At BIA we have developed this Anti-corruption policy in order to provide the Board of Directors, Senior Management, partners, business associates and third parties with an official document that outlines our commitment fighting corruption.
This policy is a crucial component of our Compliance Program, which seeks to ensure that everyone can fulfill their job responsibilities without legal, financial and reputational risk.
This policy aims to define the limits within which our partners, Senior Management and Board members, as well as business associates and third parties, must act in order to protect the organization and its employees.
The policy includes, but is not limited to, these specific objectives:
Ethical culture and awareness:
Zero tolerance to corruption:
Board members and Senior Management’s commitment and leadership:
Hospitality and donations:
Any type of donation (either in money or in kind) has to be approved by Corporate Affairs and Compliance through the Compliance site.
Donations to Entities or Public Officials:
Donations to Private Entities (Cooperatives, Nonprofit Associations, etc.):
Hospitality and courtesies:
Financial inputs to political groups:
Gifts and other considerations:
Partners can’t accept gifts, dinner invitations, trips or any type of care from our clients and prospects, suppliers, public officials or any third party who could compromise the capacity to take objective commercial decisions.
The rules to accept gifts are:
TPVs (Touch Point Vendors):
Hiring former public officials:
A system of internal controls is required, where the transactions can be reflected and reported appropriately, precisely and with reasonable details on the accounting books and records of the company.
The finance area will identify within its chart of accounts the “sensitive” or “Compliance Sensitive Transactions” or “CST”, having to continuously monitor those accounts.
The contractors shall comply the accountability provisions, books, records and provisions of internal control covered by the Applicable Anti-corruption Laws.
The access to the Ethical Line is by telephone numbers open for each of the countries in which we operate, e-mail and web site, as described in the Ethics Code.
Those who report any misconduct, and those who participate on the research, are protected from reprisals. The company prohibits and punishes any type of reprisal against complainants or partners of the investigation procedure, even with dismissal. The disciplinary sanction will be based on the Ethics Code, Employment Contract, Internal Labor Regulations and Rules on Disciplinary Sanctions.
Roles and Responsibilities:
The Board of Directors is committed to promoting a preventative culture against corruption at strategic and operational levels.
Senior Management will implement control measures to ensure prevention process and corruption risk mitigation, and there will be regular reviews to determine if possible risk has emerged.
The Compliance Department, with Legal Management’s support, is responsible of developing and tracking the Anti-bribery Management System and ensuring the effectiveness of the Compliance Program. It is also responsible of the research, track, administration and actualization of the incidents reported on the Ethics Line until the end of the researched cases, and will inform the Ethics Committee promptly.
The Management Department will assist on the outreach and awareness of this policy to all partners.
The Internal Audit Department is responsible of assessing the effectiveness and fulfillment of this Anti-corruption Policy.
Each partner is responsible of applying the criteria stablished on the policies and procedures, and will have to act in line with the corporate values and guidelines established in the Ethics Code.
a. Financial risks:
b. Operational risks:
c. Compliance risks:
d. Risk on reputation:
e. Risk of corruption:
Any breach of this policy and its related procedures will be subject to disciplinary measures that have to be applied to the employees who have committed the offense directly or by default.
The sanctions will depend on the magnitude of the offense and will be governed by each country’s laws and the internal work regulations.
from our CEO