TO ALL OUR CUSTOMERS AND SUPPLIERS
MANAGEMENT POLICY FOR THE PREVENTION AND CONTROL OF ML/FT/ FPWMD RISK, CORRUPTION AND TRANSNATIONAL BRIBERY.
COLORQUIMICA S.A.S., a Colombian company supervised by the Superintendence of Corporations’ current regulations, has designed and implemented a SYSTEM OF SELF-CONTROL AND INTEGRAL RISK MANAGEMENT FOR MONEY LAUNDERING, FINANCING OF TERRORISM, FINANCING FOR THE PROLIFERATION OF WEAPONS OF MASS DESTRUCTION (ML/FT/FPWMD), and a TRANSPARENCY AND BUSINESS ETHICS PROGRAM that helps the company to fight against these scourges, to achieve strategic objectives and provides the administration with reasonable assurance regarding their accomplishment.
The main objective of this policy is to establish the guidelines to prevent and control the risks of ML/FT/FPWMD and transnational corruption to minimize the possibility that, through the different activities carried out by the company in the development of its operations, resources from those crimes are introduced, used as an instrument for the concealment, management, investment or utilization of any form of money and other assets from illegal activities and that are committed crimes of corruption and crimes that violate transparency, ethics, and/or public morality.
Within the framework of this management, we inform that COLORQUIMICA S.A.S.:
- Is committed against illegal activities; therefore, it will strictly comply with all applicable regulations.
- Will promote an open rejection of any internal criminal activity or conduct involving ML/FT/FPWMD or corruption activities.
- Declares that compliance with commercial goals is subject to compliance with ML/FT/FPWMD prevention and control regulations and those related to transparency and business ethics.
- Will adjust all its operations, businesses, and contracts to the policies and procedures outlined in its manuals and other internal regulations that regulate the sources of ML/FT/FPWMD risk and those of transparency and business ethics; otherwise, they will not be processed.
- Will define and comply with an engagement process with individuals or companies interested in commercial transactions with COLORQUIMICA by filling out a form and delivering supporting documentation subject to verification and confirmation, also information will be requested to identify the final beneficiary of the traded goods and services. Additionally, according to their risk profile during the engagement and the relevant transactions they carry out, the corresponding analyses will be carried out to establish consistency with their economic activity and the other information provided. (Due diligence).
- Will develop unique engagement and follow-up processes in case of having third parties that, due to the nature of their activities, may expose it to a greater risk of ML/TF/FPWMD and/or corruption. (Intensified diligence).
- Will not establish contractual relations with clients, employees, suppliers, or third parties registered in Colombia’s binding lists. On the other hand, the coincidence with other lists or negative information of a public nature related to ML/FT/FPWMD and/or corruption will be considered an important criterion to deny or terminate a contractual relationship. (Verification of lists).
- Will only disclose information collected from its counterparts as a consequence of the requests formulated in writing and specifically by the competent authorities, with the fulfilment of the requirements and completion of the legal forms, in the cases indicated by the regulations.
This Policy is mandatory, as are all related procedures, and applies to all personnel working in the company, shareholders, customers, suppliers, and other third parties linked to the company.
- If you are aware of actions that may lead to fraud, money laundering, financing of terrorism, drug trafficking, corruption, bribery, or any other behavior that is contrary to the law, you can use our ethics line for your report, providing all of the available information and with the guarantee of confidentiality and anonymity of your identity: [email protected]
- The local entity: Superintendence of Corporations, has established the following channel for complaints of transnational bribery: Transnational Bribery Complaint Channel (supersociedades.gov.co)..
- The Transparency Secretariat has set up the following channel for corruption complaints: (Reporting Form).