What is it?

 

Our Unethical Behavior Allegation System is an instrument through which any unethical behaviors are reported in a private, secure, easy-to-use and with the option to do it anonymously. The system is operated by a third independent party called EthicsGlobal which is the frontrunner on allegation management and reports in the Country.

The integrity of an organization has a direct effect on its reputation and success. When everyone shows their integrity, our customers, clients, suppliers, shareholders and our competitors see us as an honest and fair company.

Our reputation grows positively. Sometimes acting with integrity is not always an easy task and the right way on going about things is not always clear. Sometimes is complicated to look at all laws and regulations that apply to us, as well as procedures and policies.

Regardless, behaving with integrity is not complicated. If you have any questions on the proper manner to behave, or if a person is not taking action correctly in terms of the integrity that you have in mind, you have the responsibility to speak up and you have the right to rely on a safe, easy, private and in your case, anonymous methods to do so.

Your director/manager or immediate supervisor becomes a viable solution for this matter, but if you think that is not the proper, nor ethical way in doing so, or if you tried speaking up and you weren’t heard, you can use our Unethical Behavior Allegation System tool to report it or to obtain even more information on how the system works.

Our organization examines each and every single case out there and if necessary, makes a complete investigation and penalizes or implements correctional measures.

If you wish to do so, you can provide your name and contact information, but identification is not necessary in other cases and you can do it anonymously.

The company expects every employee to fulfill and help maintain our values and code of conduct, whilst doing the right thing, and complying with policies of the company, as well as laws, rules and regulations anywhere and everywhere we operate.

 

You can provide your name and contact information if you like, but identification is not necessary in other cases and you can do that in an anonymous manner.

The company expects that every employee fulfills and helps maintain our values in honoring the code of ethics whilst doing the right thing, fulfilling the norms and policies of the company, as well as respecting the laws, rules and regulations anywhere and everywhere we operate.


OUR RESPONSIBILITY
  • Ensure freedom of making questions to all our members.
  • Provide tools and stations for query and complaint reception in easy, safe, confidential and anonymous ways without any fear of repercussion or vengeance.
  • Investigate, solve and in your case, punish all received reports.

YOUR RESPONSIBILITY
  • If you are a witness or have any type of knowledge of any inappropriate behavior, report it so that you don’t become an accomplice of this action.
  • Ask yourself about your personal integrity.
  • Use complaint stations provided by the company.
  • Provide all possible information and in your case, proof of every case for a proper investigation.
  • Actively monitor reports to become aware of the status and corrective measures of the investigation, and in your case add any information, proof or relapses.


Procedure


What is it?

  • It’s a service provided by a third party called EthicsGlobal that specializes on complaints management in an easy, safe and confidential way. Furthermore, it can be done anonymously or providing your personal information.


Who to contact?

  • Your director/manager or supervisor

  • Human Resources

  • Ethic Committee

  • Unethical Behavior Allegation System


How?

How does it work?

Through our toll free number 1 888 876 7548

  • Complainant should have all the information concerning the case on hand, as well as any proof material he/she may have, while answering the following questions: Who? When? Where? How?

  • Complainant calls our toll free number.

  • Connects with an advisor who will listen while making a series of relevant questions

  • The advisor will then give some alternatives for the delivery of proof.

  • Complainant then receives a monitor code, which is very important to keep for future references.


Through Internet Assistance

  • Complainant should try to have all the information related to the case on hand while answering the following questions: Who? When? Where? How?

  • Complainant enters the form and the Dynamic Internet Assistant that will lead you by the hand while making relevant questions related to the information that is provided.

  • Upon completing the complaint, the system will hand a tracking code, which becomes very important to keep safe so the complaint can be monitored.


By Mobile App

  • Download the EthicsGlobal App  


Monitoring

By using the tracking code when the complaint was filed, the person can call the hotline at any time or submit it through the Unethical Behavior Allegation System in order to:

  • Know the status of the investigation.

  • Know the conclusion and corrective measures.

  • Contribute any additional information.

  • Inform any relapses on the allegation/complaint.

  • Attach elements of proof.




Frequently Asked


Will there be any retaliation for making an allegation or a question?

The Unethical Behavior Allegation System of EthicsGlobal guarantees anonymity to the complainant when making an allegation through any means available. Fear is understandable, especially when the situation being alleged becomes even more serious and closer in proximity. But the purpose of our interference is to guarantee the complainant that there is nothing to fear and that he or she will not be forced to give us any type of information that he or she does not desire to offer.


