys-at-Law, we help companies like yours design and implement compliance-ready integrity policies aligned with the LGRA and official standards from the SFP.

🔍 Request a free compliance audit by emailing us at contacto@uplaw.com.mx or sending a WhatsApp message to +52 5655450359.