Translated from Spanish

Eleven Mexican companies listed in the U.S. stock market could become the first Mexican firms to be obligated to disclose their practices in accordance with environmental, social, and governance (ESG) criteria, according to new regulations from the U.S. Securities and Exchange Commission (SEC). Riding the ESG wave, which also resonates in Europe, at least one ratings agency specializing in these criteria has already set up shop in Mexico. This trend marks a new, more complex path for companies that pollute, violate human rights, or are accused of corruption yet seek to attract investors, especially in public markets. To date, it has been easier for the Mexican government to not adhere to international trends towards regulating corporate reporting of ESG risks. Experts believe that, as long as “social responsibility” remains voluntary, companies will continue to report only partially and mainly for reputational or marketing purposes. It is often easier for companies to purchase a social responsibility label than to submit to the scrutiny of ESG rating agencies.

By Elizabeth Rosales

While the United States discusses how to regulate publicly-traded companies in order to compel them to disclose their environmental, social, and corporate governance (ESG) practices, for most such companies in Mexico these disclosures are limited to voluntarily publishing a social responsibility or sustainability report because the Mexican government has favored self-regulation over proactively regulating the private sector. Experts interviewed by Empower point out that “social responsibility” is not the same as ESG criteria. Nevertheless, the Mexican market is already becoming attractive for ESG certifiers that also often create stock market indexes as well as financial companies that deploy investment instruments with ESG criteria. This reveals a tension between the rise of more demanding international practices and those business models that cling to self-regulation and the veneer of corporate social responsibility.

Increasingly, some of the most important public and private companies in Mexico publish sustainability reports where they can choose what to report, or not, to their investors, consumers, and other stakeholders since these are unregulated. In that sense, the challenge posed by the international trend is for companies to file public ESG disclosures with mandatory indicators defined by the State.

For eleven Mexican companies listed on U.S. stock exchanges this could happen in 2023, as three new rules proposed by the U.S. Securities and Exchange Commission (SEC) — Enhanced climate risk disclosures by issuers, Enhanced ESG disclosures by registered funds and investment advisers, and Modernized rules governing ESG-related fund names —¹“Meeting Investor Demand for High Quality ESG data,” U.S. SEC, 17 October 2022, www.sec.gov/news/speech/lizarraga-speech-meeting-investor-demand-high-quality-esg-data. seek to compel publicly-traded companies to submit ESG reports with defined criteria and indicators.

These three rules were first proposed between March and June 2022. Then, in December of last year, the comment period for the first rule closed. According to the SEC, its staff is now considering and evaluating the comments that were submitted to them by the deadline, which are available for public consultation on the Commission’s website.²“Comments for The Enhancement and Standardization of Climate-Related Disclosures for Investors,” SEC, 2022, www.sec.gov/comments/s7-10-22/s71022.htm.

If approved, the first Mexican companies that would have to prepare these disclosures are América Móvil (NYSE:AMX), CEMEX (NYSE:CX), Grupo Televisa (NYSE:TV), Coca Cola FEMSA (NYSE:KOF), Grupo Aeroportuario del Pacífico (NYSE:PAC), Grupo Simec (NYSE:SIM), and Industrias Bachoco (NYSE:IBA), all listed on the New York Stock Exchange (NYSE). APx Acquisition Corp (NASDAQ:APXIW), LatAmGrowth SPAC (NASDAQ:LATGW), LIV Capital Acquisition Corp (NASDAQ:LIVBU), and Betterware de México (NASDAQ:BWMX) — all listed on the National Association of Securities Dealers Automated Quotation (NASDAQ) — would also be required to disclose.

In Mexico, not a single company sufficiently publishes ESG disclosures in order for investors to ascertain their performance and actual impact on the communities and areas where they operate. This is because companies report only partially, according to researcher Dora Cecilia Martínez Garcés, author of “Corporate social responsibility, the role of governments, multilateral organizations and NGOs.”³“La responsabilidad social empresarial, el papel de los gobiernos, los organismos multilaterales y las ONG’s,” Facultad de Economía y Negocios, Universidad Anáhuac, March 2007, www.centroscomunitariosdeaprendizaje.org.mx/sites/default/files/la_rse_el_papel_de_los_gobiernos.pdf. In her opinion, these reports tend to highlight what companies do well and ignore other issues, such as labor rights, water usage violations, supply chain issues, and gender gaps, among others.

