Objective

The Business Transparency and Ethics Program (PTEE) of Encajes S.A. Colombia aims to establish principles, policies, guidelines, and controls to prevent, detect, manage, and mitigate corruption and transnational bribery risks, promoting an organizational culture based on integrity, legality, and transparency.

 

Likewise, the Program seeks to ensure that all actions of the Company, its directors, employees, and third parties are carried out in compliance with applicable regulations, corporate values, and defined ethical standards, thereby strengthening corporate governance and stakeholder trust.

 

The PTEE is integrated with the other compliance systems and programs of Encajes S.A. Colombia, including the Self-Control and Risk Management System for Money Laundering, Terrorist Financing, and Proliferation Financing (SAGRILAFT), ensuring a comprehensive approach to risk management and regulatory compliance.​

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Scope

The Business Transparency and Ethics Program (PTEE) is mandatory for all directors, officers, employees, temporary staff, contractors, suppliers, strategic partners, and any other third parties with whom the Company maintains commercial, contractual, or institutional relationships.

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The Program applies to all activities, processes, operations, and decisions carried out by Encajes S.A. Colombia, both nationally and internationally, regardless of the medium used (in-person, virtual, or digital), and covers interactions with both public and private sectors.

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​The scope of the PTEE includes the prevention, detection, management, and mitigation of corruption and transnational bribery risks, as well as the promotion of ethical and transparent behavior, and is aligned with other corporate programs and policies, particularly the Code of Ethics and Transparency, the Conflict of Interest Management Manual, the Whistleblower Protection Policy, and the SAGRILAFT System.

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Definitions

For the purposes of the Business Transparency and Ethics Program (PTEE) of Encajes S.A. Colombia, the following terms shall have the meanings indicated below:​​

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• Zero Tolerance for Transnational Bribery: A principle under which the Company strictly rejects any conduct related to transnational bribery.

• Abuse of Position: Misuse of a role or function to obtain personal or third-party benefits.

• Management: Includes Board members, legal representatives, and employees responsible for decision-making and representation of the Company.

• Risk Management: Coordinated activities to direct and control the organization with respect to risk.

• Senior Management: Individuals at the highest hierarchical level responsible for business operations, strategy, and execution, including the General Manager and senior leadership roles.

• Geographical Area: The territory where the Company operates.

• Shareholders: Individuals or entities holding equity participation in the Company.

• Compliance Audit: Systematic and periodic review of the implementation and effectiveness of the PTEE.

• Ultimate Beneficial Owner: The natural person(s) who ultimately owns or controls a counterparty.

• Reporting Channel: Mechanisms established to report unethical or illegal conduct confidentially or anonymously.

• Client: Individual or entity with whom the Company establishes a contractual relationship.

• Code of Ethics and Transparency: Document outlining ethical principles and behavioral guidelines.

• Company: Encajes S.A. Colombia.

• Counterparty: Any individual or entity with a business or contractual relationship with the Company.

• Contractor: Third party providing services or maintaining a contractual relationship with the Company.

• Corruption: Actions or omissions aimed at obtaining undue benefits.

• Due Diligence: Ongoing process of evaluating counterparties to mitigate corruption risks.

• Enhanced Due Diligence: Strengthened evaluation process applied in high-risk situations.

• Whistleblower: Individual reporting irregular conduct in good faith.

• Employee: Individual with an employment relationship with the Company.

• Business Ethics: Acting in accordance with corporate values and principles.

• Risk Factors: Circumstances that may increase corruption risks.

• Stakeholders: Individuals or entities with an interest in the Company.

• Misappropriation: Improper use of entrusted assets.

• Risk Matrix: Tool to assess corruption and bribery risks.

• Protective Measures: Actions to safeguard whistleblowers.

• International Transactions: Business dealings involving foreign entities.

• Compliance Officer: Individual responsible for overseeing the PTEE.

• Politically Exposed Persons (PEPs): Individuals holding prominent public positions.

• Protected Person: Whistleblower or witness granted protection measures.

• Compliance Policies: Policies ensuring ethical and lawful conduct.

• PTEE: Framework to manage corruption risks.

• Retaliation: Any adverse action against a reporting individual.

