Compliance and corruption
Money laundering and terrorist financing::Any activity or suspicion that may be linked to counterparty funds being obtained from illegal sources or channeled through complex money laundering structures to conceal their illicit origin. This includes the detection of any indication that the Company's resources could be used to finance, directly or indirectly, terrorist activities, which represents a serious threat to global security.
Conflict of Interest ::Conflict of interest refers to when an employee participates or has an interest (whether actual, potential or apparent) in an activity or relationship that benefits him/her and not the Company, such as when the personal gains of each party conflict with each other.
Non-compliance with the Anti-Corruption Policy / Acts of Corruption::Carrying out, concealing or promoting acts of bribery, corruption, collusion, bribery or in general any activity that implies, but not limited to, offering or granting a payment in money or in kind, advantages, privileges, loan of services, assumption of debts or obligations or excessive attentions, directly or through third parties a) to a national or foreign public official, b) to any entity that manages public resources and has powers of authority over private parties, c) to a private company or official thereof, or d) to any person, knowing that all or part of the resources or item of value will be offered, delivered or promised, directly or indirectly, to any government official or private entity, for the purpose of avoiding compliance with a legal, administrative or judicial provision, any code of conduct, statement of ethical principles of any company or any other analogous or complementary provision.
Acts of Corruption::Carrying out, concealing or promoting acts of bribery, corruption, collusion, bribery or in general any activity that implies, but not limited to, offering or granting a payment in money or in kind, advantages, privileges, loan of services, assumption of debts or obligations or excessive attentions, directly or through third parties a) to a national or foreign public official, b) to any entity that manages public resources and has powers of authority over private parties, c) to a private company or official thereof, or d) to any person, knowing that all or part of the resources or item of value will be offered, delivered or promised, directly or indirectly, to any government official or private entity, for the purpose of avoiding compliance with a legal, administrative or judicial provision, any code of conduct, statement of ethical principles of any company or any other analogous or complementary provision.
Receiving gifts, courtesies and hospitality in exchange for an unethical action or against the Company's values and principles.::The act of receiving "something of value" in order to obtain benefits, secure an advantage or undue influence in a business decision or relationship.
Inappropriate or fraudulent donations, sponsorships and contributions::Supporting or providing donations to beneficiaries where the use of the resources is not the original intention.
Inadequate commercial practices, breach of agreements or commitments to the detriment of third parties.::Any conduct, act, process, action or omission capable of causing damage, confusion or harm to the Company's customers, suppliers, competitors, products, services or the market in general.
Non-compliance with the Compliance Policy::Non-compliance and violations of applicable national and international laws, regulations and standards and/or the Company's internal policies.
Non-compliance with the Integral Policy::Non-compliance and violations of applicable national and international laws, regulations and standards and/or the Company's internal policies.
Lack of ethics or integrity in any of the Company's operating processes.::Any lack of ethics or integrity in the processes carried out in the Company that may harm third parties, negatively affecting the Company's reputation.
Fraud / whether planned individually or in collusion with a third party.::The act or intent to deceive, steal, take advantage of error, abuse and misappropriate any property or funds of either the Company or another person to obtain unfair or illegal advantages and benefits.
