We are committed to acting with integrity in everything that we do. This includes acting ethically and respecting all laws and regulations that apply to the Company (“Global Anti-Corruption Laws”). We demand this commitment not only from our employees, directors and board members, but also from our consultants, agents, representatives and other firms and individuals that act on our behalf (“Representatives”). Our reputation for integrity and excellence requires observance of the highest standards of conduct. These values guide every aspect of our behavior, particularly when it comes to promoting and protecting the Company’s interests. We believe that trust and credibility are essential to foster better relations between colleagues, clients, suppliers and the overall community.
In line with the recommendation set by the Integrity Program, published by the Ministry of Transparency and Comptroller General of the Union (CGU), and in compliance with Global Anti-Corruption Laws, we have a Compliance Program (“Program”) based on five pillars:
The compliance area must help top management to effectively address compliance risks through:
- Updates and recommendations
- Compliance manuals for certain laws and regulations
- Identification and assessment of compliance risks, including for new activities
- Statutory responsibilities in regards to fighting corruption and money laundering, as well as relations with regulators
- Implementation of compliance program