This Is How We Lead
Ethics and Transparency
We practice ethics and transparency, generating the best alliances of mutual trust with our different Stakeholders.
GRI (103-1, 102-16) At Celsia, we work actively to implement the best practices in ethics, transparency and business conduct, which are part of our culture, of our DNA. Our commitment to integrity is permanent and is the fundamental element that guides our actions, both in our personal lives and in the business environment, with respect to all our Stakeholders.
We are convinced that ethics, transparency and integrity are essential to build trust and add value to our business, Shareholders and society in a responsible manner; for this reason, we live these principles and integrate them into our culture, the operation, processes and the Organization’s strategy.
Our Management
GRI (103-2) Our guidelines and directives in Corporate Governance, ethics, transparency, competition and anti-corruption are primarily found in the Bylaws, Codes of Good Governance and Business Conduct and in some of Company policies, such as Fraud, Bribery and Corruption Risk-Management Policy and the Competition Policy.
Code of Conduct
DJSI (1.4.1, 1.4.3) GRI (102-16, 102-17) C-CDC1 This is a guide to behavior that complements our criteria and common sense, to help us adopt behaviors that tend to maintain our positive image, and responsibly foster the generation of value. There we can find mechanisms to confidentially report irregularities and promote appropriate environmental, health and safety practices. This Code is essential to prevent:
- Corruption and bribery.
- Discrimination.
- Anti-competitive practices.
- The improper use of privileged information.
The topics covered by our Code of Conduct are:
- Denouncing irregularities.
- Environment, health and safety.
- Money laundering and/or the use of privileged information.
- Anti-trust/anti-competitive practices.
- Conflict of interest.
- Confidentiality of information.
- Discrimination.
- Corruption and bribery.
To ensure the effective implementation of our Code of Conduct, we have mechanisms and procedures, such as:
- Dedicated help desks, focal points, mediator and hotlines.
- The Compliance System is certified, audited and verified by an independent third party.
- There are disciplinary actions in case of violation of the Code; in other words, warnings, dismissals, a Zero-Tolerance Policy.
- Employee performance-evaluation systems integrate compliance with Codes of Conduct.
- Compliance is linked to employee remuneration.
- Responsibilities, accountability and reporting lines are systematically defined in all the divisions and companies of the Argos Business Group.
DJSI (1.4.2) GRI (205-2) Our Code of Conduct covers 100% of our employees, contractors and suppliers, who accept in writing its content and receive training in it. The Code also covers our affiliates and Joint Ventures.
DJSI (1.4.2) GRI (205-2) In the last three years, our suppliers and Joint Ventures were 100% trained and informed about our Code of Conduct. In February 2022, the dissemination of The Power of Your Decision with Contractors began.
DJSI (1.4.7) GRI (102-17, 205-3) We publicly report that there were no violations of our Codes of Conduct/Ethics during our reporting period.
Anti-Corruption Policy
At Celsia, we have a Fraud, Bribery and Corruption Risk-Management Policy, which provides clear guidelines to prevent and sanction bribes of any kind and which covers bribery issues in contract payments (including kickbacks) and soft-dollar policies.
Significant Risks Related to Anti-Corruption
GRI (205-1) All our processes have been evaluated against corruption risks, since the review of compliance risks – including corruption – is carried out across the Organization. Other risks reviewed were primarily conflicts of interest, misappropriation of assets and fraud.
DJSI (1.4.6) GRI (205-3) At Celsia, during the last four years, there have been no confirmed cases of corruption or bribery, nor have there been on-going investigations related to these two aspects involving the Company.
DJSI (1.4.5) GRI (206-1) In the last four years, Celsia has not been involved in investigations related to anti-competitive practices, nor have there been fines or anti-competitive agreements in the Organization.
Anti-Corruption Training
Employees trained in anti-corruption
GRI (205-2) All our Members of the Board of Directors have been informed and trained on the Organization’s policies and procedures to fight corruption.
Transparency Hotline
The Ethics Hotline
DJSI (1.4.4) GRI (102-16, 102-17) At our Transparency Hotline, people can personally or anonymously report incorrect acts or violations of the policies established in the Code of Business Conduct. This line is managed by an independent third party and has the required confidentiality.
The Organization has Transparency Hotlines in each country where it operates:
- Colombia: (+57) 01 – 8000 – 123 – 420
- Panama: (+507) 00 – 800 – 226 – 2591 and (+507) 832 – 7907
- Costa Rica: (+506) 4000 – 1941
- The email is the same for all the countries: Celsia@lineatransparencia.com
Main results
GRI (103-3)
We participated in the Collective Action on Ethics in the electricity sector, of which we have been a member for more than five years. Noteworthy last year was the training in good practices in contracting and anti-corruption, the formation of the Competition Committee, the definition of the protocol of good competition practices in the sector and participation in the ANDI Human Rights Committee.
We updated the Fraud, Bribery and Corruption Risk-Prevention Policy, in order to strengthen the obligations of third parties associated with the aforementioned risks, close gaps in best practices and other changes to give greater clarity to the policy.
We had the participation of Berkeley Professor Ernesto Dal Bo in our course, where we were able to deliver important reflections on autonomy, integrity, the use of resources and decision making based on our cultural pillars.
We had the participation of Berkeley Professor Ernesto Dal Bo in our course, where we were able to deliver important reflections on autonomy, integrity, the use of resources and decision making based on our cultural pillars.
We defined 100% of the action plans and controls against the most-relevant risks in terms of compliance. The employees and directors filled out the Annual Declaration of Potential Sources of Conflicts of Interest and the Declaration of Assets and Income, the latter addressed to Senior Management and to the roles that have some type of special attribution.
New Challenges
GRI (103-2)
These are our short-, medium- and long-term challenges:
(0 to 2 years)
- Strengthen our campaigns and control to prevent the risks of fraud, corruption, money laundering and the financing of terrorism.
- Continue strengthening our culture of ethics and compliance in the Organization’s DNA.
- Active participation of senior management in corporate ethics and transparency programs.transparency programs.
(3 to 5 years)
- Continue searching for strategies that allow ethics and transparency to be considered as factors for the Organization’s sustainability.
(6 or more years)
- Carry out the permanent review of the Organization’s policies and codes, in order to keep them updated and adjusted to the best practices in terms of Good Corporate Governance, compliance and the Law.
Glossary
Anti-Competitive Practices: Business practices that prevent free competition; that is, the possibility for economic agents to effectively participate in a market.
Corporate Bylaws: The internal rules governing the Company’s operation and governance; they are approved by the General Shareholders’ Assembly.
Fraud, Bribery and Corruption Risk-Management Policy: Parameters in the development of the Code of Business Conduct to implement a system for risk management, in order to establish control measures aimed at preventing their occurrence.