“If any of these issues is not considered in its entirety, I believe that simulation continues to be the prevailing criterion,” said the researcher, who also represents the Belisario Domínguez Institute of the Mexican Senate.

Martínez also pointed out that, in Mexico, companies often fill out questionnaires and submit documentation without anyone verifying whether their codes of ethics and anti-corruption policies, among others, are correctly implemented or without measuring the impact of their activities. Moreover, these companies are rewarded with social responsibility distinctions as an act of good faith or trust in their “good intentions.”

This explains why some companies, on one hand, are presumed to be responsible because they create jobs or have reforestation programs while, simultaneously, they are denounced by activists and journalists for corruption, pollution, or human rights violations.

ESG vs. Sustainability

One of the problems resulting from the regulatory disparity between Mexico and other countries is that multinational companies adapt their practices to the regions in which they operate.

“It is interesting to review how in Mexico many regulatory issues are skipped by multinational companies, while in other countries they comply, since here the authority allows it,” said Dora Cecilia Martínez.

In Mexico, ESG disclosures have not been standardized nor are they discussed in the legislature, but companies can purchase corporate social responsibility labels such as that of “Empresa Socialmente Responsable (ESR),” a seal created in the private sector to “recognize” the will and not necessarily the impact of companies regarding environmental, social, and governance matters.

“Social responsibility begins when you exceed the minimum standard set by law. No one forces you. Instead, you simply do things,” said Evodio Sánchez, director of social responsibility at the Centro Mexicano para la Filantropía, A.C. (CEMEFI), the civil society organization formed by the private sector that grants the ESR label.

In an interview with Empower, Sánchez explained that CEMEFI bases its corporate responsibility indicators on the three pillars of ESG. However, the label does not certify ESG practices because no one verifies them. Of the 150 corporate social responsibility indicators that CEMEFI uses, it is enough for companies to declare that they comply with a percentage of them in order to receive the distinction.

For Fernanda Hopenhaym, co-executive director of the non-profit organization Project on Organizing, Development, Education, and Research (PODER), the work done by CEMEFI is incomparable to that of ESG ratings agencies in terms of rigor and quality of information.

“I don’t think they are at all comparable because rating agencies are very important sources of information for institutional investors before allocating their capital. It seems to me that other types of certifications or labels granted by other organizations mainly add reputational value or may be part of a marketing strategy,” she said.

CEMEFI is an organizations that bases its business model on issuing social responsibility labels, but not ESG ratings, to companies that make an annual payment of up to 126,000 pesos⁴“Convocatoria 2022 Distintivo ESR MiPyMEs Empresas Socialmente Responsables,” CEMEFI, 2022, www.cemefi.org/esr/descargas/2022/Convocatoria_PYMES_ESR_2022.pdf; and “Convocatoria 2020 Distintivo ESR.” and submit a self-evaluation.⁵“Distintivo ESR,” CEMEFI, undated, www.cemefi.org/distintivo-esr-2. The organization currently registers over 2,400 companies of all sizes on its ESR list⁶“Empresas grandes que obtuvieron el distintivo ESR,” CEMEFI, 25 February 2022, 1library.co/document/q2n4k47r-empresas-grandes-que-obtuvieron-el-distintivo-esr.html. and the sale of labels is its main source of income, according to a source who requested anonymity.

Hopenhaym explains that social responsibility are voluntary measures taken by companies out of goodwill or of their own initiative, while ESG are standards that increasingly are requested by investors and different private sector actors, particularly in the financial sector.

“These labels are easier to obtain than a good rating from an ESG agency,” Hopenhaym said.

The main difference between corporate social responsibility and ESG criteria is that the latter considers how a company’s ESG risks are analyzed as part of a systemic business approach, “whereas many organizations still focus on sustainability through an isolated strategy and department,” explained the sustainability communications agency Expok on its website.⁷“¿Qué son los rankings ASG?,” ExpokNews, 3 January 2022, www.expoknews.com/que-son-los-rankings-asg.

In addition, ESG rankings are assigned by rating agencies that provide measures of the adaptation and resilience of companies or assets to risks and opportunities in order to help investors make better decisions, for example about how the availability of a natural resource will affect a certain company according to its industry.

In other words, an ESG rating agency prepares listings that indicate where a company or an asset ranks in a certain category. It focuses on highlighting the risk in investors’ portfolios against a matrix of environmental, social, and corporate governance factors.

