SAGRILAFT and Business Ethics

We are committed to the prevention of money laundering, financing of terrorism, FPWMD, bribery and corruption.

We are committed to the prevention of money laundering, bribery and corruption.

Dear all,

In conformity with the provisions of the Basic Judiciary Circular Letter of the Superintendence of Societies in Chapter X – “Integral ML/FT/WMD Self-Monitoring and Risk Management and Suspicious Operations Report to the FIAU,” modified by External Circular Letters 100-000016 of 2020, and 100-000004 of 2021, and Chapter XXIII – “Instructions and administrative recommendations aimed to start Transparency and Business Ethics Programs through self-monitoring and management of the corruption risks and transnational bribery risks,” modified by External Circular Letter 100-000011 of 2021, for KPMG S.A.S. and KPMG Advisory, Tax & Legal S.A.S., hereon “KPMG,” it is imperative to divulge and communicate to its clients, providers, third parties, collaborators and partners the implementation of the System of Self-Control and Management of the Comprehensive Risk of Money Laundering, Financing of Terrorism, and Financing of Proliferation of Weapons of Mass Destruction – SAGRILAFT as well as the adoption of the Transparency and Business Ethics Program (PTEE), in compliance with Colombian bylaws, our code of conduct, and the risk policies that allow us to with integrity in the development of our corporate purpose.

The policies, procedures, and controls implemented by KPMG are used in order to prevent risks associated with Money Laundering, Financing of Terrorism, and Financing of Proliferation of Weapons of Mass Destruction (ML/FT/FPWMD) and its source crimes, as well as the prevention of crimes associated with corruption and transnational bribery (C/TB).

The following are the most significant aspects that are part of our policies:

Money Laundering, Financing of Terrorism, and Financing of Proliferation of Weapons of Mass Destruction Integral Self-Monitoring and Risk Management System – SAGRILAFT

Identification, evaluation, control, and monitoring of ML/FT/FPWMD risks. Implementation and evaluation of controls associated with ML/FT/FPWMD. Due diligence processes and counterpart knowledge. Declaration of source of funds and resources. Report of information to the relevant authorities (FIAU, Prosecutor’s Office, Superintendence of Societies, among others). Divulgation of information and training to the counterparts. Reporting channels (Compliance Officer functional account, RCC inbox, and Hot Line).

Transparency and Business Ethics programs through corruption and transnational bribery self-monitoring and risks management activities.

KPMG considers that when acting with a strategic ally or when offers its services in its own name or through a third party, the following policies are appliable to both the Firm and the third party that has to establish a relationship with KPMG clients, whether public or private:

The Firm strictly prohibits any act of corruption or bribery in any form, directly or indirectly, or through or in relation with its collaborators, clients, providers, and third parties, even if such behavior is legal or it is permitted by the appliable legislation or local practices.
KPMG and its personnel must not (whether directly or through and intermediary [1]) offer or accept incentives (including gifts or entertainment) with the intention of improperly influencing in the behavior of the receptor or other individual, or that results in a violation of the appliable laws.
It is not permitted for KPMG personnel, directly or through a third party, to promise or offer gifts, food, entertainment, travels, charity donations, sponsorships, political contributions, or other valuable objects to a Public Servant or from regulatory entities with the intention of improperly influencing any act of decision of said person, to induce said person to violate their duties or guarantee an improper or unfair advantage, even if this conduct is legal of permitted in accordance with the appliable law or local practices.
No third party may offer courtesy in name of KPMG with the intention of acquiring products and/or services or having the KPMG Firm receive special treatment.
It is not permitted for third parties to give gifts or incentives (including gifts, entertainment, invitations, or food) with the intention of obtaining contracts as provider for the Firm.
KPMG has zero tolerance with facilitation payments, which may include small payments or gifts of little monetary value to public or private workers to ensure or accelerate rutinary actions.
In case of giving or receiving an incentive, gift, or entertainment, it must be reported to the corresponding Compliance Officer, according to the mails referenced below.

The information and data that on the occasion of these policies are communicated to the Compliance Official will be treated as established in Law 1581 of 2012.

KPMG is aware of the impact caused by the conducts associated to ML/FT/FPWMD, corruption and transnational bribery (C/TB) and the importance of fighting them together, therefore, we thank you for your commitment in complying with the law as collaborator, partner, provider, client, or third party, in order to manage and prevent these types of risks in a timely and responsible manner.

[1] To be understood as a third party that receives the name of strategic ally, subcontractor, service provider, member of a temporary union, alliances, and partnerships.

Regards,

KPMG en Colombia