Part of the commitments established in the policy is following and respecting regulations applicable to companies that form part of the GEB, the “Zero Tolerance” policy to fraud, money laundering and terrorism financing and corruption. This is in addition to taking the components of the Control System aligned with the “COSO” model as key principles and applying the
Three Lines of Defense Model
According to the standard promoted by the European Confederation of Institutes of Internal Auditing (ECIIA) which defines responsibilities regarding the Internal Control System. In this regard, GEB has implemented a control architecture
As a result of this separation of duties, the Corporate Compliance Department was created, which is part of the Legal and Compliance VP and reports directly to the Audit and Risk Committee of the Board of Directors of GEB.
The objective of the Compliance Department is to formulate, implement and control the policies on transparency and compliance within the Group through the establishment of monitoring and control mechanisms and to promote a corporate culture of probity in its activities and relations with all stakeholders
The construction of the Ethics and Compliance Program was based on international standards and regulatory requirements, seeking to prevent the materialization of the risks of money laundering and terrorism financing, fraud and corruption, through the following components:
It is the document through which TGI establishes and develops the principles of behavior and the rules of action that govern its administrators and collaborators and those of its subsidiaries, based on its corporate values: transparency, respect, integrity and fairness. Through the Code, TGI declares its commitment to a "zero tolerance" policy against fraud, money laundering, financing of terrorism and corruption.
Ethical Channel: Know everything about our Ethical Channel here
In the face of a potential conflict of interest, the most important thing is that it be reported as soon as it becomes known and before any decision is made, in order to manage it.
It is the Comprehensive System for the Prevention of Asset Laundering and Financing of Terrorism that TGI has implemented.
It is made up of several elements, among them the warning signs that are behaviors or characteristics of certain operations or persons, which could lead to the detection of a suspicious operation of money laundering or financing of terrorism.
These signs must be reported immediately. Another important element is the verification of interest groups in control lists, for which the official template must be filled out and sent by mail:
TGI applies the provisions of Law 1712 of 2014, which regulates the right of access to public information and the procedures for the exercise and guarantee of the right and the exceptions to the disclosure of information.
TGI complies with Law 1474 of 2011, through which it seeks to strengthen the mechanisms of prevention, investigation and punishment of acts of corruption and the effectiveness of the control of public management. Annually, TGI prepares, executes and publishes the Anticorruption and Citizen Services plan in compliance with this law.
TGI in compliance with Law 1581 of 2012, protects the constitutional right that all people have to know, update and rectify the information that has been collected about them in databases or files.
TGI abides by the provisions of Law 1778 of 2016, which is responsible for dictating the rules on the liability of legal persons for acts of transnational corruption abroad.
Coordination of the timely and adequate attention to the requirements that come from the surveillance and control entities.
The entire GEB compliance program is supported by strong corporate governance, a culture of integrity, policies, procedures and methodologies, permanent communication and training, monitoring and information systems.