According to the Mexican Stock Exchange, there are currently six rating agencies operating in Mexico: A.M. Best, Fitch Ratings, HR Ratings, Moody’s Local de México, S&P Global Ratings, and PCR Verum.⁸“Rating agencies,” Grupo BMV, 2022, www.bmv.com.mx/en/listed-issuers/rating-agencies. Of these, two rate sustainability and only half — S&P Global Ratings, A.M. Best and Moody’s Local de México — confirmed that they consider ESG factors.

CEMEFI, businesspeople who reward their businesses

CEMEFI was founded on December 7, 1988, in Mexico City with Jorge Victor Villalobos Grzybowicz as its legal representative, according to the Commission for the Promotion of the Activities of Civil Society Organizations.⁹“Buscador de OSC,” Comisión de Fomento de las Actividades de las Organizaciones de la Sociedad Civil, undated, www.sii.gob.mx/portal.

Although his name does not appear in the association’s registry, CEMEFI recognizes as its founder the businessman and honorary president of the organization Manuel Arango Arias,¹⁰“Manuel Arango Arias, evento de inauguración de #CasaCEMEFI,” Facebook, 5 April 2022, www.facebook.com/Cemefi/videos/manuel-arango-arias-evento-de-inauguraci%C3%B3n-de-casacemefi/957411921626559. co-founder of Aurrerá and Grupo Cifra,¹¹“Visita del señor Manuel Arango, cofundador de Grupo Cifra,” 28 September 2010, embamex.sre.gob.mx/guatemala/index.php?option=com_content&view=article&id=146:visita-del-senor-manuel-arango-confudador-de-grupo-cifra&catid=28:septiembre-2010&Itemid=105. which includes chains such as Walmart Mexico, VIPS, and Suburbia.¹²“Historia – Línea de tiempo,” Walmart México, undated, www.walmartmexico.com/conocenos/historia.

According to CEMEFI,¹³“CEMEFI,” CEMEFI, 2022, www.cemefi.org/cemefi. its community is comprised of more than 1,600 members who are foundations, associations, companies, and individuals, over 3,000 users of its services, and an operational team of more than 50 people.

This includes some members of Mexico’s wealthiest families who have passed through the ranks of its management team and governing bodies,¹⁴“CEMEFI,” Órganos de gobierno, CEMEFI, 2022, www.cemefi.org. such as María del Pilar Servitje de Mariscal, of the family that owns Grupo Bimbo.

CEMEFI also has associates such as Arturo Elías Ayub, director of Strategic Alliances and Content of América Móvil and son-in-law of Carlos Slim, founder of América Móvil and the richest man in Mexico, and Bárbara Garza Lagüera Gonda, president of the FEMSA (Coca-Cola) Collection Development Committee. These prominent individuals and families add up to a group of businesspeople who rate and reward their own businesses.

“One thing that made the label very successful was the origin of its founders. Manuel Arango has many relationships, especially in retail, including shares of Walmart,” said Sánchez, director of social responsibility for CEMEFI.

Walmart, for example, is one of the companies that received the ESR label as soon as CEMEFI began awarding it in 2001, despite having been accused of corruption and of allegedly facilitating money transfer scams in the U.S.

From 2012-19, the Walmart supermarket chain, which has the ESR label in Mexico, was implicated in alleged bribery cases in Mexico, Brazil, India, and China, among other countries, after paying public officials in order to speed up construction permits for its stores.¹⁵“Walmart pagará US282 millones por casos de sobornos,” El Economista, 20 June 2019, www.eleconomista.com.mx/empresas/Walmart-pagara-US282-millones-por-casos-de-sobornos-20190620-0058.html.

According to the SEC, Walmart failed to “to operate a sufficient anti-corruption compliance program for more than a decade as the retailer experienced rapid international growth” and, in 2019, it was forced to pay a 44 million USD fine to the SEC and another 138 million USD to the Department of Justice to settle the investigation into possible violations of the Foreign Corrupt Practices Act.