• Reputational Risk: Risk of damage to the Company’s image or trust.

• Foreign Public Official: Individual exercising public functions abroad.

• Transnational Bribery: Offering undue benefits to foreign officials.

• Witness: Individual providing relevant information.

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Illicit Enrichment

Unjustified increase in an employee’s assets compared to their legitimate income.

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Context

Encajes S.A. Colombia carries out its activities in a business environment that demands high standards of integrity, transparency, and regulatory compliance, both in its relationships with the public and private sectors, at national and international levels.

 

In this context, the Company recognizes the importance of timely identifying and managing the risks of corruption and transnational bribery, which may affect business sustainability, corporate reputation, and stakeholder trust.

 

The Business Transparency and Ethics Program (PTEE) is adopted as a preventive and cross-functional instrument, aimed at establishing clear guidelines for ethical conduct, strengthening corporate governance, and promoting an organizational culture based on legality, responsibility, and accountability.

 

The Program is integrated with the Company’s other management and compliance systems, particularly the Self-Control and Risk Management System for Money Laundering, Terrorist Financing, and Proliferation Financing (SAGRILAFT) and the Code of Ethics and Transparency, ensuring a comprehensive approach to risk management and regulatory compliance.​

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Senior Management Commitment

Senior Management of Encajes S.A. Colombia expresses its explicit and unequivocal commitment to business ethics, transparency, and compliance with applicable regulations, and adopts a zero-tolerance policy toward corruption and transnational bribery.

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In fulfilling this commitment, Senior Management:​

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  Approves, supports, and promotes the implementation of the Business Transparency and Ethics Program (PTEE), as well as the Code of Ethics and Transparency and the policies that comprise it. 

• Ensures the appointment of a Compliance Officer, as well as the allocation of the human, technical, and financial resources necessary for the proper execution, monitoring, and continuous improvement of the Program.

• Requires all directors, employees, and third parties to strictly comply with the principles, values, and guidelines established in the PTEE and other corporate policies.

• Promotes an organizational culture focused on the prevention, detection, and mitigation of corruption and transnational bribery risks, as well as the responsible use of reporting channels.

• Ensures the protection of whistleblowers and the prohibition of retaliation against those who report, in good faith, conduct that is irregular or contrary to ethics and legality.

• Conducts periodic monitoring of the operation and effectiveness of the Program, adopting corrective and improvement measures as necessary.

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This commitment is transversal across all levels of the organization and constitutes a fundamental pillar of corporate governance and the sustainability of Encajes S.A. Colombia.

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Corporate Values within the Framework of Transparency​​​

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The Business Transparency and Ethics Program (PTEE) of Encajes S.A. Colombia is based on a set of principles and values that guide the conduct of Senior Management, directors, employees, and third parties, and serve as a reference framework for decision-making and engagement with stakeholders.

 

These principles and values reflect the Company’s commitment to responsible, transparent business management aligned with applicable regulations:

• Ethics and Integrity: Acting consistently with corporate values and rejecting any improper, corrupt, or unlawful conduct.

• Legality: Strict compliance with legal and regulatory provisions, as well as internal Company policies.

• Transparency: Conducting operations in a clear, traceable, and verifiable manner, facilitating accountability.

• Honesty: Acting with integrity and truthfulness in all labor, commercial, and contractual relationships.

• Good Faith: Promoting relationships based on trust, respect, and loyalty with stakeholders.

• Responsibility: Consciously assuming obligations and the consequences arising from one’s actions.

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These principles and values constitute a transversal axis of the PTEE and are mandatory for all levels of the organization and for third parties acting on behalf of Encajes S.A. Colombia.

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Roles and Responsibilities​​​

The implementation and effectiveness of the Business Transparency and Ethics Program (PTEE) of Encajes S.A. Colombia are the responsibility of the entire organization, under the leadership of Senior Management and with clearly defined roles.

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Senior Management and Parent Company

Approve the C/TB policy, the PTEE, and its updates; appoint the Compliance Officer; allocate the necessary resources; and periodically monitor the operation and effectiveness of the Program.

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Legal Representative​​
Leads the implementation of the PTEE, supervises its execution, reviews the reports of the Compliance Officer, and ensures the availability of resources, as well as the follow-up of audits and corrective actions.

