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Code of Ethics of Petróleos Mexicanos, its

Subsidiary Productive Companies and Affiliate

Companies

Property of Petróleos Mexicanos Marina Nacional # 329, Colonia Verónica Anzures, Delegación Miguel Hidalgo, Mexico City, Zip Code 11300 Phone (+52 55) 1944 2500.

CODE OF ETHICS OF PETRÓLEOS MEXICANOS, ITS SUBSIDIARY

PRODUCTIVE COMPANIES AND AFFILIATE COMPANIES

In force from

Day Month Year

25 Nov 2016

OR-03-COD-001 Page 1 of 20

Approved/Authorized This page substitutes the one approved / authorized on: Area(s)/ Collegiate Body(ies) Agreement(s)/FAC Day Month Year

Board of Directors CA-122 / 2016 11 Nov 2016 Day Month Year

Contents

Number Topic Page

Section I Overview 3

I.1 Objective 3

I.2 Field of Application (Scope) 3

I.3 Responsibilities Inherent to the Present Document and Authorization Authorities

3

I.4 Interpretation 4

I.5 Legal Framework 4

I.6 References 4

Section II Code of Ethics 5

II.1 What is Ethics? 5

II.2 Why Is It Important to Apply This Code? 5

Section III Ethical Principles 6

III.1 Respect 6

III.2 Equality and Non-Discrimination 7

III.3 Effectiveness 7

III.4 Honesty 7

III.5 Loyalty 8

III.6 Responsibility 8

III.7 Legality 9

III.8 Impartiality 9

III.9 Integrity 10

Section IV Corporate Ethics Directives 11

IV.1 Information 11

IV.2 Loyal Competition 11

IV.3 Anti-Bribery 11

IV.4 Conflict of Interests 11

IV.5 Relations with Third Parties 12

IV.6 Personal Relationships 12

IV.7 Community and the Environment 12

CODE OF ETHICS OF PETRÓLEOS MEXICANOS, ITS SUBSIDIARY PRODUCTIVE COMPANIES AND AFFILIATE COMPANIES

In force from

Day Month Year

25 Nov 2016


Approved/Authorized This page substitutes the one approved / authorized on: Area(s)/ Collegiate Body(ies) Agreement(s)/FAC Day

Month

Year


Number Topic Page

Section V Support Tools 13

V.1 How to Use This Code? 13

V.2 The 5 Questions 13

V.3 Who to Approach in Case of Doubts? 13

V.4 How to Report Violations to the Code? 14

Section VI Practice and Follow-Up 15

VI.1 Personal Liability 15

VI.2 Code of Conduct 15

VI.3 Ethics Committee 15

VI.4 Non-Retaliation Policy 17

VI.5 Infractions of the Code 17

Transitional Provisions 19

CODE OF ETHICS OF PETRÓLEOS MEXICANOS, ITS SUBSIDIARY

PRODUCTIVE COMPANIES AND AFFILIATE COMPANIES

In force from

Day Month Year

25 Nov 2016


Approved/Authorized This page substitutes the one approved / authorized on: Area(s)/ Collegiate Body(ies) Agreement(s)/FAC Day

Month

Year


Section I Overview

I.1 Objective To establish the corporate ethics regulations of Petróleos Mexicanos, its Subsidiary Productive Companies and Affiliate Companies (hereinafter referred to as Pemex). I.2 Field of Application (Scope) This Code is to be mandatorily applied to all personnel working for Pemex. Any person linked to Pemex, whose actions may affect the reputation of the company, must conduct him- or herself in a manner that follows the provisions of this Code. The Ethics Committee will propose the enforcement mechanisms for this Code, which will be applicable to all suppliers, contractors, subcontractors, and any kind of commercial partners, with the purpose of seeking to establish joint ventures with companies that share the same ethical viewpoint as Pemex. I.3 Responsibilities Inherent to the Document and Authorization Authorities.

Authority Responsibility

Board of Directors of Petróleos Mexicanos

To issue the present Code, as well as to issue the corresponding amendments and/or updates.

General Director of Petróleos Mexicanos

Submit a proposal to the Board of Directors of Petróleos Mexicanos.

Institutional Internal Control Unit

Prepare the proposal of the Code, coordinate the revision and amendments thereto, while incorporating the best practices; also, promote corporate ethics and integrity. Review, and, in case it should be deemed necessary, update the document every 2 years.

Ethics Committee Review the document and receive proposals for the update thereof. Support in disseminating and applying the present Code.