“The 283 million dollar settlement puts an end to the uncertainty generated by the investigation for possible FCPA violations and makes Walmart de México y Centroamérica (Walmex) more eligible as an investment candidate for funds that require compliance with so-called environmental, social and governance (ESG) factors,” according to an analysis by Casa de Bolsa Citibanamex, as quoted by Forbes México.¹⁶“Walmart Inc. Pagó 283 mdd para cerrar caso de corrupción en México,” Forbes, 24 June 2019, www.forbes.com.mx/walmart-inc-pago-283-mdd-para-cerrar-caso-de-corrupcion-en-mexico.

Furthermore, the U.S. Federal Trade Commission (FTC) sued Walmart in 2022 in federal court accusing it of allowing money transfers to fraudsters at its stores since the chain had failed to warn about the risks of fraud in this type of transaction and did not train its employees to avoid such cases.¹⁷“La FTC dice que Walmart permitió el fraude relacionado con transferencias de dinero”, FTC, 28 junio 2022, consumidor.ftc.gov/alertas-para-consumidores/2022/06/la-ftc-dice-que-walmart-permitio-el-fraude-relacionado-con-transferencias-de-dinero.

Furthermore, the U.S. Federal Trade Commission (FTC) sued Walmart in 2022 in federal court accusing it of allowing money transfers to fraudsters at its stores since the chain had failed to warn about the risks of fraud in this type of transaction and did not train its employees to avoid such cases.¹⁸“La FTC dice que Walmart permitió el fraude relacionado con transferencias de dinero,” FTC, 28 June 2022, consumidor.ftc.gov/alertas-para-consumidores/2022/06/la-ftc-dice-que-walmart-permitio-el-fraude-relacionado-con-transferencias-de-dinero.

“People call me all the time and tell me ‘such and such a company that has an ESR label has a problem.’ They tell me anything from ‘that company’s driver cut off my car on the highway’ to much more delicate things. First, let’s understand that there are 150 social responsibility indicators and, second, that no company is free of issues or problems with its stakeholders,” said CEMEFI’s Sánchez.

ESR labels: from green to pinkwashing

The principle of self-regulation is a mistaken concept, in Hopenhaym’s opinion, since no one can be both judge and jury. She also considers that the State should be the guarantor and regulator of the private sector.

“If the source of information is the company itself, there is a problem with the design of the label or rating. Whatever it is, if there is not an independent third party to make that evaluation and my primary source of information is ‘hey, company, how are you doing? Let me see your policies and everything you have on paper,’ but no one evaluates what’s actually happening, such a label is useless,” said the co-director of PODER.

In the same vein, for researcher Dora Cecilia Martínez Garcés, the most objectionable aspect of the ESR methodology is the self-evaluation and the lack of mechanisms to corroborate the information that companies provide, not to mention that it is a model whereby the company pays for the label and only 5% are rejected.¹⁹Data obtained in an interview with Evodio Sánchez, CEMEFI’s director of Social Responsibility.

Denisse Cufré, a specialist in businesses and human rights, agrees with Martínez Garcés.

“What happens with ‘certifications’ that are purely and exclusively from the private sector is that, in most cases, it is not proven that they have a positive impact both on the environment and on the community or people, and on the other hand we cannot be sure of what the companies themselves communicate,” said Cufré.

This is how practices such as greenwashing come about, which is a marketing strategy used by companies when they deceptively boast about their environmental responsibility. Or pinkwashing, which is used to promote false support with the activism of lesbian, gay, bisexual, trans, and intersex (LGBTI) people.

The case of Bimbo: sustainability backed by CEMEFI

The case of companies such as Bimbo, one of the largest bakeries in the world, is an example of the washing phenomenon. The company has maintained its ESR label from CEMEFI for 22 years, but was singled out in the 2016 report “Mexico: businesses and human rights” by over 100 civil society organizations for having the most abusive practices among foreign and national companies in Mexico.

The report documented that, throughout its value chain, Bimbo is “violating the access and exercise of human rights, such as the right to health, a healthy environment, adequate food, and access to information” by using “30 highly toxic pesticides that have been banned in other countries due to their impacts on health and the environment.”²⁰“Grupo Bimbo viola cinco derechos humanos”, Contralinea, 11 September 2016, contralinea.com.mx/opinion/grupo-bimbo-viola-cinco-derechos-humanos. Substances such as glyphosate, endrin, lindane, and DDT were detected in rivers, drains, lagoons, and the ocean off the the coast of Sinaloa where Bimbo sources manufacturing supplies.

In addition, Greenpeace Mexico has denounced Bimbo’s use of farmers and day laborers who are victims of what is known as “contract farming,” one of the most abusive forms of piecework.

