Anti-fraud and
Anti-corruption Policy

Introduction

At BIA we have developed this Anti-corruption policy in order to provide the Board of Directors, Senior Management, partners, business associates and third parties with an official document that outlines our commitment fighting corruption.

This policy is a crucial component of our Compliance Program, which seeks to ensure that everyone can fulfill their job responsibilities without legal, financial and reputational risk.

Objectives

This policy aims to define the limits within which our partners, Senior Management and Board members, as well as business associates and third parties, must act in order to protect the organization and its employees.

The policy includes, but is not limited to, these specific objectives:

  • one-circle Promoting a culture of ethics and values that helps prevent, detect, investigate and mitigate the risks of corruption.
  • two-circle Complementing the Anti-bribery Management System (AMS), which aims to combat risks of corruption, including bribery, fraud, extortion, misappropriation, etc. in all its forms and manifestations.
  • three-circle Defining criteria, outreach, limits and responsibilities of this policy and the consequences of its breach.
  • four-circle Maintaining financial controls designed to secure the financial books and statements, showing the underlying transactions in detail and precisely.

Outreach:

This Anti-corruption policy applies to all partners, Senior Management, Board or Audit members, business associates and third parties.

Ethical culture and awareness:

At BIA we have Anti-corruption programs and training courses being taught in person and virtually through an e-learning platform. We also have an Ethics Code outlining our standards to guide partners in their work.

Zero tolerance to corruption:

BIA has a zero-tolerance policy for bribery, fraud, extortion, misappropriation, etc. in all its forms and manifestations. This means that any incidence, claim or suspicion will be investigated and those responsible will be punished.

Board members and Senior Management’s commitment and leadership:

It is the Board members and Senior Management’s responsibility to show their commitment to meeting this policy and promoting an ethical culture.

Hospitality and donations:

Any type of donation (either in money or in kind) has to be approved by Corporate Affairs and Compliance through the Compliance site.

Donations to Entities or Public Officials:

For analysis and approval of Entities and Public Officials, Compliance will use the following criteria:
  • one-circle Do not offer, promise or make any donation, gift or courtesy to any Public Official whose entity is responsible of the permit management, licenses or any type of authorization that might affect the company, directly or indirectly.
  • two-circle Do not offer, promise or make any donation to Public Entities or Public Officials, except after natural disasters.
  • three-circle Do not offer, promise or make any donation, gift or courtesy, such as tickets to events or invitations to Public Officials, to take advantage for the Official’s own or familiar benefit.
  • four-circle Do not offer gifts or donations to Public Officials as an incentive in exchange for or as a reward for granting an application, passing products through custom offices or giving any potential undue advantage for the company.
  • five-circle Follow the procedure and get the established authorization at the Compliance site.
Once the donations are approved, they have to be supported and attach its acceptance report at the Compliance site.

Donations to Private Entities (Cooperatives, Nonprofit Associations, etc.):

Donations should be made preferably when the Private Entity has humanitarian purposes, seeks the public good or has been approved by Corporate Affairs and Compliance, and only if they meet the following requirements:
  • one-circle The organization is directed to the welfare of the community or has humanitarian purposes.
  • two-circle The donor follows procedure and has received authorization at the Compliance site.

Hospitality and courtesies:

All courtesies, gifts, dinner invitations, travel, entertainment and other favors made to third parties are subject to this policy. Applicable limits can be found at the Compliance site. Promotional expenses are allowed, including gifts of nominal value related to the brands and portfolio of the company, reasonable meals, tickets to company’s events or those sponsored by the company, subject to the following conditions:
  • one-circle Promotional activities or for an existing contract operational cost.
  • two-circle Reasonable expenses. Not luxurious or extravagant.
  • three-circle Recorded expenses.
  • four-circle Permitted by the local law.
  • five-circle Not carried out secretly or with the appearance of impropriety.
  • six-circle Notify the Compliance site about the expense.
Any exception will have to be approved by the Ethics Committee through the Chief Compliance Officer.

Financial inputs to political groups:

It is forbidden to give donations, gifts, courtesies, loans or rental of furniture, equipment, transportation or any other support to political parties and candidates for public offices.