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I.4 Interpretation The interpretation of this Code falls to the Ethics Committee. I.5 Legal Framework

Article 95 of the Law of Petróleos Mexicanos.

Articles 225, Section VI, 226, Section VIII, and 227, Section XII, of the Organization Bylaws of Petróleos Mexicanos.

Guidelines regulating the Internal Control System in Petróleos Mexicanos, its Subsidiary Productive Companies and Affiliate Companies.

I.6 References.

Federal Law of Administrative Responsibilities of Public Officials.

General Law of Administrative Responsibilities.

Decree by means whereof various provisions of the Federal Criminal Code in Matters of

Anticorruption Practices are Reformed, Expanded, and Derogated, published in the Official

Journal of the Federation on July 18, 2016.

Code of Ethics for Public Officials of the Federal Government, the Integrity Regulations for

the Exercise of Public Function, and the General Guidelines to Promote the Integrity of

Public Officials and to Perform Permanent Actions that Promote Ethical Conduct, Through

the Committees of Ethics and Conflict of Interest Prevention, published in the Official Journal

on August 20, 2015.

Code of Ethics of the Petrobras System.

Ethics and Conduct Standard for Repsol Employees. Board of Directors of Repsol S.A.,

2012.

Ethics Code of Conduct, version 2.9. Statoil 2014

General Principles of the Shell Business. Shell International Limited, 2014.

Code of Ethics and Conduct of YPF S.A.

Our Code, Our Responsibility. BP Code of Conducts.


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Section II Code of Ethics

In this Code, we reflect the culture, values and principles of the company that rule our conduct, and it represents a decision-making guide for our actions. By acting in an ethical, honorable manner, we generate value as a company and maintain the trust among ourselves and with other people and partners, investors, clients, supply companies, contractors, service companies, as well as the public, with whom we interact. II.1 What is Ethics? For Pemex, ethics refers to the values and principles that rule the actions of those who are a part of Pemex. It is the collection of standards and criteria that guide us and establish the correct and approved conducts within the company. II.2 Why Is It Important to Apply This Code?

It helps to strengthen Pemex’s image and credibility.

It contributes to making Pemex more competitive, reliable and honest.

It reduces the risk of possible losses due to failure to comply with the business objectives.

It creates an improved coexistence and working environment.

It strengthens Pemex’s ethical culture.

It helps us make decisions in accordance to our ethical principles, identify which criteria are considered to be correct by our company, and to act accordingly.

It supports the building of solid and lasting business relationships with third parties who share our philosophy of ethics and integrity.


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Section III Ethical Principles

In Pemex, we have defined nine principles that will aid us in accomplishing our mission and which must be reflected in our daily actions; these principles are as follows:

1. Respect 2. Equality and Non-Discrimination 3. Effectiveness 4. Honesty 5. Loyalty 6. Responsibility 7. Legality 8. Impartiality 9. Integrity

III.1 Respect This means acknowledging our own value, rights and obligations, as wells as those of other persons.

Why is respect important for Pemex?

Because it allows for personal, professional, and family growth and contributes to the improvement of the working environment and our daily coexistence. In Pemex, we develop our activities with respect, consideration, and care towards other persons, communities, the environment, companies, and governments with whom we interact. Some examples of how we experience respect in Pemex:

By treating all persons with dignity. By taking other people’s time into account, by being on time regarding working schedules

and scheduled meetings. By avoiding nonverbal or verbal expressions and attitudes that may offend the dignity, or

the physical, sexual, or psychological integrity of other persons. By promoting a balance between the personal, family and working life. By taking care of the environment and actively pursuing its conservation. By respecting the Safety, Health at the Workplace and Environmental Protection

standards.


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III.2 Equality and Non-Discrimination It means treating all persons in the same way, by acting in an appropriate and friendly manner, without distinction, exclusion, restriction, or preference. Why are equality and non-discrimination important for Pemex?

Because these guarantee that all the personnel can access the programs, benefits, jobs, positions, or commissions under the same conditions and with the same possibilities and opportunities, depending solely on their merits, work and daily effort. Some examples of how we experience equality and non-discrimination in Pemex:

By adopting inclusive attitudes. By guaranteeing equal treatment regarding working conditions. By promoting, without distinction, the development of capabilities and abilities. By not making discriminating jokes, comments or pranks. By understanding that we are all different, and therein lies the wealth of diversity. By recognizing any well-aimed efforts.

III.3 Effectiveness This means using our capabilities and resources (time, energy, working tools, personnel, supplies, et cetera) optimally to achieve Pemex’s objectives. Why is effectiveness important for Pemex?

Because it contributes to strengthening our internal processes and thus, to increase the company’s competitiveness. Some examples of how we experience effectiveness in Pemex:

By performing our activities in due time, form, and with quality. By working appropriately as a team. By optimizing the time of our working day to generate benefits for the company. By bearing the greatest benefit of the company in mind through our actions.

III.4 Honesty This means acting righteously, adhering to the truth, equity and justice, while taking the well-being of persons and the community into account.


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Why is honesty important for Pemex? Because honesty helps us maintain an environment of righteousness and justice, thereby deepening the trust amongst ourselves. Additionally, it is a priority to be recognized by people, supply companies and the general public as a credible, reliable company. The persons we interact with must know that we conduct ourselves with honesty and that we reject corruption and any action that may affect our efficacy, damage our reputation, and expose us to unnecessary risks. Some examples of how we experience honesty in Pemex:

By respecting the property of others. By acknowledging the contributions, ideas and initiatives put forth by others. By making the appropriate use of the company’s resources. By neither lying nor misleading. By not accepting, participating in, concealing, nor promoting corruption or any illegal

act.

III.5 Loyalty This means to show support and commitment towards the company and feeling pride for being a part of Pemex. Why is loyalty important for Pemex?

Because the achievements of this company are the result of the added actions of everyone who is a part of the company. Loyalty towards Pemex leads us to direct our actions towards the achievement of the mission, raison d’être, and values of the company, thus contributing to its growth, strengthening and daily improvement. Some examples of how we experience loyalty in Pemex:

By following the strategies established by the company, always seeking to benefit it. By keeping the company’s information and resources safe. By constantly being aware of the purpose, mission, raison d’être and values of Pemex. By adding value to the company through our work and the decisions we make. By making decisions to seek the best conditions for Pemex. By feeling pride of a job well done and for belonging to Pemex.

III.6 Responsibility This means, making decisions consciously, assuming the consequences for our actions and fulfilling our obligations as best as we possibly can.


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Why is responsibility important for Pemex?

Because acting with responsibility has a positive impact on our lives, working areas, company and country. Each person working for Pemex supplies their knowledge, dedication, commitment and professional diligence to achieve the established objectives in due time and form, and with quality. Some examples of how we experience responsibility in Pemex: By asking questions and seeking answers to our concerns. By making the effort to learn and become better every day. By fulfilling our work-related responsibilities in due time, form and with quality. By reflecting on and learning from our mistakes or those of others. By admitting to our mistakes, we can correct them and prevent ourselves from repeating

them.

III.7 Legality This means complying with the terms established by laws, regulations, and other applicable regulatory provisions. Why is legality important for Pemex?

Because when our conduct enforces the established standards, the trust and certainty of our actions are strengthened. Some examples of how we experience legality in Pemex:

By knowing about and complying with the laws, standards, and provisions related to our

work. By reporting any conduct that may go against the values established in this Code and the

applicable regulations. By adhering our conduct and decisions to the applicable laws and regulations. By rejecting and reporting corruption, theft, fraud, and any other illegal action.

III.8 Impartiality This means conducting oneself and acting objectively, without influences, divisions or prejudice, treating everyone without distinction, and not granting special or preferential treatment to anyone throughout the established processes.


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Why is impartiality important for Pemex?

Because it strengthens the trust placed in us by peers, partners, investors, suppliers, contractors or third parties, upon learning that we act and make decisions based on objective criteria. Some examples of how we experience impartiality in Pemex:

By making decisions using an objective criterion. By giving every person with whom we interact the same treatment. By not allowing external influences or interests other than the company’s interests, to

affect our actions and decisions. By using objective criteria that seek to benefit the company. By performing actions and making decisions free of influences or interests that go

against the company.

III.9 Integrity It means acting by adhering to all principles and values contained in this Code. Why is integrity important for Pemex?

Because it generates trust among ourselves and third parties or companies with whom we interact, and helps us to create an environment with the necessary conditions to fight corruption. Some examples of how we experience integrity in Pemex:

By being aware that our daily actions add to or subtract from the results of the company. By acting and making decisions based on all ethical principles. By conducting ourselves with correctness in all our actions. By being congruent in our actions and words.


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Section IV Corporate Ethics Directives

These are conduct patterns that establish the behavior we must maintain in all relationships among ourselves, with commercial partners, with the community and the environment, in order to be perceived as an ethical, responsible and reliable company. IV.1 Information

In Pemex, we comply with the established provisions on matters of transparency, access to information, accountability and personal data protection.

