BUSINESS AND TRANSPARENCY ETHICS PROGRAM POLICY PTEE
CHECOREPUESTOS S.A.S Nit. 830058959-9 adopts a Business Transparency and Ethics Program as good business practices, implementing transparent processes that generate a culture of prevention and legality in each of the activities we carry out, for this reason, in compliance and adoption of national laws, regulations, good practices and in accordance with international agreements approved by the Congress of the Republic of Colombia, this policy is adopted and implemented, in order to avoid, detect, investigate and remedy any form of misconduct in any activity carried out by the company; This Policy publicly establishes the commitment of the company and senior management to ethical, transparent and honest conduct, as well as to guide business in a responsible manner and comply with the laws.
Likewise, employees and counterparties contractually bound to CHECOREPUESTOS S.A.S. must comply without exception with the control, supervision, and reporting measures for any activity or event related to corruption or transnational bribery in the performance of their duties. Actions will also be taken when any of these activities violate the provisions of the PTEE.
We are committed to providing the financial, human, and technological resources required by the company and the Compliance Officer for the proper conduct of their activities.
Therefore, CHECOREPUESTOS S.A.S. issues the following guidelines that have been implemented within the PTEE Business Transparency and Ethics Program:
1. The company will focus its efforts on managing the risks of transnational corruption and bribery.
2. The company promotes and establishes within its organization a corporate culture of zero tolerance for corruption and transnational bribery among all its counterparties.
3. The company establishes requirements for the engagement of counterparties and rejects the establishment or renewal of a contractual relationship that does not meet the requirements established by law and the company's internal regulations.
4. All company employees must immediately report to the Compliance Officer any transactions that pose a risk of corruption and transnational bribery that they identify, in connection with their position, role, or function.
5. The company monitors the operations of individuals or legal entities, both domestic and foreign, that may expose the company to greater risk of money laundering (ML/FTA/FPADM), including Politically Exposed Persons (PEPs).
6. The company has guidelines for identifying, measuring, controlling and monitoring risk factors and associated risks.
7. The company will implement due diligence and enhanced due diligence procedures, in accordance with the risk level of its counterparties.
8. The company will rely on public sources and open information to understand its counterparties, making the best use of the information in accordance with the Statutory Habeas Data Law (Law 1581 of 2012).
9. Documents and records relating to compliance with the regulations on prevention and control of the risks of transnational corruption and bribery must be kept for a period of no less than ten (10) years, in accordance with the provisions of Article 28 of Law 962 of 2005.
10. CHECOREPUESTOS S.A.S. employees assume the commitment and responsibility to promptly respond to requests made by the Compliance Officer in the exercise of their duties within the framework of the PTEE.
11. El manual del PTEE se enfocará en evaluar continuamente los riesgos específicos de la organización. Esto se hace mediante una matriz de riesgos, que permitirán identificar, evaluar y controlar posibles riesgos de corrupción.
12. The company will define clear responsibilities and procedures to maintain integrity and ethics with its counterparties.
13. The company will study and consider financial and accounting aspects to identify corruption risks in the company's financial system.
14. It will facilitate effective channels for reporting and internal communication. This will allow for the detection and addressing of potential irregularities.
15. It will provide information channels to train employees and stakeholders on the PTEE and the importance of business ethics.
We are committed to disclosing the provisions of this policy to our employees, business partners, and other stakeholders as applicable.
Signed in Funza, Cundinamarca, on the 15th day of June 2024,
Legal Representative
Code: A-PO-0001
Version: 0.0
Effective Date: 01/08/2024