Facilitation payments:

The company does not allow facilitation payments even if they are made with personal resource of the partner. This type of payment is prohibited.

Gifts and other considerations:

Partners can’t accept gifts, dinner invitations, trips or any type of care from our clients and prospects, suppliers, public officials or any third party who could compromise the capacity to take objective commercial decisions.

The rules to accept gifts are:

  • one-circle That the invitations, trips or seminars and commercial meetings are authorized by the Director or Corporate VP.
  • two-circle That the gifts are delivered during special occasions and do not exceed the price limit of the Ethics Code.
  • three-circle Any doubt or exception will have to be approved by the Compliance site.

Third Parties:

TPVs (Touch Point Vendors):

Subject to Due Diligence process stablished by Compliance site on its procedure. Contracts to be executed with TPVs will include clauses that allow the unilateral termination of contracts if the counterpart commit corrupt acts in order to comply Anti-corruption Laws.

Hiring former public officials:

The company will not be able to hire a former public official at the moment they serve as public official or for the coming two years from their date of termination of service, that has signed resolutions or decisions where the company had participated or had been involved. Any exception will have to be audited and approved by the Ethics Committee.

Records:

A system of internal controls is required, where the transactions can be reflected and reported appropriately, precisely and with reasonable details on the accounting books and records of the company.

The finance area will identify within its chart of accounts the “sensitive” or “Compliance Sensitive Transactions” or “CST”, having to continuously monitor those accounts.

The contractors shall comply the accountability provisions, books, records and provisions of internal control covered by the Applicable Anti-corruption Laws.

Ethical Line:

The access to the Ethical Line is by telephone numbers open for each of the countries in which we operate, e-mail and web site, as described in the Ethics Code.

Those who report any misconduct, and those who participate on the research, are protected from reprisals. The company prohibits and punishes any type of reprisal against complainants or partners of the investigation procedure, even with dismissal. The disciplinary sanction will be based on the Ethics Code, Employment Contract, Internal Labor Regulations and Rules on Disciplinary Sanctions.

Roles and Responsibilities:

The Board of Directors is committed to promoting a preventative culture against corruption at strategic and operational levels.

Senior Management will implement control measures to ensure prevention process and corruption risk mitigation, and there will be regular reviews to determine if possible risk has emerged.

The Compliance Department, with Legal Management’s support, is responsible of developing and tracking the Anti-bribery Management System and ensuring the effectiveness of the Compliance Program. It is also responsible of the research, track, administration and actualization of the incidents reported on the Ethics Line until the end of the researched cases, and will inform the Ethics Committee promptly.

The Management Department will assist on the outreach and awareness of this policy to all partners.

The Internal Audit Department is responsible of assessing the effectiveness and fulfillment of this Anti-corruption Policy.

Each partner is responsible of applying the criteria stablished on the policies and procedures, and will have to act in line with the corporate values and guidelines established in the Ethics Code.

Risks:

There are different types of risks in this policy: financial risks, operational risks, compliance risks, and risk of reputation and corruption.

a. Financial risks:

  • one-circle Misappropriation of Assets and Accounting Fraud in favor of employees or the organization.
  • two-circle Financial losses in favor of employees or third parties, for goods or services not yet provided or received in different quality.
  • three-circle Unfair negotiations with suppliers that support the increase in the business’ costs and expenses.
  • four-circle Increase in costs and expenses due to theft of products through unauthorized mechanisms.

b. Operational risks:

Due to conflict of interests, inadequate supervision, lack of attachment to the organization’s essential values and culture.

c. Compliance risks:

Money laundering, corruption, tax evasion, violation of policies and procedures.

d. Risk on reputation:

Corporate Groups’ demands (clients and suppliers)

e. Risk of corruption:

Breach of rules and policies affecting the company’s situation and the impact on its reputation.

Sanctions:

Any breach of this policy and its related procedures will be subject to disciplinary measures that have to be applied to the employees who have committed the offense directly or by default.

The sanctions will depend on the magnitude of the offense and will be governed by each country’s laws and the internal work regulations.

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