The Group’s Compliance Model applies to both employees and contractors. It is clearly defined and is communicated regularly through internal communication channels, as well as being available on the Group’s website. All contracts with contractors include clauses relating to ethics, modern slavery and crime prevention to ensure adherence to the Group’s Compliance Model.
The Compliance Model comprises five pillars:
The Code of Ethics
This code sets out the Group’s values and provides guidelines on behaviour for all employees and contractors.
- Code of Ethics
- Conflict of Interest Guidelines
- Gifts and Hospitality Guidelines
- Modern Slavery Act
- Monitoring effectiveness of programme
- Annual Statement
The Crime Prevention Model
This model ensures compliance with the anti-bribery and anti-corruption laws in the United Kingdom and Chile. The Vice President of Finance and Administration is responsible for overseeing, defining and implementing the model. As part of the model, the Group regularly undertakes the following activities:
- Training on key risk areas (ethics, anti-corruption, modern slavery and antitrust matters)
- Investigating all reports made by whistleblowers
- Assessing conflict of interest and due diligence on all business partners
- Updating and reviewing all employees’ conflict of interest statements
- Bolstering the compliance programme and systems
- Overseeing third-party reviews of the Crime Prevention Model
- Implementing policies and processes to ensure the proper management of any noncompliance exposure
- Crime Prevention Handbook
- Anti-corruption clauses in contracts
- Due diligence process, including global checking
- Antitrust – Politically Exposed Person (PEP) Facilitation Fees Guidelines
Employees and external stakeholders can report concerns of irregular conduct or ethical issues through the Company’s intranet, by email, or letter, or by using a dedicated hotline. All complaints are investigated, findings are reported to the Ethics Committee and action taken if required. The security and confidentiality of employees is ensured for the duration of the process, safeguarding individuals and therefore achieving greater transparency.
- Reporting channels (web, telephone hotline, email)
- Methodology of complaints investigation and reports
- Monitoring – analysis of complaints and improving internal controls
Communication and Training Programme
The Group has a comprehensive training programme to ensure that the policies and procedures of the Compliance Model are clearly understood and embedded in the culture of the organisation. The programme emphasises the right to know and there are measures in place to enhance the skills required to ensure its effective implementation.
The Group updated its compliance training programme in 2016, adding the concept of modern slavery and examples of its use to the new employee induction and e-learning courses.
- Communications (news, intranet, posters)
- Training programme – induction of new employees and e-learning
Compliance Risks and Control Assessment
The objective of the Compliance Risks and Control Assessment is to identify, develop and improve internal controls to prevent potential risks. This assessment is performed at least annually.
- Identification of risks and controls
- Assessment of risks and controls, and improvement of the process
The model is reviewed regularly, both internally and by third parties, and on matters relating to corruption it has been certified under Chilean anti-corruption legislation.
Crime Prevention & Code of Ethics