The information published by Pemex will be precise, correct, complete, truthful and timely, and it shall be disseminated only by authorized persons and through authorized media.

Pemex will publish its information pursuant to the applicable provisions. IV.2 Fair Competition

In Pemex, we promote and foster fair and free competition.

We offer fair treatment with equal opportunities for suppliers, both individuals and companies, contractors, and any other commercial partner, through technical and financial selection criteria, which have previously been established per company.

IV.3 Anti-Bribery

In Pemex we reject bribery, kickbacks, collusion, conflicts of interest, influence trafficking, and, in general, any kind of corruption.

We are against any payment or benefit to ensure preferential treatment or accelerate the business relationships.

We neither accept nor do we grant gifts, benefits, travel, commissions, or any other form of compensation to exert an influence on a business decision, or to obtain undue advantages.

Pemex is committed to identifying and managing such risks that may expose us to acts of corruption, so as to reduce the possibility of such acts occurring.

IV.4 Conflict of Interest

We seek to prevent conflicts of interest, with the purpose of guaranteeing clean and transparent processes.

A conflict of interest is present when, due to kinship, friendship, patrimonial interests, or any other, a person favors their own interests or those of third parties over those of Pemex.


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IV.5 Relationships with Third Parties

Our business relations will be conducted in accordance with the ethical principles of the company and without placing other interests above those of Pemex.

In our commercial practices, there will be a strict compliance with the terms established in the anti-corruption provisions in force.

We are committed not to hire any persons or companies, either suppliers and/or contractors, who may incur in any practice that fails to follow the terms set forth in this Code.

We promote the adhesion of suppliers and/or contractors to this Code and to the commitment for maintaining high ethical standards.

Pemex personnel is free to participate in political activities in the exercise of their democratic rights, provided that these activities are performed outside working hours and facilities, without making use of company assets, and as long as no mention is made of their relationship with Pemex.

IV.6 Personal Relationships

We are an inclusive company, we reject any kind of discrimination and we promote a dignified, courteous, and respectful treatment towards all persons, while at all times acknowledging their rights and liberties.

We are committed to maintaining a working environment that is characterized by equality and non-discrimination, by acknowledging the value of human diversity, no matter their ethnicity or nationality of origin, their tone of skin, their culture, sex, gender, gender identity, age, disabilities, social status, financial status, health, religion, physical appearance, genetic characteristics, pregnancy, their mother tongue, opinions, sexual orientation, political identity or affiliation, civil status, family situation, family responsibilities or language.

We prohibit any conduct of sexual harassment, sexual assault, or harassment at work, as well as any kind of violence or conduct that may attack the dignity and human rights of other persons.

IV.7 Community and Environment

In Pemex, we protect the cultural heritage by respecting the principles and traditions of the communities and countries with which we interact.

We are committed to maintaining safe facilities and processes to prevent accidents, risks and harm to the people, communities, and the environment.

We protect and preserve the environment, establishing measures to avoid the harm to the ecosystem, by always following the provisions set forth on the matter.

The relationships of Pemex with municipal governments and the communities in general, are established by complying with the ethical values and principles of the company, in a framework of respect, honesty and transparency.

In Pemex, we are aware of the direct or indirect influence that our activities may have on the financial and social development, as well as on the general well-being of the communities in the areas in which we operate, and therefore we seek strategies for the best development of these areas.


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Section V Support Tools

V.1 How to Use This Code? This Code is a guide that seeks to direct the persons working for Pemex on matters of ethics and integrity; however, it cannot possibly include all the possible situations where a conflict of an ethical nature might occur. The situations that are not included in this Code must be resolved by using individual reasoning, while always respecting the principles and values herein described; therefore, the Code provides tools to aid us in strengthening our ethical criterion for decision-making. V.2 The 5 Questions The following questions will aid us in making decisions that follow the ethical principles. If, in the development of our activities, we are faced with a dilemma and the answer is not obvious, ask yourself the following questions:

Is the decision I am making… Ethical?

Ask yourself…

Does this decision follow the values contained in this Code and the Code of Conduct?

Does the decision I am making follow regulations?

Have I fully understood the consequences of this decision?

Will either this decision or my conduct be understood as an example for others to follow?

Should this matter become public knowledge, will I continue thinking I did the right thing?

If the answer to all questions is affirmative, we can consider that the decision follows the ethical principles of the company.

V.3 Who to Go to In Case of Doubt?