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Compliance Officer​​
Designs, implements, and monitors the PTEE; assesses C/TB risks; verifies due diligence processes; trains the organization; submits reports to Senior Management; and manages reporting to competent authorities.

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Statutory Auditor and Internal Audit

Evaluate compliance with and effectiveness of the PTEE, report findings, weaknesses, or warning signs, and provide recommendations for improvement.

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Directors and Employees​​

Comply with PTEE policies and procedures, act with integrity, prevent conflicts of interest, and promptly report any irregular situation through the established channels.

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Complementary Policies

Prevention of conduct related to ethics and employee behavior

Establishes the principles and rules of conduct that guide employees’ ethical behavior. It promotes integrity, respect, and responsibility in the performance of their duties through the Internal Code of Conduct (formerly Code of Ethics).​

Prevention of conduct related to corruption, fraud, or similar acts

The Code of Ethics and Transparency (in English and Spanish) establishes zero-tolerance guidelines for acts of corruption, bribery, and fraud. It applies to all employees, directors, and third parties linked to the Company.

Regulation of commercial relationships

​The Gifts and Hospitality Policy establishes rules for the giving and receiving of gifts, courtesies, and hospitality. It aims to prevent conflicts of interest and practices that may affect business transparency.

Confidentiality and proper handling of reports​

The Investigation Policy ensures the confidential, objective, and timely handling of reports received, defining the investigation process under principles of impartiality and due process.

Whistleblower protection and zero tolerance for retaliation​

The Whistleblower Protection Policy guarantees protection for those who report, in good faith, potential irregularities. It prohibits any form of direct or indirect retaliation.

Efficient management and knowledge of suppliers​

The Supplier Selection and Evaluation Procedure defines guidelines for selection, evaluation, and monitoring, aiming to mitigate corruption, fraud, and bribery risks in the supply chain.

Conflict of interest management and employee awareness of C/TB risks​

The Conflict of Interest Management Manual establishes mechanisms to identify, declare, and manage conflicts, strengthening employee awareness of corruption and bribery risks.

Guidelines for onboarding and contracting clients and counterparties

Commercial, credit, and foreign trade procedures establish due diligence criteria for onboarding clients and counterparties. They prohibit relationships with individuals or entities included in restricted lists and establish the obligation to report to competent authorities.

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Reporting Channels

Encajes S.A. Colombia provides confidential and secure channels to report, in good faith, any conduct that may constitute acts of corruption, bribery, fraud, conflicts of interest, or non-compliance with the PTEE.

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The channels are as follows:

Compliance Officer:
Katherine Baena Acosta
Email: oficialcumplimientoptee@encajes.com
Phone: (+57) 601 2942888 Ext: 452

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Ethics Line:

Emails: lineaetica@encajes.com - protecciondedatos@encajes.com

Spanish anonymous form:  https://forms.gle/6bZ9BEwCypWZZDkF9

English anonymous form: https://forms.gle/GcDWPdVTv9hJaL1T9

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Reports may be submitted confidentially and, if necessary, anonymously, through the Company’s internal channels. All reports will be handled under principles of confidentiality, impartiality, due process, and whistleblower protection, with zero tolerance for retaliation.​

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Training and Awareness

Encajes S.A. Colombia promotes a culture of integrity and compliance through periodic training and dissemination programs of the PTEE, aimed at employees, directors, and, where applicable, third parties.​

Training covers, among other topics, corruption and bribery risks, conflicts of interest, ethical duties, reporting channels, and responsibilities related to the PTEE, and is coordinated by the Compliance Officer, with proper record-keeping and follow-up in accordance with internal guidelines.

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Consequences of Non-Compliance

Failure to comply with the provisions of the Business Transparency and Ethics Program (PTEE), the Code of Conduct, the Code of Ethics and Transparency, and other associated policies will result in the adoption of applicable disciplinary, contractual, and legal measures.​

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These consequences may include internal sanctions, termination of employment or contractual relationships, reporting to competent authorities, and other actions provided for under applicable regulations, without prejudice to any civil, administrative, or criminal liabilities that may arise.