SAGRILAFT AND PTEE PoliciesÂ
- Grupo al S.A.S. is committed to complying with all legal regulations that seek to control criminal activities, such as money laundering, terrorism financing and financing of the proliferation of mass destruction weapons.
- All directors and employees of Grupo al S.A.S. are aware of the policies established in the SAGRILAFT MANUAL â€“ SELF CONTROL SYSTEM and COMPREHENSICE RISK MANAGEMENT OF LA (Money Laundering) / FT (Terrorism Financing) / FPADM (Financing of the Proliferation of Mass Destruction Weapons) and are committed to its strict compliance in the different daily activities, considering the established functions for each position regarding SAGRILAFT.
- To enter into commercial agreements with a counterparty, (customers, suppliers, contractors, among others), the guidelines stipulated in the SAGRILAFT manual, must be strictly followed which includes duly completed and signed forms, required internal and external supports and other stipulated requirements.
- The company will not have links with natural or legal persons that are within the international binding lists for Colombia or other lists that are considered high risk activities of LA/FT/FPADM, including its employees and shareholders.
- The company undertakes to make the relevant reports to the competent authorities when suspicious operations are detected that may be related to money laundering, terrorism financing and financing of the proliferation of mass destruction weapons, following the procedures established in the SAGRILAFT Manual.
- The SAGRILAFT Manual together with the risks established therein must be reviewed and adjusted periodically to keep the system updated at all times and thus avoid being used directly or indirectly in a criminal activity related to money laundering, terrorism financing and financing of the proliferation of mass destruction weapons.
- All Grupo al S.A.S. personnel must be constantly trained in SAGRILAFT matters, to ensure that the established policies are correctly complied with and thus prevent the company, managers, and employees from being exposed to ML/FT/ATF/MFATF activities.
Business Ethics and Transparency Program (PTEE)
GRUPO AL S.A.S. is committed to comply with all national regulations governing matters related to transparency, integrity, and business ethics.
- Law 1474 de 2011 (Anti-Corruption Statute)
- External Circular 100-000003: guide to adoption of business ethics programs.
- Resolution 100-006261 of October 2nd, 2020: obligated sectors and companies.
The PTEE aims to reduce the risk of occurrence in GRUPO AL S.A.S. of an act of bribery in the framework of national and international business or transactions, through a comprehensive Transparency and Business Ethics System that regulates the responsibility related to acts of corruption, including transnational bribery.
PRINCIPLES RELATED TO THE PTEE
The Transparency and Business Ethics Program is established under the declaration of six (6) fundamental principles, which must reflect our actions at all levels and are integrated to the organizational values contained in the Code of Ethics and Conduct Manual of GRUPO AL S.A.S. Based on the above, every person linked to the company by any means is co-responsible for the proper and correct application of this Transparency and Business Ethics manual.
1.1.1 Principle of legality: all persons linked to the Company are committed to ensuring compliance with Colombian laws, as well as with the provisions and regulations issued by the authorities and the rules and policies established by the Company.
1.1.2 Principle of honesty: to the extent that all employees are aware of their responsibilities and their moral, legal, and labor obligations and practice them, it can be affirmed that they are fulfilling their duties to the community, the company and the country, and the only way to do so is to be guided by the path of an honest, transparent, and legitimate business. Those with higher hierarchical levels and responsibility for the Company’s assets and processes must be more committed to a careful conduct.
1.1.3 Principle of good faith: to act in good faith, with diligence and care, permanently ensuring respect for people and compliance with the law and giving priority in its decisions to the Company’s principles and values over private interests.
1.1.4 Principle of Loyalty: out of loyalty to the Company, every person must report in a timely manner to his or her immediate superiors any fact or irregularity committed by another employee or a third party, which affects or may harm the interests of the Company, its customers, shareholders, and directors. If the employee prefers to keep his or her identity confidential, he or she may do so through the Transparency Line.
1.1.5 Principle of general and corporate interest: all actions must always be governed by the general interest, and management at all levels must be devoid of any personal economic interest. Transparent conduct is exempt from payments or acknowledgments to obtain or retain business or gain a business benefit.
1.1.6 Principle of truthfulness: we tell and accept the truth above all other considerations. The information we provide to the public is truthful.
The Corporations Superintendence has made available the following links for complaints related to acts of transnational bribery or corruption:
â€˘â€Ż Transnational Bribery Reporting Chanel (Canal de Denuncias por Soborno Transnacional)
â€˘â€Ż Acts of Corruption Reporting Chanel (Canal de Denuncias por actos de CorrupciĂłn)
The mechanism provided by GRUPO AL S.A.S through which complaints from employees and third parties will be received is through the intranet and/or institutional mail:â€Żtransparenciayetica@grupoal.com.coâ€Ż and/or the website, by filling out the following form.