Compliance, ethics and transparency

Our company has a clear philosophy and corporate ethics that are constantly evolving.

Honest corporate management and compliance are the foundation of our business. We strive to build our processes in such a way that they are as transparent as possible for our partners and clients.

We have introduced a new management model, in which we improved the mechanisms for developing metrics and reporting systems. This was done in order to make our processes more open and the results of these processes measurable.

The introduction of a new model led to the need to revise the company’s organizational structure and decision-making process. Due to some changes, we have combined some areas of management, centralized management and approved new selection criteria for managers and top managers.

The measures taken will help ensure that our company becomes as open and transparent as possible for our customers.

Internal and external control mechanisms

Management and compliance Our company follows ensuring that all the processes of our enterprises comply with corporate ethics, paying special attention to compliance with internal and external standards and standards. To monitor compliance in 2016, the “Management and Compliance Council” was established, which consists of the Executive Management Department and the Legal Compliance Department.

The Executive Management and Compliance Council is responsible for implementing and complying with standards, principles and management procedures, as well as for management coordination and internal controls, including work in the field of fraud and corruption. The board constantly monitors complaints and processes feedback to identify business process violations and take steps to prevent them in the future.

The Fraud Prevention Program (EPCP) XXXXXXXXXXXXXXXXXXEPPCP is our corporate compliance program.

It is a set of measures designed and integrated to identify, correct and prevent, cases of deviations from corporate ethics, including fraud, corruption and money laundering.

The program is designed for all participants of our management and business processes, including senior management, employees, and customers, suppliers, investors, partners, sponsored organizations, government agencies and all those who cooperate with us directly, or represent our interests in various fields.

The program Ma consists of three pillars aimed at the continuous improvement of corporate ethics, integrity and transparency of processes in all of our enterprises:

1. Prevention. Aims to identify, assess and reduce the risk of deviations from corporate ethics;
2. Detection. It includes mechanisms that can promptly detect and prevent possible deviations from corporate ethics that could be prevented;
3. Setting fines or other penalties applied to each incident of proven deviation from corporate ethics. This eliminates the vulnerability that led to the corresponding deviation, and prevent possible repetitions of the incident in the future.

The program is an integral part of our company’s corporate ethics code, behavior guidelines, compliance with corporate rules and regulations and other internal instructions. Knowing and adhering to these instructions helps everyone to take part in strengthening the regulatory framework of the company, as well as in preventing fraud, corruption and money laundering.

Compliance policy

Compliance policy is a high-level strategic management guide designed to formalize corporate positioning in relation to stakeholders strengthening the fundamental aspects of business continuity and promoting the alignment of macro-processes with a common mission, vision and foundation The direction of the company.

Policies describe in detail such topics as:

1. Conflict of interest;
2. Family conflicts;
3. Receiving gifts;
4. Money laundering and financing of terrorism.

Improved security in making decisions and in nominations

Compliance assessment

In order to assist the company’s management in making decisions, we conducted a preliminary analysis of some of the issues facing top management. This assessment includes aspects related to compliance with internal policies, principles of governance and regulation, as well as the application of legislation to prevent and identify possible non-compliance with corporate ethics.

Improved security in appointments.

Data Integrity Check (BIC) is another important decision support mechanism that targets which is to improve the quality of candidates appointed to senior positions, without prejudice to meritocracy, through a process of analyzing candidates’ integrity.