In accordance with the organization’s commitment to take the necessary measures to
prevent the crimes of Money Laundering (ML) and the Financing of Terrorism (TF), as well as the Proliferation of Weapons of Mass Destruction (FPADM) and, in turn, to have the
best practices in ethical and regulatory issues, the ML/TF/FPADM Comprehensive Risk Self-control and Management System (hereinafter SAGRILAFT) has been implemented in Finart S.A.S., in order to establish the necessary control measures, aimed at preventing the activities and operations of Finart S.A.S from being used as an instrument or being used as a means for the concealment, management, investment or use, in any way, of
money or other assets from criminal activities, or to try to give the appearance of legality to
transactions, operations and funds related to money laundering and its source crimes
and/or for the channeling of resources towards carrying out terrorist activities these or to
the proliferation of weapons of mass destruction.
This Policy sets out the main corporate guidelines that allow the identification, evaluation,
prevention and mitigation of ML/TF/FPADM risk and associated risks, in accordance with the code of ethics of Finart S.A.S, current legislation and international principles and
standards. . This policy is complemented by the guidelines and directives established in
the annex “Manual for compliance with the system of self-control and comprehensive risk management of money laundering, and financing of terrorism and financing of the
proliferation of weapons of mass destruction – SAGRILAFT Finart (S.A.S )” AN-02862
Define the general criteria for the prevention, detection and self-control of the risk of Money Laundering, the Financing of Terrorism and the Financing of the Proliferation of Weapons of Mass Destruction, which must be implemented by all Administrators, collaborators, representatives, suppliers, counterparts in general and other interested parties, in the activities, businesses, contracts and/or situations that may generate links or links with Finart S.A.S.
The foregoing, in order to protect and strengthen the corporate image of Finart S.A.S, and
protect its stakeholders, complying with the guidelines established by the Superintendence of Companies and for the exercise of specific controls, and thus prevent any/ s of the activities of Finart S.A.S is used for illicit purposes or establishes a link with third parties related to any of these illicit activities.
This ML/TF/FPADM Self-Control and Comprehensive Risk Management policy applies to
all processes, channels and procedures of the company Finart S.A.S. This means that it
applies to suppliers, shareholders, members of the Board of Directors, legal representatives, collaborators and other counterparties.
Compliance with this Policy is mandatory, as are all related procedures.
Counterparty: is any natural or legal person with whom the Company has commercial,
business, contractual or legal ties of any kind. Among others, the partners, employees,
customers, contractors and suppliers of Company Products are counterparties.
ML/TF/FPADM Risk Control: Implementation of policies, procedures, processes, practices
or other actions to minimize the risk of Money Laundering, the Financing of Terrorism and
the Proliferation of Weapons of Mass Destruction in the operations, businesses and Finart
Financing of the Proliferation of Weapons of Mass Destruction or FPWMD: It is any act
that provides funds or uses financial services, in whole or in part, for the manufacture,
acquisition, possession, development, export, transfer of material, fractionation, transport,
transfer , deposit or dual use for illegitimate purposes in contravention of national laws or
international obligations, when the latter is applicable.
Financing of terrorism or TF: These are all those actions that are carried out to financially
support or finance terrorists or terrorist groups with goods or funds of legal and illegal
Money laundering or ML: These are all actions to hide or give the appearance of legality to
resources of illicit origin. It is a criminal conduct that is incurred when any person or company acquires, protects, invests, transports, transforms, guards or manages assets of illicit origin.
PEP: Means politically exposed persons, that is, they are public servants of any system of
nomenclature and job classification of the national and territorial public administration,
when in the positions they hold, they have functions in the area to which they belong or in Those of the job file that occupy, under their direct responsibility or by delegation, the general direction, formulation of institutional policies and adoption of plans, programs and projects, direct management of goods, money or State securities. These can be through spending management, public contracting, investment
project management, payments, liquidations, administration of movable and immovable
property. Also includes Foreign PEPs and PEPs of International Organizations
SAGRILAFT: It is the abbreviation for the ML/TF/FPADM Comprehensive Risk SelfControl and Management System. It is a set of appropriate and sufficient control measures, aimed at preventing Finart S.A.S from being used as an instrument for
Finart S.A.S, is committed, among others, to the prevention of ML/TF/FPADM risk, and
has defined mechanisms and tools for knowing its collaborators, suppliers and the market, as well as procedures that are transversal to the entire operation that allow the
construction of a culture of prevention and compliance with regulations, being aware of its
For this, Finart S.A.S promotes that the ML/TF/FPADM prevention policies that are
implemented are guided by international recommendations and good practices, especially
those issued by the International Financial Action Task Force -FATF- and by the Latin American Financial Action Task Force -GAFILAT, for which efforts will be focused on developing a culture of compliance and crime prevention.
The foundations of this policy have been built according to the criteria established in the
document “ABC of the Risk of Money Laundering, Financing of Terrorism and Financing of
Proliferation of Weapons of Mass Destruction SAGRILAFT Finart (S.A.S)” AN-02861
Therefore, Finart S.A.S, represented by its directors and collaborators, undertakes to:
(i) Design and implement the self-control and comprehensive risk management system for
ML/TF/FPADM, hereinafter SAGRILAFT, in accordance with the guidelines established by
the Superintendency of Companies
(ii) Establish risk management methodologies with the most appropriate control
mechanisms and their application to the identified ML/TF/FPADM Risk Factors, as well as
other possible associated risks, including their measurements.
(iii) Exercise vigilance regarding the risk profile and be in a position to detect Unusual
Operations and Suspicious Operations
(iv) Have procedures adjusted to the highest international standards and the current
national regulations of the operation for the linking of collaborators, clients and suppliers (counterparts).
(v) Design, implement and update the SAGRILAFT manual in such a way that Finart S.A.S
has the control mechanisms established to prevent Money Laundering, the Financing of
Terrorism and the Financing of the Proliferation of Weapons of Mass Destruction
(vi) Implement due diligence procedures for counterparties that allow knowing and
verifying the identity of these
(vii) Carry out enhanced due diligence procedures which implies advanced knowledge of
the counterparties and the origin of the assets received and must be applied to those that
may hold the designation of publicly or politically exposed person (PEP’s) and the located
in high-risk countries.
(viii) Monitor compliance with the policies by employees and design and implement a system for managing consequences for non-compliance with this policy and its procedures.
(ix) Monitor the training program and its effectiveness for the execution of the mechanisms
established for the prevention of ML/TF/FPDAM by all the collaborators of Finart S.A.S.
(x) All persons directly or indirectly linked to Finart S.A.S must comply with the provisions
of this policy and the SAGRILAFT Manual in accordance with the responsibilities assigned
in their functions, prioritizing them before the fulfillment of commercial goals or personal
All the information derived from the application of this policy will be subject to confidentiality, which means that it can only be known by the competent authorities and the people of the Company legally authorized to do so. Thus, all the collaborators of Finart S.A.S, have the obligation to safeguard and limit the use of it for the purposes strictly established in the Law and in this policy, among which is that of meeting the information
requirements of the competent authorities. or control entities.
For the Company, it will be a very serious offense on any front of the operation, the omission or breach of any of the controls, information management or other guidelines defined in this policy and its procedures for the prevention, detection and control of activities of Money Laundering, Financing of Terrorism and Financing of the proliferation of
weapons of mass destruction.