Business Ethics
We are aligned with the UN Global Compact
We are committed to operate based on its 10 Principles on human rights, environment, and anti-corruption, contributing to 15 Sustainable Development Goals, 35 Targets and 43 Indicators of the 2030 Agenda. Among them, the fight against Climate Change stands out, through the implementation of our Global Strategy for both Mitigation and Adaptation, based on diagnoses made with expert partners to implement a Carbon Management System and an Adaptation and Resilience Management System.
The Code of Ethics is the expression of our way of doing things
It reflects our culture and is a simple and fundamental tool for Aleatica’s work team to always act correctly in any situation.
Our Code of Ethics and Conduct establishes the guiding principles of the behavior of all of us who are part of Aleatica and is the compass that guides relationships with our Stakeholders: partners, customers, employees, suppliers, subcontractors, allies, governments, communities and any group or person who is related to the Company. All of us who are part of Aleatica, from the Board of Directors to the managers and employees, without exception, are committed and required to know the Code and comply with it in a timely manner.
In this, a structure of topics based on the five pillars of Aleatica was established.
- Safety in our Business Units and for our customers
- Safety for our employees
- Engagement with communities
- Environmental Care
- Customer service
- Quality and innovation
- Zero tolerance for bribes, improper payments and facilitation payments
- Prevention of money laundering and terrorist financing
- Gifts, hospitality and entertainment expenses
- Conflicts of interest
- Accuracy of information and records
- Free competition
- Insider trading
- Relationship with Third Parties
- Privacy and data protection
- Use of assets
- Protection of our name
- Respect for Human Rights
- Diversity and inclusion
The Code of Ethics and Conduct and the Anti-Corruption Policy are of vital importance to Aleatica, forming the top of our regulatory pyramid.
The Compliance team conducted a specific training of both documents, to expose and make known to 100% of employees the main changes to these documents, making clear the commitment of senior management on compliance with the values and principles included in them. In said Anti-Corruption Policy:
- Bribes in any form (including kickbacks) on any portion of contract payments or soft dollar practices are prohibited.
- Making political contributions on Aleatica’S behalf are strictly prohibited.
- Obtaining an undue advantage or benefit using donations or sponsorships as a method are prohibited.
We guarantee confidentiality and protection against retaliation
At Aleatica we have an ethical channel managed by the Compliance Department, guaranteeing confidentiality and protection against retaliation for those who use it, and which provides for the possibility of making complaints anonymously. The following means of contact are available to make any inquiries or to report illegal behavior, irregularities, and non-compliance with Aleatica’s internal policies and the Code of Ethics and Conduct:
Upon receipt of any report, the Compliance Department responds to the informant indicating receipt and, if necessary, requesting additional information. If the Compliance Department decides to conduct an investigation, it appoints an Investigation Instructor according to the nature of the allegation. The Investigation Instructor involves those areas deemed necessary to develop the investigation and considers the advisability of adopting precautionary measures while the investigation process underway is substantiated and resolved.
Aleatica’s governing bodies are aware of the standards of transparency and integrity that must govern our actions. To this effect, these bodies have a direct involvement in decisions that enable the creation of up-to-date Corporate Governance through the approval of corporate policies.
In addition, the Group’s internal procedures have been developed so that its governing bodies receive independent information from the Compliance and Internal Audit Departments, which allows for an assessment of Aleatica’s compliance status in different aspects of its corporate life.
The Chief Compliance and Risk Officer submits to the Audit Committee for approval decisions regarding investigations and proposed measures for the following cases:
- Any allegation, whether material or not, involving an officer of the Group or any member of the governing bodies of the companies comprising Aleatica or its subsidiaries.
- Any allegations of corruption and/or bribery.
- Any compliance breach that could prevent the General Meeting of Shareholders from declaring that the annual accounts and the annual report provide an accurate description of the company.
- Any compliance breach that indicates a significant deficiency or weakness in Aleatica’s enterprise risk management system.
- Any compliance violation that, if made public, could have a significant effect on the market price of the publicly traded shares.
were received in 2022.
All complaints received were investigated and resolved. All complaints are reported to the highest governance body designated for compliance issues at least quarterly.
| Classification by issue | 2021 | 2022 |
|---|---|---|
| Working environment | 44 | 63 |
| Sexual Harassment | 0 | 7 |
| Compliance & Ethics | 7 | 11 |
| Safety Concerns | 0 | 1 |
| Company Processes | 0 | 1 |
| General Inquiries | 3 | 3 |
| Total | 54 | 86 |
Because it matters to us
At Aleatica, we take compliance with this Code, its policies and procedures and the applicable laws very seriously. That is why Aleatica will take the legal or disciplinary actions it deems appropriate in accordance with the applicable legislation, up to and including dismissal.
Depending on the circumstances, certain behaviors may also give rise to penalties of a civil or criminal nature by the corresponding authorities.
Inappropriate behavior that is thus subject to legal or disciplinary action may result in sanctions that may extend not only to the individual who committed the violation, but also to those who, through their actions or omissions, approved such behavior or were aware of the violations and did not make an effort to correct them immediately. Failure to comply with this Code may result in the amendment or cancellation of Aleatica’s business relationship with the third party in question, subject to the contractual obligations and applicable laws.
**The data shown on this page corresponds to Aleatica Mexico**
