Our Commitment

Encajes S.A. Colombia adopts the Self-Control and Comprehensive Risk Management System for Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction (SAGRILAFT), in compliance with applicable regulations and with the purpose of preventing the Company from being used to carry out illicit activities.​

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​The organization maintains a zero-tolerance policy toward any conduct related to ML/TF/PF and promotes a culture of legality, transparency, and self-control.

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System Objective

To implement effective mechanisms for the identification, measurement, control, and monitoring of ML/TF/PF risks, minimizing the likelihood that the Company may be used to give an appearance of legality to resources derived from illicit activities or to channel resources toward such activities.​

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​Scope

SAGRILAFT applies to:​​

• Shareholders and Directors

• Senior Management

• Employees

• Clients

• Suppliers

• Contractors

• Other related third parties

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It covers all processes and operations carried out by the Company.​​

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How Do We Manage Risk?

The System is developed under a preventive and structured approach that includes:​

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• Risk Identification: Segmentation by counterparties, products, channels, and jurisdictions.

• Evaluation and Measurement: Assessment of inherent and residual risk through internal tools.

• Control: Application of due diligence procedures, verification against restrictive lists, identification of the ultimate beneficial owner, and document retention.

• Monitoring: Continuous oversight, analysis of unusual transactions, and reporting of suspicious activities to the competent authorities when applicable.

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Due Diligence and Knowledge of Counterparties

Encajes S.A. Colombia applies formal procedures for the knowledge of clients, suppliers, employees, and other third parties, including:

• Identity verification.

• Identification of the ultimate beneficial owner, when applicable.

• Verification against restrictive and binding lists.

• Application of enhanced measures when the level of risk so requires.

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Governance and Responsibilities

Senior Management leads the implementation and supervision of the System.

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​The Compliance Officer executes, coordinates monitoring, and prepares the corresponding regulatory reports.

All employees and related third parties must comply with the established guidelines and report any situation that may represent an ML/TF/PF risk.

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Compliance Culture

The Company promotes periodic training of its personnel and the dissemination of the System, strengthening an organizational culture based on integrity, legality, and corporate responsibility.​

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Consequences Regime

Failure to comply with the provisions of SAGRILAFT may result in disciplinary, contractual, or legal sanctions, without prejudice to any applicable criminal liabilities, as established in the related manuals.