The Group’s Compliance Model applies to both employees and contractors. It is clearly defined and 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 and crime prevention to ensure adherence to the Group’s Compliance Model.
The Compliance Model comprises of five pillars:
The Code of Ethics
This code sets out the Group’s values and provides guidelines on behaviour for all employees and contractors.
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 and anti-trust matters)
- Investigating all reports made by whistleblowers
- Conflict of interest assessment and due diligence on all business partners
- Updating and reviewing all employees’ conflict of interest statements
- Bolstering the compliance programme and systems
- Third party review of the Crime Prevention Model Policies and processes are in place to ensure the proper management of any non-compliance exposure.
Policies and processes are in place to ensure the proper management of any non-compliance exposure.
Employees and external stakeholders can report concerns of irregular conduct or ethical issues through the Company’s intranet, or by email, letter or using a dedicated hotline. Every complaint is investigated, the findings are reported to the Ethics Committee and, if required, action is taken. Measures are taken to ensure the security and confidentiality of employees for the duration of the process, safeguarding employees and providing greater transparency.
Communication and Training Programme
The Group has a comprehensive training programme to ensure that the policies and procedures of the Compliance Model are understood and embedded in the culture of the organisation. The programme emphasises the right to know and there are measures in place to bolster the skills required to ensure its effective implementation.
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.
The Compliance Model is regularly monitored and reviewed internally as well as by external parties. The strong performance of the Compliance Model has enabled it to be certified in Chile. The Model is regularly reviewed 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