Ethics is our core value: acting correctly and in good faith, being coherent in in what you think, say and do and favoring common good over personal interests; these attitudes translate into good results that, in turn, contributed to the sustainability of our Company and the society. In this regard, we have implemented tools to promote it, assess its fulfillment and take pertinent actions in case of non compliance therewith.
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Declaration of Ethical Behavior
The Declaration of Ethical Behavior was defined by our workers in 2006, being a moral orientation tool, aimed at building an action framework for labor, personal and institutional relations; it is intended to reaffirm a trust, transparency, responsibility and justice basis in relations of workers, workers with Company, and both parties with stakeholders.
The most recent review was in 2016 and it was presented to our Management Committee, Audit Committee and Board of Directors and then adopted by the Company as our ethics code.
Anti-bribery, Anti-corruption and Anti-fraud Policy
The Anti-bribery, Anti-corruption and Anti-fraud Policy (AAA Policy) gathers declarations, practices, and indicators adopted by our Company at regulatory, statutory and good governance levels, with the intent of promoting prevention and detection of potential fraud or corruption situations, and efficient treatment thereof, protecting ethics as a core value for the Company and its workers. All of the foregoing to have an identifiable regulatory body for its management and provisions of further transparency in its actions. It establishes corporate guidelines for identification, prevention, protection and management of fraud or corruption risk.
Besides we have an Application Guide for the Anti-bribery, Anti-corruption and Anti-fraud Policy for third parties, in which are elements of orientation, action and report that must be considered by third parties to whom the AAA Policy applies.
Manual for the prevention and control of assets laundering and terrorist financing risk
ISAGEN S.A E.S.P. has a manual for the prevention and control of assets laundering and terrorist financing risk, which includes the guidelines established by Financial Superintendence of Colombia in their Legal Basic Circular 029/2014, for those who are issuers of securities, such as is ISAGEN S.A. E.S.P. Through these guidelines, it seeks to protect the company and their investors of assets laundering (AL) and terrorist financing (TF) risks and its source crimes, in order to identify and mitigate the materialization of AL/TF risk on legal, reputational, operational or contagion risk.
Transparency and Access to Information Law
We promote transparency as an explicit commitment of our Management Model and we comply with Law 1712 of 2014, which regulates the right of accessing public information, procedures for exercising and guaranteeing such right, and information advertising exceptions, which is applicable to corporate information directly related to the public utility service we provide.
Pursuant to the guidelines of this Law and our good governance in-house policies, we provide information to complying with the law.
It's a mechanism consisting of an email address, a telephone hotline and a fax line, which we have made available to employees and the general public so that they can report irregularities or acts committed by employees or third parties that affect or may affect the interests of the Company or its stakeholders; all under the principles of service, investigation, justice, confidentiality, performance, backing, support, non-reward and respect. These concerns can be submitted anonymously, if preferred.
Described below are some types of cases or events that may be reported through the Ethics Channel:
- False reports
- Fraud or theft
- Misappropriation of assets
- Conflicts of interest
- Manipulation of financial statements
- Money laundering
- Disclosure of confidential information
- Technological abuse
- Breach of laws or regulations
- Environmental impact
- Corporate image impact
- Breach of free competition
- Work harassment
- Sexual harassment
- Human Rights
To report your concerns, you may contact:
- | 01 8000 41 00 27
- | +57 (4) 361 53 20
- | firstname.lastname@example.org
Conflicts of Interest mailbox
We have an internal management tool where employees must report any situation, activity or potential risk related to the Anti-bribery, Anti-corruption and Anti-fraud Policy, and its application guide. Particularly, those issues related to fraud and conflict of interest. Besides, we have the mailbox email@example.com for our third parties.
The members of the Board of Directors and Board Committees, the Chief Executive Officer and the employees must act with diligence and loyalty towards the Company within the framework of values, principles, practices and declarations framed within the Good Governance Code, and must abstain from getting directly or indirectly involved in the decisions and/or conducts on which a conflict of interest exists or could exist.
Similarly, they are aware of the juridical nature of the Company, its equity composition and the conformation of the Board of Directors, and propose additional challenges relative to the identification and dissemination of potential conflicts of interest. The Administration will disclose every year the conflicts of interest declared by the members of the Board of Directors in the Corporate Governance report.
It is appointed by the Board of Directors and conformed by at least three of its members; if possible, all its independent members must be part of it. The President of the Audit Committee must be one of the Board of Directors independent members.
This Committee supports the Board of Directors in the analysis of aspects related to:
- Assessment of financial results and accounting policies
- Business Control System
- Corporate Audit Activities
- External Control Bodies
- Corporate risk management and business continuity
- Assessment of Good Corporate Governance Practices
- Business ethics
- Prevention of money laundering
- Other matters assigned by the Board of Directors or provided for by law
Check here the responsibilities and powers of the Audit Committee.
It advises and guides the Company on issues related to potential cases of breach of ethics, fraud or corruption.
It addresses the following topics:
- Ethics as a core value
- Business Ethics System
- Declaration of Business Behaviors (DBB)
- Fraud and Corruption Management Policy
- Human Rights
Human Rights The Committee is comprised by:
- Administrative Manager
- Corporate Auditor
- Judicial Director
- External independent member appointed by the Board of Directors
These are all policies, practices, provisions, declarations, definition of responsibilities, mechanisms and measures set out by the Company to manage and protect ethics as our core value.
These are all actions undertaken as a Company to convey, share, disseminate and promote our transparency practices and ethics management among our stakeholders. This is aimed at creating dialogue opportunities, transcending on engagement.
The companies have the mandate of implementing effective systems to promote ethics, transparency and fight against corruption, in order to involve stakeholders and enabling collective actions that help protect social climate against corrupt practices.
Collective action of the colombian electric energy sector
Accompanied by the UN Drug and Crime Office, the Transparency Secretariat of the Presidency of Colombia and the Fundación Transparencia por Colombia, the electric energy sector companies signed a collective agreement aimed at incorporating transparency and ethics good practices, which promotes healthy competition, trust and sustainability of the companies involved, all of which is summarized in five principles, some of which we have already implemented and others on which we are working internally:
- Progress in development and implementation of a comprehensive anti-corruption program.
- Continue promoting competition in the electric energy sector, relying on good corporate governance indicators for prevention of free competition restrictions.
- Build and disseminate in each company a map of corruption risks, competition restrictive practices, and money laundering and terrorist financing.
- Supply useful information to promote transparency in the sector and the energy market.
- Disseminate this agreement in each company, with their Board of Directors and various industry stakeholders.