As a rule, we must first discuss the matter with the person who holds the immediately superior

position. Should this be impossible or if they are unable to help us to resolve the issue, then we

must continue seeking until we have found an answer or a solution. For this purpose, we can

approach the next-higher rank in the organization chart or contact the Ethics Line (EL) to request

advice and guidance on ethical issues.


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V.4 How to Report Infractions to the Code?

Ethics Line

The Ethics Line is a mechanism that provides the coordination and communications to respond

to, advise and channel cases dealing with ethical matters within Pemex. The information

collected through this medium will be channeled to the areas that are prepared to learn,

investigate, and, if applicable, penalize ethical and conduct misdemeanors.

The Ethics Line guarantees the complete confidentiality of those persons filing a report and of

the information registered therein.

In the case of possible infractions to labor-related regulations, the operators of the Ethics Line

will turn them over to the Department of Labor Relations and Personnel Services for the

corresponding response, so that, acting as a representative of the employer, it can proceed

within its field of competence.

Depending on the nature of the cases, these may also be turned over to the competent

specialized areas and/or the Responsibilities Unit for their response.

You will be able to contact the Ethics Line through an 01-800 number, an e-mail, and Pemex’s

website, which will be published through the corresponding institutional mechanism.

Responsibilities Unit.

As an additional mechanism, the Ministry of Public Function has established Citizen Attention

Modules, which the Responsibilities Unit of Petróleos Mexicanos places at the disposal of its

personnel to receive complaints and reports. You will find further information at the link:

http://www.pemex.com/ayuda/preguntas_frecuentes/Paginas/atencion_ciudadana.aspx

Speak to your

superior

Speak to the head of the

area

Call the EL

http://www.pemex.com/ayuda/preguntas_frecuentes/Paginas/atencion_ciudadana.aspx


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Section VI Practice and Follow-Up

VI.1 Personal Liability

It is fundamentally important for Pemex that those who work for the company should exercise our functions in accordance with the terms set forth in this Code; for this reason, we must train ourselves using the tools provided by the company.

All the personnel is required to sign a statement of adhesion to the Codes of Ethics and Conduct of the company.

VI.2 Code of Conduct

To support the compliance with the Code of Ethics and make its application clearer, the CEO of Pemex will issue the Code of Conduct of Petróleos Mexicanos, its Subsidiary Productive Companies and, if applicable, its Affiliate Companies, which is a complementary document that will establish all the behaviors that are expected and permitted for the persons working at and for Pemex, pursuant to the compliance with the ethical principles herein described. Affiliate Companies may follow the Code of Conduct or, if applicable, issue their own Code, as long as it is aligned with the principles contained in the Code of Ethics.

VI.3 Ethics Committee

We have a collegiate body, specialized in corporate ethics, which regulates and promotes the application of and compliance with the terms established in the Codes of Ethics and Conduct. Objectives of the Ethics Committee

To promote corporate strategies to generate the ethical environment that will promote the

achievement of Pemex’s objectives.

Promote knowledge and the practice of the Codes of Ethics and Conduct to improve the

level of ethics culture of Pemex’s personnel.

Establish measurement mechanisms on the correct execution of the ethical principles

listed in this Code, through the application of environment and service surveys, or other

means that may be considered to be convenient. These surveys will aid in detecting

conducts that may affect the healthy development of Pemex’s activities, and they will aid

in instrumenting strategies that will strengthen the enforcement of the terms established

in this Code, as may be applicable.

To learn and analyze the possible infractions to the Codes of Ethics and Conduct that are

reported through the Ethics Line.


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To learn, issue opinions, analyze and instruct the corresponding areas about the relevant

cases, regarding the possible infractions to the Codes of Ethics and Conduct, which are

reported through the Ethics Line.

Verify the response to or execution of the penalties established for relevant cases.

Establish a coordination mechanism with the Responsibilities Unit and the Internal

Auditing area for the exchange of information regarding violations or infractions of the

Codes.

Composition of the Ethics Committee

The Committee will be composed as follows:

Position Title Holder

Chairman Head of the Institutional Internal Control Unit

Deputy Chairman Appointed by the person who occupies the Chairmanship of the Committee

Permanent Member Person appointed by the head of the Corporate Department of Management and Services.

Four Rotating Members

Representatives of the corporate management, Subsidiary Productive Companies, and Affiliate Companies.

Permanent Guests

One person appointed by the head of the Legal Department of Petróleos Mexicanos

One person appointed by the head of the Responsibilities Unit of Petróleos Mexicanos.