Since 1998, Bimbo has published annual reports that include sustainability sections, albeit none with ESG criteria.²¹“Informes anuales,” Grupo Bimbo, 1998-2021, www.grupobimbo.com/index.php/es/inversionistas/reportes/informes-anuales. Even so, it is listed in the S&P/BMV Total Mexico ESG Index, a stock market index that contains ESG criteria. The company was contacted by phone and e-mail but did not respond to requests for comment.

ESG indexes and funds

ESG indexes list assets that report and meet ESG criteria and aim to identify those that meet specific sustainability criteria within each industry, while ESG funds refer to the concept of sustainable investing and facilitate investment decisions based on environmental, social, and governance factors.

According to Cufré, companies are finding ESG disclosures and ratings increasingly attractive because they offer prestige and trust.

“Companies are interested because it obviously increases their reputational value and this has been proven, there is more and more interest in consuming in a responsible way. So of course having a rating increases the company’s sales capacity,” says Cufré, a specialist in business and human rights. It also attracts investment.

For these reasons, investment institutions are beginning to generate more investment funds or provide financing through blue and green bonds, added the expert.

“The World Bank, the Inter-American Development Bank, and all the projects they finance have environmental, social, and economic safeguards, and even complaint mechanisms when they don’t meet the same standards as the banks,” says Cufré.

Different companies dedicated to the creation of ESG indexes and ratings are beginning to see Mexico as a potential market. For example, between 2020-21, the firm S&P Dow Jones together with the Mexican Stock Exchange designed its first three indexes that include companies with ESG commitments in Mexico.

These indexes are S&P/BMV Mexico Total ESG Index, S&P/BMV IPC ESG Tilted Index, and S&P/BMV IPC CompMx Trailing Income Equities ESG Tilted Index.

“No one certifies per se, but the ESG scores that are used in the construction of the index are obtained by a global division of S&P that rates companies on ESG criteria according to their sector and economic activity,” explained Pavel Gibrán Esquivel Vázquez, deputy director of Indexes and Statistics for the BMV.

Despite the lack of regulation, the ESG wave is already on Mexico’s horizon and, in 2022, the MSCI agency, dedicated to issuing risk ratings using ESG criteria, opened offices in the state of Nuevo León.

MSCI is not yet listed as a recognized BMV rater,²²“Rating agencies,” BMV, 2022, www.bmv.com.mx/en/listed-issuers/rating-agencies. but it is one of the leading U.S. raters of “private equity, debt, equity market indexes, hedge fund and other portfolio analysis tools” and assesses the ESG risks and opportunities of these products.

As of December 2022, MSCI was hiring specialized staff in Mexico to integrate a team to research and rate companies based on their industries’ exposure to specific ESG risks.²³“ESG Rating Associate,” LinkedIn, December 2022, www.linkedin.com/jobs/view/3380673599.

This team will have the tasks of conducting ESG research, supporting the implementation of quality control measures, contributing to the improvement of rating models, and coordinating with suppliers on ways to improve the quality of information, among others.

For two months, Empower tried to get an interview with MSCI; however, it did not respond to a request for an interview and/or comment.

CEMEFI’s director of social responsibility considers that it depends on different factors whether these types of practices should become mandatory in Mexico.

“I don’t like to answer this way, but it depends on the maturity of the country, the maturity of the industries, and the capacity of the agencies to evaluate, sanction, and so on, but I believe that companies see that moving forward in accordance with the law is no longer a path that will lead them to survive or remain competitive in the long term, because the consumer is the one in charge. I would say that the fact that a law is imposed does not necessarily mean that it will be complied with,” says Sánchez.

Unregulated corporate accountability in Mexico

Around the world there are over 400 regulations on corporate social responsibility, but none are applied in Mexico, said Luisa Montes, executive director of Ecovalores, an information agency on environmental, social, and governance issues, in an interview with Empower.

“The Mexican government’s Sustainable Finance Council, headed by the Ministry of Finance and Public Credit, has basically been analyzing the best regulations for responsible investment, not so much for socially responsible companies. In that case, the Ministry of Economy should be the one to regulate it, but there have been changes in the agency and it seems that this has not been a priority for this government,” said Montes.

In Mexico, initiatives have been discussed and sometimes approved that have to do with the environment, corruption, and labor rights that go hand in hand with ESG standards, but these are scattered efforts, according to Martínez Garcés.

