Transparency

Ethical standards of behavior are the basis for the creation of value in Grupo Energía Bogotá, as regards actions taken by its collaborators and the manner in which they generate trust between the different stakeholders with whom the company works.

Within the frame of Macro Policy of Corporate Responsibility and the Good Governance Code, and the new agreement with the commitments derived from the company's adherence to UN Global Compact, this section establishes the Anti-fraud and Anti-corruption Policies, the Ethics Code and the Ethics channel of Grupo Energía Bogotá.

  • Internal Auditing Statute
  • Policy of Internal Control and Fraud and Corruption Prevention

    The policy’s objectives are:

    • To adopt and maintain an Internal Control System that allows the Group’s companies to achieve their objectives, management and results.
    • To promote and consolidate an ethical culture based on corporate values.
    • To establish guidelines that allow identifying, detecting, assessing, mitigating, monitoring, researching, preventing and correcting risks of fraud and corruption.

    Grupo Energía Bogotá (GEB) is committed to a policy that describes, among other aspects:

    • To comply with and respect the regulations applicable to all companies that are part of GEB.
    • To assume a “Zero Tolerance” position to fraud, money laundering, terrorist financing and corruption.
    • To promote a culture of transparency to strengthen the Internal Control System.

    Those responsible for the Internal Control System’s proper functioning and compliance with guidelines for preventing fraud, corruption, money laundering and terrorist financing, are:

    • Managers
    • Directors
    • Employees
    • Shareholders
    • Internal control bodies
    • Contractors
    • Customers, as the case may be

    In order to ensure compliance and preserve the Internal Control System’s integrity in GEB companies, the companies apply the “Three Lines of Defense” model, according to the standard promoted by the European Confederation of Institutes of Internal Auditing (ECIIA), in which the responsibilities within the Internal Control System are defined as follows:

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    The first line of defense: senior management is controlled through the owners of processes, who establish their own control activities (Self-control) to mitigate their risks and maintain effective internal control.

    Second line of defense: oversight and monitoring functions. This line ensures the first line of defense is operating as designed.

    Third line of defense: corresponds to independent assurance by means of internal auditing activities.

  • Prevention of money laundering activities and terrorism financing

    Complying with External Deed 060 of 2008 issued by the Colombian Financial Superintendence, which establishes obligations to securities' issuers who are not "subjected" to inspection and surveillance from the former, as regards the prevention and control of money laundering activities and terrorist financing, the Board of Directors of Grupo Energía Bogotá approved the following manual: “Comprehensive System for the Prevention and Control of Money Laundering and Terrorist Financing Activities" (SIPLA- for its Spanish acronym), as evidenced in Minute No. 1454 of 24 November 2009, and appointed the company's Statutory Auditor as Compliance Official.

    EEB's SIPLA manual contains policies, controls and procedures adopted by the company to prevent money laundering and terrorist financing activities. 

  • Ethics and Conduct Code

    The Ethics and Conduct Codes define the rules that govern the relationships Grupo Energía Bogotá and its companies have with administrators, collaborators, suppliers, contractors, customer and in general all stakeholders, as well as their behavior within the market in which they perform their activities. 

    Furthermore, the Code establishes and puts in place general behavior principles that administrators and collaborators from the companies of Grupo Energía de Bogotá must adhere to in order to adjust corporate values, the obligations acquired in labor relationships and ethical principles.

    Enforceability

    The Ethics and Conduct Codes apply to all companies that make up Grupo Energía Bogotá and it is binding upon its administrators and collaborators.

    Suppliers and contractors must also behave in accordance to the Code, in the performance of their chores under contracts, agreements, purchase or service orders or any other similar mechanism.

    By signing the Ethics and Conduct Agreement, administrators and collaborators of the Group commit to fulfill and adhere to the standards and guidelines contained therein. Signing of this Agreement is perfected when collaborators execute their work contract with any of the companies of Grupo Energía Bogotá, and an update adhesion to the Code is performed annually.

    Our Corporate Values

    Corporate values that guide the ethics culture of Grupo Energía Bogotá and frame the actions of its administrators and collaborators in their relationships with stakeholders and compliance with their responsibilities, are:

    • The achievement of individual and collective results.
    • Change and innovation
    • Human development
    • Transparency
    • Respect
    • Justice
    • Excellence
    • Integrity

    Conflict of Interests

    Group administrators and collaborators will face a conflict of interest event when, in the performance of their activities or responsibilities, their integrity and judgement may be influenced by the possibility of having to choose between the interests of the company, their own interests or the interest of a third party.

    Following, find some examples of situations that may give rise to conflict of interests. 

    • Direct or indirect work relationship
    • Management of presents, gifts and invitations
    • Participating in transactions of Grupo Energía Bogotá or its companies
    • Participation in contracting processes
  • Ethics Channel

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    The Ethics Channel is the only valid and official means to receive reports related to fraud, corruption, wrongful or illegal behaviors, consultation and ethics dilemma. 

    All reports received are analyzed in accordance with that established in the Ethics Channel Manual, with which it guarantees, among others, the following:

    • The identity of the reporting individual, with the information and evidences supplied in the report, which will be maintained as confidential, maintaining total discretion.
    • There will be no reprisals against administrators, collaborators or third parties that report fraud or corruption events or that make consultations on ethical dilemmas.

    Upon completing a report, the user will be assigned a user name and password, which will allow him/her to do his/her own follow-up.

    Report

    If you are interested in making a report in the Ethics Channel, you have the following alternatives, managed by a third independent party that ensures confidentiality as regards management of the information provided:

    The activities of conveying or disclosing ungrounded rumors, submitting reports or supplying information that are deliberately false or misleading will not be subject to review or follow-up.