Supervision of the Compliance
The supervision of the Program is the responsibility of the Financial Administrative Directorate.
The daily monitoring and inspection of compliance with the recommendations, prohibitions and determinations of the Program and, in particular, of its Code of Ethics and Conduct, is the responsibility of all departments together with the Committee of Compliance.
The GEL it makes available whistleblowing channels where all interested parties will be able to present reports on the improper conduct of the company and its members, aiming to improve its methods of combating legal, ethical and regulatory non-conformities.
The Committee of Compliance is the body responsible for receiving the reports and contributions made regarding its Program. The body is made up of company members, from three to seven.
Any doubts that employees may have about potential conflicts of interest should be referred to the Management Committee. Compliance, who is prepared to provide an impartial opinion.
Compliance Committee Guidelines
- The information received by the Compliance are treated with total secrecy.
- The GEL is committed to no retaliate against anyone who reports an alleged violation of Ethic and Conduct.
- Failure to comply with the rules of the Compliance gives GEL may result in disciplinary action.
- Doubts should be clarified directly with the immediate superior or with the Compliance.
- The GEL has a commitment to respond and / or adopt the appropriate measures to ascertain the conduct contrary to what is established in its Compliance.
Guarantee of Anonymity and Confidentiality
The GEL guarantees the anonymity and confidentiality of the informant of any and all communications received by the Compliance.
Under no circumstances is the information provided to the Compliance will be used against whoever collaborates. This is a firm commitment by GEL.
The GEL may carry out further investigations to investigate complaints or contributions received by the Compliance, including investigative steps, if applicable.
In the exercise of its functions, the Compliance he must observe the precepts of discretion, professionalism, integrity, morality, skepticism, respect for everyone right of defense, impartiality in assessing situations and objectivity in determining the facts brought to the Committee.
The GEL adopt the appropriate disciplinary measures in cases of violation of this Code.
No member of the GEL or any professional who is directly connected to the company activities will no longer suffer any type of reprimand for the breach of the precepts of its Compliance Program, regardless of his position.
The measures to be adopted by the GEL they will be analyzed on a case-by-case basis and may lead to the dismissal of the employee or the termination of any contracts, if pertinent, always respecting the assessment of the severity of the harmful conduct.