“They are isolated legislative initiatives, some of them having to do with labor rights, gender issues, or the recently approved 12 vacation days. These are attempts at regulation. I think we are moving towards greater control, regulation, and oversight, towards the State as guarantor of competition and performance of companies, but it has not been considered as a whole,” said Martínez Garcés, who points out that social responsibility is still considered a philanthropic issue by companies in Mexico.

For Montes, there are several things that can be regulated, among them the information that companies disclose, as they are not required by law to publish sustainability reports.

Jorge Reyes, interim director of the School of Corporate Responsibility at Universidad Anáhuac, agrees that the challenge lies in the measurement and communication of companies, especially so that they act in a more transparent way that serves as a true exercise of accountability.

“In reality, where the legislation has been able to evolve is not towards the requirement that companies be sustainable, but, for example, in Europe where progress has been made in this sense. What is obligatory and what is required of companies is that they present information, periodic sustainability reports,” Reyes told Empower.

He refers to a proposal that was adopted by the European Commission in February 2022 on corporate sustainability due diligence,²⁴“The Global ESG Regulatory Framework toughens up,” White & Case, 15 July 2022, www.whitecase.com/insight-alert/global-esg-regulatory-framework-toughens. an important component of the European Green Pact and of a human rights strategy that will require strategic and operational changes not only for companies based in Europe but also for European companies with operations on other continents.

The ESG business

In the end, “it is good business to have sustainable practices because consumers are increasingly interested in you as a company being responsible, so why not be really responsible if we know that there is consumer interest in having a responsible company,” said Cufré.

The interest of investors and consumers opens the way for the creation and/or adaptation of companies such as MSCI, Standard & Poors, BlackRock, and Vanguard, which do business based on ESG criteria. However, each one is based on its own methodologies, which are not homologated. In the opinion of experts, it would be better to have mandatory standards to avoid discretionality in the recognition of companies that comply versus those that do not.

For example, among 140 companies currently listed on the BMV, S&P Global considers that there are only 30 that meet the requirements to be listed in the S&P/BMV Total Mexico ESG Index,²⁵“¿Qué emisoras integran el S&P/BMV Total Mexico ESG Index?,” BMV, 7 July 2022, blog.bmv.com.mx/2022/07/que-emisoras-integran-el-sp-bmv-total-mexico-esg-index. which also includes Bimbo and, again, Walmart, to name a few.

Pavel Gibrán Esquivel Vázquez, deputy director of Indexes and Statistics at the BMV, told Empower that companies cannot apply but instead are chosen by an S&P Global committee based on the criteria of a methodology, which is not public.

The methodology of this index excludes companies involved in the manufacture of weapons, including those for military use, those that extract coal or produce coal-based electricity, those that manufacture or sell tobacco products, and those that extract from oil sands.²⁶“S&P/BMV Indices Methodology,” S&P Global, October 2022, spglobal.com/spdji/en/documents/methodologies/methodology-sp-bmv-indices.pdf.

It also specifies that the ESG score of listed companies may be calculated based on data provided directly by the companies or, in their absence, on publicly available information.

Therefore, as long as there is no regulation based on ESG best practices, companies will continue to have an open door to report the information that they wish to make public, despite the growing interest and demand for more information and corporate commitments not only from investors and consumers but also from activists and affected communities.

The road ahead will be marked by how the ESG trend does or does not influence the business model of organizations that do not measure ESG practices and accept the information provided voluntarily by companies. According to the experts, the latter model does not allow one to understand the true impact of companies, something that is of increasing interest to regulators, investors, and consumers.

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1 “Meeting Investor Demand for High Quality ESG data,” U.S. SEC, 17 October 2022, www.sec.gov/news/speech/lizarraga-speech-meeting-investor-demand-high-quality-esg-data.

2 “Comments for The Enhancement and Standardization of Climate-Related Disclosures for Investors,” SEC, 2022, www.sec.gov/comments/s7-10-22/s71022.htm.

3 “La responsabilidad social empresarial, el papel de los gobiernos, los organismos multilaterales y las ONG’s,” Facultad de Economía y Negocios, Universidad Anáhuac, March 2007, www.centroscomunitariosdeaprendizaje.org.mx/sites/default/files/la_rse_el_papel_de_los_gobiernos.pdf.