How can I monitor a complaint I have filed?

When you make a query or a complaint, you will be given a tracking code. You will need this information to follow the complaint status, receive an answer to your question or verify the status of the complaint that has already been made. We ask you to wait at least 5 or 6 labor days to follow up. Get in contact again with the hotline support in order to:

  • Know if any additional information is needed to process your query or complaint.

  • Provide any new information related to your complaint.

  • Review any updates or its resolution.

  • Understand the corrective measures or its final resolution when the investigation is completed.


After making a complaint, will I be informed of its resolution?

The company will only indicate the status of the investigation to the complainant. The content and the result of the investigation are confidential, so in those terms the company reserves the right to provide or not the outcome to the complainants.


What kind of information or data are required to use a complaint line?

The complaint line can be used to submit an allegation or to monitor a previous complaint. When you submit a complaint, you will be asked to facilitate information regarding the incident in the most detailed manner. To perform a better investigation towards your complaint, it is advised to:

  • Provide complete names and job positions of those involved and give out the names of the people that have knowledge of the incidents (Witnesses).

  • Describe the place and time of the incident.

  • If possible, get a hand of elements that might serve as evidence.

  • Write a brief essay explaining how the incidents occurred in detail.


How much time will it take to solve a complaint already submitted?

EthicsGlobal sends the information to the Ethics Committee or the corresponding Ethic Officer within a time span of 24 hours after the complaint is submitted. The company will be the one to determine the time needed for investigation purposes and resolution of the complaints.


When should I use the Ethics Line?

When you know, when informed or when you are involved in a situation where it does not conflict with the company’s Code of Conduct and, in addition, when there are concerns, an ethical or a fulfillment issue that you’d prefer a third party to take over and manage instead of treating the situation directly or with another coworker. The decision is completely voluntary when to use the Ethics Line.


What happens if I want to provide more information even after the complaint has been submitted?

At any given moment, a complainant can access the report line in order to supply new information or inform of any recidivism for that matter. With the tracking code in hand, the new gathered data could be incorporated whenever you want, if the investigation remains ongoing.

Why file a complaint?

Because internal crimes or offences gravely affect the heritage of the company, and thus hamper the employees sooner or later. As an example, a single fraud might cause casualties that force the company to reduce its number of employees, its salaries or other benefits.


In most severe cases, these types of crimes have led entire companies into bankruptcy. Helping to avoid non-ethical behaviors is, essentially, to protect the security of your own job and those of your colleagues.

It also improves working environments whilst reporting behaviors of those who impinge against the integrity and well-being of all organization members.


What benefits provides the Ethics Line?

It develops and strengthens an ethics culture, improves working environments and fosters the use of irregular conduct reports through safe, viable, factual and independent methods, being an effective and exemplary service delivery the prime target for those who use this system.


What happens if I see or become a witness of a Code of Conduct breach and I don’t file a complaint?

Every member of the organization is obliged to report those breaches related to the Code of Conduct of the company that would affect the organization and its members. If you are aware or become a witness of any important infringement and do not report it, when the organization becomes aware of it, then you might make yourself creditor of a severe sanction from the organization itself.



What can be reported?

  • Fraud

  • Robbery

  • Corruption

  • Bribery

  • Confilct of interests between the clients, suppliers or colleagues

  • Authority abuse

  • Counterfeit seles, operations and payments

  • Deceiving an auditor or a supervisor

  • Retrieve information from the company

  • Sexual harassment.

  • Intimidation or Extortion.

  • Harassment

  • Inmoral conducts against good morals.

  • Damaging a person’s reputation

  • Bullying

  • Excessive use of work time for personal matters

  • Hiring, remunerate or compensate without authorization


  • Hiring, remuneration, compensation or promote a person due to personal relationships

  • Un-authorized sales

  • Document alteration

  • Purchases or acquisition of products and/or services in detriment of the company or due to personal relationships

  • Use of the company’s confidential information for personal benefitsDisclose confidential information in detriment of the interests and prestige of the company

  • Excessive bureaucracy in detriment of productivity

  • Bottlenecks

  • Consume, possess, distribute or sell any type of illegal drugs

  • Drinking alcohol or doing drugs within the company or during working hours

  • Get to work under the influences of drugs or alcohol

  • Any situation that endangers the safety or health of employees, visitors or the general public

  • Any situation that harms or endangers the working environment

  • Disobeying or failing to comply safety standards of the company

Service operated by:

 

Reporting methods