Policy for the Whistleblower System

Purpose: These policies govern the process of reporting and investigating allegations of financial or fraudulent misconduct in general, faults to the Code of Ethics and procedures for investigating such complaints. Complaints can be made directly or anonymously following the whistleblower system that will be described later.

Scope:  As an example, the behaviors that can generate investigation are detailed below: 

  1. Misappropriation (robbery or theft) for own benefit of money or property under their responsibility or that of a collaborator, including the misapplication of funds, mishandling of cash and accounting and billing errors.
  2. Falsification of contracts, reports or records (including alterations, confections or falsifications of all or any part of a document, contract or record).
  3. Inappropriate activity with suppliers or contractors (including inappropriate negotiations or illegal activities with respect to receiving prize payments for preference of suppliers or contractors).
  4. Any other illegal or irregular use of the properties or assets of the Group.
  5. Pay bribes or give anything of value to a government official directly or indirectly for the purpose of securing an inappropriate advantage, except for donations or gifts that have been previously consulted and expressly approved by the Administration.
  6. Receive or collect in a personal capacity benefits arising from the relationship with Group customers referred to third parties.
  7. Any type of situation that generates illegality or infractions to the norms established in the Code of Ethics of the Group, mainly the following:
    1. No type of harassment is allowed in the workplace; psychological, verbal, sexual or any other kind of harassment coming from any person who works or not in the organization, towards another collaborator, client, supplier, visitor or anyone who is in the facilities of the Group or who does business with it.
    2. Partners, lawyers, executives or collaborators provide their personal services in private to suppliers, customers or competitors, except situations previously consulted and approved by the Board of Directors

Procedure for Reporting Complaints:

  1. To report your complaints you can choose the following modalities:
  1. Directly to the Vice Presidency of Audit, who will follow the detailed procedures later. Internal Audit will make sure to protect the anonymity of the collaborators who in good faith have filed any complaint, and will also ensure the V.P. of Audit that they are not sanctioned, suspended, threatened or discriminated when presenting in good faith the accusations in accordance with this policy.
  2. To your immediate supervisor. In such cases, the supervisor should immediately report the matter to V.P. audit.
  3. The complaints can be directly or anonymously through the email ‘denuncias@conductaetica.com’. Only V.P. of Audit will be enabled to access this address to receive the complaints that have been made.
  4. Through the intranet in the section entitled to file the complaint
  1. Suppliers and people outside the Organization with suspicions or doubts can make their complaints directly to the address ‘denuncias@conductaetica.com’ or through the website morimor.com where they can make the report in the field enabled.

Only V.P. of Audit will be enabled to access this address to receive the complaints that have been made, who will follow the procedures detailed below. Internal Audit will ensure to protect the anonymity of those who have filed any complaint, the providers will not be sanctioned, threatened or discriminated against for having filed a complaint in good faith according to this policy.

 

Complaint Form