4 “Convocatoria 2022 Distintivo ESR MiPyMEs Empresas Socialmente Responsables,” CEMEFI, 2022, www.cemefi.org/esr/descargas/2022/Convocatoria_PYMES_ESR_2022.pdf; and “Convocatoria 2020 Distintivo ESR.”

5 “Distintivo ESR,” CEMEFI, undated, www.cemefi.org/distintivo-esr-2.

6 “Empresas grandes que obtuvieron el distintivo ESR,” CEMEFI, 25 February 2022, 1library.co/document/q2n4k47r-empresas-grandes-que-obtuvieron-el-distintivo-esr.html.

7 “¿Qué son los rankings ASG?,” ExpokNews, 3 January 2022, www.expoknews.com/que-son-los-rankings-asg.

8 “Rating agencies,” Grupo BMV, 2022, www.bmv.com.mx/en/listed-issuers/rating-agencies.

9 “Buscador de OSC,” Comisión de Fomento de las Actividades de las Organizaciones de la Sociedad Civil, undated, www.sii.gob.mx/portal.

10 “Manuel Arango Arias, evento de inauguración de #CasaCEMEFI,” Facebook, 5 April 2022, www.facebook.com/Cemefi/videos/manuel-arango-arias-evento-de-inauguraci%C3%B3n-de-casacemefi/957411921626559.

11 “Visita del señor Manuel Arango, cofundador de Grupo Cifra,” 28 September 2010, embamex.sre.gob.mx/guatemala/index.php?option=com_content&view=article&id=146:visita-del-senor-manuel-arango-confudador-de-grupo-cifra&catid=28:septiembre-2010&Itemid=105.

12 “Historia – Línea de tiempo,” Walmart México, undated, www.walmartmexico.com/conocenos/historia.

13 “CEMEFI,” CEMEFI, 2022, www.cemefi.org/cemefi.

14 “CEMEFI,” Órganos de gobierno, CEMEFI, 2022, www.cemefi.org.

15 “Walmart pagará US282 millones por casos de sobornos,” El Economista, 20 June 2019, www.eleconomista.com.mx/empresas/Walmart-pagara-US282-millones-por-casos-de-sobornos-20190620-0058.html.

16 “Walmart Inc. Pagó 283 mdd para cerrar caso de corrupción en México,” Forbes, 24 June 2019, www.forbes.com.mx/walmart-inc-pago-283-mdd-para-cerrar-caso-de-corrupcion-en-mexico.

17 “La FTC dice que Walmart permitió el fraude relacionado con transferencias de dinero”, FTC, 28 junio 2022, consumidor.ftc.gov/alertas-para-consumidores/2022/06/la-ftc-dice-que-walmart-permitio-el-fraude-relacionado-con-transferencias-de-dinero.

18 “La FTC dice que Walmart permitió el fraude relacionado con transferencias de dinero,” FTC, 28 June 2022, consumidor.ftc.gov/alertas-para-consumidores/2022/06/la-ftc-dice-que-walmart-permitio-el-fraude-relacionado-con-transferencias-de-dinero.

19 Data obtained in an interview with Evodio Sánchez, CEMEFI’s director of Social Responsibility.

20 “Grupo Bimbo viola cinco derechos humanos”, Contralinea, 11 September 2016, contralinea.com.mx/opinion/grupo-bimbo-viola-cinco-derechos-humanos.

21 “Informes anuales,” Grupo Bimbo, 1998-2021, www.grupobimbo.com/index.php/es/inversionistas/reportes/informes-anuales.

22 “Rating agencies,” BMV, 2022, www.bmv.com.mx/en/listed-issuers/rating-agencies.

23 “ESG Rating Associate,” LinkedIn, December 2022, www.linkedin.com/jobs/view/3380673599.

24 “The Global ESG Regulatory Framework toughens up,” White & Case, 15 July 2022, www.whitecase.com/insight-alert/global-esg-regulatory-framework-toughens.

25 “¿Qué emisoras integran el S&P/BMV Total Mexico ESG Index?,” BMV, 7 July 2022, blog.bmv.com.mx/2022/07/que-emisoras-integran-el-sp-bmv-total-mexico-esg-index.

26 “S&P/BMV Indices Methodology,” S&P Global, October 2022, spglobal.com/spdji/en/documents/methodologies/methodology-sp-bmv-indices.pdf.