Transparency and Business Ethics Policy
AVSA S.A. and their controlled companies are committed to promote a culture of transparency and integrity, establishing practices that lead to the management of risks related to Corruption and Transactional Bribery, complying with the rules that regulate it.
ETHICAL PRINCIPLES AND VALUES
The transparency and business ethical program is established under the statement of the following principles and values:
ETHICAL PRINCIPLES:
1. Ethical principles of our people
- We act honestly and are consistent between what we think, feel, say and do.
- We provide dignified and equal treatment to people and value their differences.
- We generate credibility by acting with transparency and speaking truthfully.
- We act with commitment and response for the consequences of our actions.
2. Common ethical principles between the organization and our people
- We join efforts and talents to achieve common aims.
- We listen to everyone carefully and share information, ideas and thoughts.
- We are open to transformation, and we are always searching for new ways to do things better.
- We learn with humility from our success and failures and seek our integral development.
3. Ethical principles of our organization
- We orient our organization to customers because they are our reason for being.
- We do things right from the beginning and forever.
ETHICAL VALUES
1. Values of our people:
- Integrity.
- Respect.
- Trust.
- Responsibility.
2. Common values between the organization and our people:
- Teamwork.
- Communication.
- Innovation.
- Learning.
3. Values of our organization:
- Service-oriented attitude.
- Quality.
COMPLIANCE POLICIES
AVSA S.A. and its controlled companies established the following compliance policies:
1. Transparency and business ethics policy.
AVSA S.A. and its controlled companies are committed to the prevention of risks associated with Corruption and Transnational Bribery in relation to the operations and businesses they carry out, based on socially responsible principles, guidelines and objectives. To fulfill this purpose, the company develops the following activities:
- Structure, execute, and supervise actions aimed at managing risks related to Corruption and Transnational Bribery, through periodic risk assessment.
- Clearly communicate the Compliance Policies and the Transparency and Business Ethics Program; to facilitate the understanding of employees and other third parties related to the company, raise awareness of the risks of Corruption and Transnational Bribery to which the company is exposed and promote a culture of transparency and integrity.
- Adopt strategies to promote compliance with the Transparency and Business Ethics Program and the associated Policies.
- Implement internal reporting channels that allow anyone to report, confidentially and securely, about breaches of the Company’s PTEE and possible suspicious activities related to Corruption and Transnational Bribery C/ST.
- Collaborate, in accordance with current legislation, with the authorities in the provision of the information necessary to investigate and combat organized crime, helping informally in the fight against corruption and bribery.
Corruption and transnational bribery are unacceptable in AVSA S.A. and its controlled companies.
2. Expenses on gifts, benefits, lodging, travel and entertainment to third parties.
No gifts or benefits shall be given or offered to third parties, nor shall expenses be incurred for entertainment, food, lodging or travel to third parties, whose purpose is to influence an illegal practice.
3. Expenses on gifts, benefits, lodging, food, travel and entertainment for employees.
Expenditures on gifts, benefits, lodging, food, travel and entertainment are directly linked to the fulfillment of institutional objectives and are made with criteria of reasonableness and transparency, ensuring the efficient use of resources.
4. Political contributions.
Contributions may be made to political parties, political campaigns and/or candidates, if the regulations are complied with, and illegal practices are prevented.
5. Donations.
Donations may be made through the delivery of resources and/or goods, to institutions or individuals, to provide a benefit to vulnerable groups as part of their social work.
6. Payments to contractors and suppliers
Payments may be made to contractors and suppliers, in accordance with the negotiations previously established with them.
7. Payment to associates.
Payments may be made to associates in accordance with the concepts authorized by the General Meeting of Shareholders.
8. Remuneration to employees.
The payment of remuneration to its employees is made in a punctual, fair manner, in conditions of equity and transparency, giving accomplishment to the legal provisions in force.
Remuneration includes the agreed monthly basis, as well as any other salary and non-salary concept, such as bonuses, incentives, overtime, commissions or additional benefits, as applicable. Payment is made monthly by bank deposit. Any modification in the remuneration conditions is informed to the worker in a timely manner, and it is in accordance with the provisions of the applicable labor regulations.
9. Handling of archiving and preservation of documents related to international business or transactions.
The regulations regarding the filing and conservation of documents of their business or international transactions are complied with.
COMPLIANCE OFFICER
Person in charge of promoting, developing and ensuring compliance with the Transparency and Business Ethics Program and who was appointed by the Board of Directors.
COMMUNICATION CHANNEL
1. Whistleblower protection policy.
Within the framework of the Transparency and Business Ethics Policy regarding the prevention of risks associated with Corruption and Transnational Bribery, AVSA S.A. and its controlled companies reaffirm their commitment to the protection of whistleblowers, as well as the confidential management of their identity and all the information provided, for which the Compliance Officer is the only one authorized to receive complaints.
The company prohibits any act of retaliation, discrimination, intimidation, or adverse action against those who report.
For this reason, it will act diligently to prevent and punish any form of retaliation.
2. Ethical line.
Any complaint related to possible breaches of the company’s policies and the Transparency and Business Ethics Program or possible acts of Corruption and/or Transnational Bribery, you can communicate confidentially through the email oficialdecumplimiento@avidesadeoccidente.com.
3. Likewise, all our counterparties may use the reporting channels provided by the Superintendence of Companies for the reporting of complaints, as follows: