The Company’s Code of Ethics and Business Conduct (the “Code”), which was approved by the Audit Committees and Boards of Directors of the subsidiaries, encompasses all the principles that Grupo Peña Verde deems essential for the success of its business, since, by offering mostly intangible products, generating, conveying, and maintaining trust of its customers is paramount.
In this way, the Group grounds its daily operations on ethical principles that are aligned with the mission, vision, and values of each of its subsidiaries, thereby fostering solid relationships built on respect, integrity, and legality.
Likewise, and in accordance with the 2011 reform on human rights, all contractual documentation (including that corresponding to the settlement of claims) is prepared to fully comply with and safeguard the human and fundamental rights of policyholders, clients, employees, and all those who are related to the Group’s companies.
In this context, and to ensure that those who are part of the Group adhere to the guidelines established by the Code, all new employees are given a physical copy of the Code, which they are required to read. In this regard, in order to encourage their understanding of the Code, the Company organizes annual training workshops for employees, who are subject to a final evaluation to gauge their knowledge of the Code.
It is important to mention that, although the Code does not cover all possible situations that may arise, it provides the necessary information for the members of the Group to know how they should perform their duties. For this reason, the Compliance Area oversees the proper adherence of employees to the ethical guidelines (as well as training activities related to the Code), since failure to comply with them could result in disciplinary action, termination of the contract and even civil and/or criminal prosecution.
Employees may request the necessary advice on how to proceed in the event of a possible violation of the Code, and the Human Resource and Legal Departments are responsible for providing them all the guidance within their reach.
It is important to note that all members of the Board of Directors adhere to and have a good understanding of the Code of Ethics.
Key Principles of the Code
Respect for others
Decisions in labor matters (hiring, remuneration, promotion, among others) are made based on talent, skills, qualifications, and performance, with no regard for race, sex, skin color, religion, age, nationality, sexual orientation, gender identity, disability and any other reason that is not aligned with the values and cultural pillars that identify Grupo Peña Verde.
In this way, the Company strives to provide a
workplace free of discrimination, retaliation of any
kind or harassment, distinguished by:
Conduct in the workplace
We do not tolerate physical or verbal violence, or any kind of threats in the workplace committed by or against employees or their property.
Labor relations and working conditions
Grupo Peña Verde recognizes and respects the right of employees to associate in order to encourage collective bargaining, provided that compliance with the terms of collective bargaining agreements is upheld.
Idea assets
Given the nature of our business, it is of utmost importance to establish rules and controls that regulate access, handling, authorization of use, among others, of our tangible and intangible assets. Such regulations include:
Third-party Services Policy
In order for a third party to be considered as a potential service provider for Grupo Peña Verde, it must have integrity and good reputation, as well as read and sign the Group’s Code of Conduct and Ethics for suppliers.
In this regard, suppliers declare that they will fully comply with their labor obligations as defined by current legislation, since all contracts with third parties state that such has no labor dependance on Grupo Peña Verde.
Policies Related To Regulatory Compliance
Anti-corruption policy
Grupo Peña Verde strictly prohibits the realization, concealment and/ or promotion of any act of bribery, corruption, collusion, blackmail, and any activity that involves offering or granting any person a payment in cash or in kind, advantages, privileges, provision of services, assumption of debts or obligations, or excessive courtesies, either directly or through third parties.
Therefore, both at the Group level and in each subsidiary, the necessary measures are taken to prevent and avoid acts of corruption, under the following principles
Gifts and hospitality
It is strictly prohibited to accept bribes, kickbacks, gratuities or other exceptional payments from any organization or individual that competes with, intends to do business with, or is doing business with Grupo Peña Verde.
Donations
All donations are reviewed and approved by the Head of the Corporate Legal Department, who must ensure that donations are not made when: i) they are at the request of a government official, or ii) a government official is involved in the administration of such organizations.
Political Contributions
Under no circumstances shall direct or indirect contributions be made to political parties, movements, committees, political and labor organizations, or their representatives and candidates, except as required by applicable laws, if any.
Anti-money Laundering
Grupo Peña Verde does not promote or enable transactions with resources of illicit origin, or the financing of terrorism or any other financial crime. In this regard, we make sure that we only work with renowned clients and suppliers, whose businesses comply with the applicable legal framework and whose resources come from legitimate sources.
Other Relevant Policies
Human Rights Policy
During 2021, the Group’s Human Rights Policy was developed, approved, and released, thus providing a precise and clear framework to ensure the dignified treatment of all people related to the Company
Diversity and Inclusion Policy
In order to continue promoting equal opportunities and better decision-making, in 2021, the Company’s Diversity and Inclusion Policy was developed, approved, and released, which establishes the necessary guidelines for this purpose.
Main Measures To Prevent Conflict Of Interest
Related-Party Transactions
Any transaction between related parties must be carried out at market value and comply with the Policies for Transactions with Related Parties and Entities in force and approved by the Board of Directors.
Related parties are considered to be:
