Compliance

COMSA Corporación's Compliance model regulates matters of great importance for the group, so its knowledge, assumption and compliance is of vital importance.

Below is a breakdown of the documents that make up the regulatory compliance model, developed on the basis of the Code of Ethics and the Criminal and Anti-Bribery Compliance Policy, of which only those with hyperlinks are accessible to the public:

COMSA Corporación's Code of Ethics

Criminal and anti-bribery compliance policy

Corporate Protocols and Policies applicable to all group companies adhering to the Compliance model:

Protocol for general risk management measures in group structures

Protocol of the Bodies of the Compliance Function

Protocol of rights and duties of the members of the organisation with respect to the Compliance model

Protocol for Ethics Channel management, internal investigations and corporate reactions

Review plan

Information Security Protocol

Privacy Policy

Protocol of the procedural representative of the legal person

Protocol for the prevention of harassment and other discriminatory behaviour

Competition compliance policy

Guidelines for action in case of inspection by competition authorities

Protocol for the prevention of fraudulent and unfair behaviour

Policy on contracting with business partners and consultants

Policy on hospitality, gifts and donations

Code of Conduct for suppliers

Entry policy and dawn raid registrations

Protocol for the prevention of criminal risks of corruption

Conflict of interest management protocol

Fiscal Policy

Protocol for the prevention, control and management of tax and social security risks

Whistleblowing Management System Policy (Ethics Channel)

Data protection policy of the complaint management system

COLOMBIA

Self-control and Integral ML/FT/FPADM Risk Management System Manual for the company COMSA COLOMBIA S.A.S.

COMPLIANCE MANUAL OF THE TRANSPARENCY AND BUSINESS ETHICS PROGRAMME FOR THE COMPANY COMSA COLOMBIA S.A.S.

For more information on the scope of application of the compliance model, see the Perimeter of the group companies adhered to the model.

Employees of the organization can access all Compliance documents via the following link.