Ethics and Compliance

We work with transparency, respect, integrity and fairness

At TGI, we act in accordance with our corporate values, which leverage compliance with the business strategy and allow us to honor our commitments to our stakeholders.

Why is this important?

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The Control Architecture and the mechanisms and tools of the Corporate Governance that we follow at TGI provide us with all the inputs so that our decisions are informed, conscious and ethical.

According to the Internal Control and Prevention of Fraud and Corruption Policy, we are committed to promoting a transparency culture that integrates the different risk management systems of our organization. These are aimed at the identification, detection, evaluation, mitigation, monitoring, investigation, prevention and correction of behaviors related to fraud, money laundering, financing of terrorism and corruption, as well as the strengthening of the Internal Control System.

How do we manage it?

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Our Ethics and Compliance Program aims to guarantee an ethical and transparent approach in the management of business operations, for which we promote a culture of zero tolerance against fraud, money laundering, terrorist financing and corruption.

It includes the following components:

Code of Ethics.

Ethical Channel and Conflicts of Interest.

Sipla, Comprehensive System for the Prevention and Control of ML/ FT.

Law on transparency and access to public information.

Anticorruption and Citizen Service Plan.

Data Protection.

Transnational anti-bribery law.

Control entities.

Preventive legal strategy.

The Ethics and Compliance Program is managed by the Compliance Department, under the administrative responsibility of the Legal and Services Vice Presidency, and reports to the Audit and Risk Committee of the Board of Directors. Likewise, at TGI we have an Ethics and Compliance Committee that aims to contribute to the strengthening of the company's ethical culture and verify the implementation and monitoring of the program of the same name.

Furthermore, this program is subject to audits, which are carried out by the Internal Audit Management, directly or with the support of an independent third party.

Reports or inquiries to the Ethics Channel can be made through the telephone line 018000125470 or the email canaleticogeb@pwc.com; or by directly entering the Ethics Channel.

Our Code of Ethics responds to a participatory exercise of the collaborators and was approved by the GEB and TGI Presidency committees. Furthermore, it is permanently disseminated among stakeholders through campaigns to strengthen the business ethics culture.

(102-17) At TGI, we also have an Ethical Channel, whereby our stakeholders can report any event or conduct related to alleged fraud and corruption, or unethical conduct, as well as consult on ethical dilemmas.

For the management of conflicts of interest, our collaborators can seek advice, first, with the direct report, with the Compliance Department or report them to the Ethics Channel, which is administered by a third party to guarantee independence.

What we achieved in 2020

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(205-1) 100% of our key processes were assessed for corruption risks.

In 2020, our "strengthening the culture of transparency and integrity through the dissemination of the concepts of control architecture and the ethics and compliance program" practice was selected to be part of the publication of good anti-corruption practices in Colombia, made by the Global Compact Red Colombia, Alliance for Integrity and UNODC.
We update the strategic risks of fraud and corruption, in accordance with GEB guidelines.
(205-2) Within the framework of the La Ética Nos Une campaign, we conducted training on the Control Architecture Model and the Ethics and Compliance Program, with the participation of 448 employees - a coverage of 98% - and we achieved the ownership of the concepts of 91% of trained collaborators.
(205-2) 100% of the members of the Board of Directors were informed of the content of the Ethics and Compliance Program through an interactive video.
We conducted the induction in the Ethics and Compliance Program to 100% of the workers who joined the company in 2020.
(205-2) 100% of suppliers registered in SAP Ariba (shared registry with GEB) have been informed about the Ethics and Compliance Program, 1,047 of them in 2020.
100% of the collaborators adhered to the Code of Ethics and Declaration of Conflicts of Interest.
(205-3) In 2020 we did not confirm any case of corruption in the company.
We adopted the verification procedures in control and accountability lists and attended the requirements of the Bogotá Comptroller's Office.
We met 100% of the requirements made by the control entities.
We participated in the Business Transparency Measurement (MTE), carried out by Transparencia por Colombia and aimed at improving transparency and anti-corruption standards to strengthen business management. According to the results, the level of risk of corruption is low for TGI.
(Own) (102-17) The Ethical Channel worked optimally in its different accesses to the website, email and by telephone. To see the balance of the Ethical Channel, you can refer to the Annexes of the statistics of the reports received.

See annexes

We trained 448 employees in the Control Architecture Model and the Ethics and Compliance Program.
We trained 448 employees in the Control Architecture Model and the Ethics and Compliance Program.
We trained 448 employees in the Control Architecture Model and the Ethics and Compliance Program.
We trained 448 employees in the Control Architecture Model and the Ethics and Compliance Program.

Challenges for 2021

In 2020, our “strengthening the culture of transparency and integrity through the dissemination of the concepts of control architecture and the ethics and compliance program” practice was selected to make part of the publication of good anti-corruption practices in  colombia, made by pacto global red colombia, alliance for integrity and unodc.

Strengthen the work of monitoring fraud and corruption risks and monitoring of the Ethics and Compliance Program.
Implement the new controls established in the strategic risks of fraud and corruption.