The purpose of this policy is to establish the guidelines to be followed by PERU FROST S.A. employees in order to prevent and detect, in a timely manner, acts related to corruption, money laundering, bribery, terrorist financing and environmental pollution, thereby adequately complying with the applicable legislative regulations, in particular, establishing the guidelines for prevention activities and to comply with the provisions of Law 30424 as amended by Legislative Decree 1352, a transcendental regulation that serves as the basis for the formulation of this document. This POLICY applies to PERU FROST S.A., whose main office is located in Lima, Av. Manuel Olguín 501, Int. 902 – Santiago de Surco, in the development of its activities of:
The scope of application extends to all members of PERU FROST S.A. and to the entities that at any given time make up its business group, as well as to all contracted and subcontracted personnel, related agents, partners, collaborators and prescribers and other natural and legal persons who act in an authorized manner on behalf of or on behalf of our organization.
In this sense, this policy has the following specific objectives:
This policy is based on:
All our objectives are reviewed and updated periodically, with the approval of the General Management.
| PREPARED BY | 12/08/2024 |
| Administration | |
| REVISADO POR | 12/08/2024 |
| Legal adviser | |
| APPROVED BY | 12/08/2024 |
PERU FROST S.A. proceeds to the preparation and approval of this policy against acts of corruption, money laundering, bribery, financing of terrorism and protection of the environment, which contemplates different cases that a collaborator or third parties representing PERU FROST S.A. may face.
It refers to giving, offering, promising, receiving, granting, accepting or requesting any object of pecuniary value or other benefits such as gifts, favors, promises or advantages of any kind, for oneself or for another person, in exchange for the performance or omission of any act related to one's work or to influence the making of a decision or granting favorable treatment by or towards a collaborator.
Resources in cash or in kind provided to support non-profit organizations, to promote education and culture, social support or any other similar purpose without obtaining any commercial benefit in return.
Bribery is the action and effect of giving or receiving something of value so that someone does (or stops doing) something, circumventing a formal or implicit rule about what they should do, for the benefit of the person giving that something of value or a third party.
For the purposes of this policy, Public Officials includes the following categories of persons:
Consultants, agents, advisors, external lawyers, representatives, lobbyists or others who, both in the public and private sectors, carry out any operation on behalf of or on behalf of PERU FROST S.A., in relation to their interaction with public officials, government entities, clients, suppliers and third parties, are considered.
Activity that seeks to convert, transfer, manage or safeguard money, goods, effects or profits whose illicit origin is known or should be presumed, with the purpose of avoiding the identification of its origin, its seizure or confiscation.
Activity by which, directly or indirectly, within or outside the national territory, funds, financial or economic resources or financial services are voluntarily provided, contributed or collected for the purpose of committing terrorist activities that, among others, cause a state of anxiety, alarm or fear in the population.
An external party with which the organization has, or plans to establish, some type of business relationship. The definition of Business Partner includes, but is not limited to, customers, clients, “business alliances,” business alliance partners, consortium members, external suppliers, contractors, consultants, subcontractors, suppliers, vendors, advisors, agents, distributors, representatives, intermediaries, and investors. This definition is deliberately broad and should be interpreted according to the risk profile.
PERU FROST S.A. and its collaborators express their commitment to act in a responsible and respectful manner with the environment, paying special attention to its protection in accordance with the interests and concerns of civil society, the approved Integrated Management System Policy, as well as the current legislation that regulates it.
PERU FROST S.A. rejects any act of contamination, improper handling and illegal management of solid waste, illegal extraction of marine species, among others detailed in current regulations, as well as collaborating with the competent supervisory entities in our plants and fishing vessels.
In this regard, PERU FROST S.A. and its collaborators undertake to report any act or attempt that occurs, internally or externally, that goes against the environment, especially the crimes defined in Title XIII of the Peruvian Penal Code, by Law No. 292633.
At PERU FROST S.A. we periodically identify and evaluate the various acts of corruption, prevention of money laundering, financing of terrorism and the environment to which our activities are exposed, documenting the results in our RISK MATRIX, and we establish control plans for risks evaluated as above low risk with the clear objective of preventing and reducing their probability of occurrence, as well as to establish monitoring and control mechanisms.
As a result of the internal and external mechanisms for evaluating the effectiveness of our MANAGEMENT SYSTEM, as well as based on the information collected, analyzed and evaluated, we have established measures and are committed to continuously improving its effectiveness, with the aim of creating a truly living system capable of adapting to changing market circumstances and to the improvements, opportunities and errors detected.
To ensure maximum independence, a specific position has been designated within our organization chart, called Compliance Officer, a position endowed with adequate capacity, independence and authority, so that, in direct dependence on the Ethics Committee, the correct implementation and improvement of our MANAGEMENT SYSTEM is ensured according to the defined and agreed requirements.
The designated Compliance Officer is available to all members of our organization to advise, guide and support them on matters of ethical conduct and compliance.
Likewise, our organization will have all the necessary resources, in a proportionate manner, to carry out the actions, measures and controls planned in our RISK CONTROL MAP.
At PERÚ FROST we have a CODE OF CONDUCT AND ETHICS in force and approved by the Ethics Committee, applicable to all our members, of which they are informed upon joining the company.
This CODE OF CONDUCT AND ETHICS applies to all PERÚ FROST personnel, without prejudice to the legal consequences that may be imposed on them for any acts, events or behaviors that constitute a violation of the law.
In this regard, we have a disciplinary system, of which PERÚ FROST members are informed, to sanction conduct contrary to the provisions of this POLICY and the CODE OF CONDUCT AND ETHICS and non-compliance with the other requirements of the MANAGEMENT SYSTEM, including criminal conduct. Its application will be done in an equitable and proportional manner, under the principle of non-discrimination and respecting the applicable labor legislation. The sanctioning measures are established in the PERÚ FROST Code of Conduct and Ethics.