One person appointed by the head of the Internal Auditing Department.

Secretary Appointed by the person occupying the Chairmanship of the Committee.

The four rotating members shall be appointed as follows: (i) one from the Corporate

Management of Petróleos Mexicanos; (ii) two from among the Subsidiary Productive

Companies, and (iii) one from among the Affiliate Companies. The appointments of

these members will be performed according to the terms of the Rules of Operation of the

Ethics Committee itself.

All the members of the Committee must at least hold a position as Deputy Directors, or

coordinators, or an equivalent position.

The rotating members will participate in the Committee for a term of one year.


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All the members of the Committee must be renowned for their prestige and honor.

The permanent guests will have the right to speak but not to vote.

If during the course of their participation in the Ethics Committee, one of the members is

subject to a liabilities procedure, he or she will recuse him- or herself from his or her

functions.

On the Deputies

The Members of the Ethics Committee may be substituted by such public officials who meet the requirements indicated for the regular members. These deputies must be appointed by the head of the Department or Company they are ascribed to. This appointment will be exclusively valid for the corresponding session.

On the Rules of Operation of the Ethics Committee

The Ethics Committee will prepare its Rules of Operation to achieve the objectives established in this Code.

Those Affiliate Companies that are not a part of the Ethics Committee or lack a representative in Mexico City, must form their own committees, groups or ethics boards to develop and follow up on the applicable actions on matters of ethics and integrity, which are to be in line with the terms established by Pemex on the matter.

VI.4 Non-Retaliation Policy

For Pemex, the participation of all the personnel in the compliance of the present Code is paramount, wherefore any retaliatory acts against whomever has notified or reported any conduct contravening this Code, through the mechanisms established for this purpose, are hereby forbidden, thereby guaranteeing the confidentiality thereof and protecting their identity according to the applicable provisions. Pemex personnel filing a report shall not be object of pressure, harassment, or retaliation. Filing an accusation or a report knowing that it is false, constitutes a violation of this Code.

VI.5 Infractions of the Code

All Pemex personnel have the obligation to comply with the terms established in this Code.


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Pemex commits to analyze all reports of possible infractions to this Code. The Department of Labor Relations and Personnel Services, acting in its capacity as representative of the employer, will perform the corresponding investigations and administrative processes to define the borders of labor – related liabilities, determine the application of disciplinary sanctions pursuant to the applicable provisions, which, depending on the gravity of the case, may go from a warning to termination of the employment relationship. The consequences of failing to comply with the contents of this Code may, in addition to the labor – related penalties indicated above, derive in actions or sanctions of an administrative, civil, mercantile, or even criminal nature, which will be applied by the competent authorities, as applicable. It is the obligation of the personnel and all other responsible authorities, to participate and cooperate in an integral and honest manner with any investigation or management process that takes place in relation with an infraction to this Code. The above, without impairing any of the actions initiated before other authorities.


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Transitory Provisions

First: This Code shall come into force on the day following the publishing date hereof in the Regulatory Control System. Second. Without prejudice of the terms set forth in the first transitory provision, the Internal Control Unit will be responsible for executing the necessary measures, so that the personnel of Petróleos Mexicanos, its Subsidiary Productive Companies and Affiliate Companies learn this Code and participate in the enforcement thereof. Third. Within a term of 45 business days after this Code comes into force, the Ethics Committee will issue its Rules of Operation. Fourth: Within a term no greater than 90 days after this Code comes into force, the General Management of Petróleos Mexicanos will issue the Code of Conduct of Petróleos Mexicanos, its Subsidiary Productive Companies and, when appropriate, Affiliated Companies. Fifth: The publication of this Code hereby renders the Code of Ethics Petróleos Mexicanos, its Subsidiary Productive Companies and its Affiliated Companies, which was authorized on November 7, 2014 by the Board of Directors of Petróleos Mexicanos, null and void by means of Agreement CA-119/2014, in its 881st Extraordinary Session. Sixth: For the initial session of the Ethics Committee, the integration thereof, which section VI.3 hereof refers to, the rotary members will be appointed as follows:

One representative appointed by the Corporate Finance Director;

One representative appointed by the CEO of Pemex Transformacion Industrial;

One representative appointed by the CEO of Pemex Etileno, and One representative appointed by the CEO of P.M.I. Comercio Internacional.

The above composition shall be valid for one year, pursuant to the terms of section VI.3, and upon expiry of the said term, the terms of the Rules of Operation of the Ethics Committee shall prevail.

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