Likewise, within this Policy we slide some Guidelines of Conduct:
Contractors, suppliers and business partners must be recruited through a fair and formal selection process that includes, where appropriate, written requirements against corruption, money laundering, bribery, terrorist financing and environmental pollution.
It is the duty of employees to ensure that all activities and transactions have the proper authorization, are correctly recorded and are carried out in accordance with the policies of PERU FROST S.A.
PERU FROST S.A. must carry out a due diligence procedure for the implementation of controls on acts of corruption, money laundering, bribery, financing of terrorism and environmental pollution in the Organization to be acquired or absorbed, as well as when it signs any business collaboration agreement or establishes a new Organization with another shareholder.
To do so, the Legal Department and/or the department that promotes these contracts must inform the Compliance Officer so that he/she can supervise, control and monitor due diligence. This procedure must be documented and kept by the Compliance Officer.
Business collaboration is understood to mean the different forms in which PERU FROST S.A. enters into a business agreement, joint venture, consortium or other similar forms with another natural or legal person, which implies that PERU FROST S.A. and another natural or legal person will carry out joint commercial activities and participate in the management, administration, execution, responsibilities and profits of said joint business.
PERU FROST S.A. employees are responsible for ensuring compliance with the provisions of this Policy with the third parties with whom they interact. Therefore, they must have a written contract that formally reflects the scope of the services they will perform, the payment terms and the clause on compliance with PERU FROST S.A.'s anti-corruption policies.
PERU FROST S.A. expressly declares that facilitation payments are prohibited.
PERU FROST S.A. and its collaborators must reject direct or indirect requests for bribes from third parties, including public officials and people close to them, even in the case of being extorted with unfavorable actions.
PERU FROST S.A. is aware that in some cases, failure to agree to pay a bribe may endanger the employee's well-being and safety. If PERU FROST S.A. finds itself in this situation, it will notify the competent authority of this circumstance.
PERU FROST S.A. employees are responsible for monitoring, reviewing and carrying out due diligence when, in the performance of their duties, they have suspicions or warning signs that PERU FROST S.A. is being used to carry out money laundering or terrorist financing activities. In these cases, they must inform the Compliance Officer, without prejudice to using the reporting channels.
PERU FROST S.A. is committed to developing, documenting, maintaining and continually improving its internal financial controls to ensure that all payments are accurately recorded in the Organization's accounting books and records. All payments must be recorded correctly and transparently. In this regard, all records must be supported by supporting information such as receipts, orders or other applicable documents.
PERU FROST S.A. prohibits the registration or authorization of false or misleading entries in operating records or accounting records with the aim of concealing improper payments.
All collaborators, and especially those collaborators or areas that contract, supervise, control or coordinate the services of these third parties or suppliers, are obliged to carry out due diligence when they must act on behalf of the Organization with public officials or persons who imply a risk of acts of corruption, money laundering, financing of terrorism and environmental contamination; which allows you to have the peace of mind and knowledge of who you are working with, what their reputation and qualifications are.
The purpose of having business courtesies is to create goodwill for work as long as they are not used with the intention of unduly influencing the decisions of the person receiving it, go against legal regulations or the policies of PERU FROST S.A.
The delivery of institutional gifts will be subject to the terms approved by PERU FROST S.A.
Due to the nature of the Organization, the relationship with Public Officials is a recurring activity in the development of its operations and therefore, necessary to ensure business continuity.
In this regard, the Organization encourages its employees to maintain good professional relations with said officials, which should be marked by collaboration as long as they do not violate any of the principles set forth in this Policy or breach legal regulations and are exempt from any form of pressure or intervention.
Any member of our organization, employee, partner, shareholder, director, representative and/or person acting in an authorized manner on behalf of or on behalf of PERU FROST S.A. has the obligation to inform and/or report any action, conduct, information or evidence that is susceptible or suspected of violating this POLICY or the requirements of the MANAGEMENT SYSTEM of our organization and that may constitute a criminal act or conduct.
At PERU FROST S.A., individuals have the following means available to report any type of suspicious event or behavior or to raise any type of doubt or query in this regard:
At PERU FROST S.A. we value the communication of any indication or suspicion of violation of the law by any member, person or organization linked to our organization, so we appreciate the greatest possible detail in the exposition of the reported/communicated facts.
Our organization has established secure internal mechanisms and processes to ensure the confidentiality of complaints and communications received, as well as to protect people who participate in our compliance objective through communication and reporting from any type of threat or coercion.
There are no exceptions to non-compliance with this Policy. Non-compliance with this policy may result in the imposition of administrative sanctions by various supervisory authorities, criminal sanctions, and others, including disciplinary sanctions provided for in the Internal Work Regulations and current regulations.
Ningún colaborador será degradado a un cargo de menor jerarquía, ni estará sujeto a sanciones u otras medidas disciplinarias por comunicar sospechas de violación de la presente Política o por rehusarse a pagar un soborno, incluso cuando ello implique la pérdida de un negocio para PERU FROST S.A.. PERU FROST S.A. garantiza que ningún colaborador deberá estar sujeto a represalias por comunicar su sospecha y el ejecutivo, colaborador o plana gerencial que se acredite ha realizado actos de represalia será sancionado conforme a las normas vigentes.
Any business partner/commercial partner who fails to comply with this Policy will be sanctioned with the automatic termination of his/her contract or business relationship with PERU FROST S.A.
If you become aware of or suspect a possible breach of this Policy, you must report it through the established channels.
This document will be effective from the date of its publication.
From this date, the Policy will be part of the induction process for all employees, and its knowledge will be promoted to suppliers, contractors, clients and business partners.
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