PTEE Politics


The Board of Directors and Senior Management of Finart S.A.S. express the responsibility they have to promote ethical conduct among Collaborators, Members of the Board of Directors, Shareholders, Clients, Suppliers, Contractors, Strategic Allies and Third Parties that interact with it (hereinafter Counterparts).

The purpose of the company is to promote in the Anti-Bribery and Anti-Corruption Policy its commitment to zero tolerance for any conduct that is considered bribery or corruption, reinforcing the values, standards and principles established in the Code of Ethics, which establishes the obligation to always act in accordance with honest and ethical manner in all our activities, as well as compliance with all current and future regulations that regulate
these issues.

The implementation of this Policy seeks to meet the following objectives:

A. Prevent damage to the image and reputation of the company through the adoption and compliance with provisions that prohibit any form of transnational bribery or other forms of corruption.

B. Strengthen the corporate culture based on ethical conduct and the absolute rejection of transnational bribery and any other form of corruption in accordance with the provisions of our Code of Ethics.

C. Establish the company’s guidelines to identify, measure, control, monitor, detect, investigate and correct situations of bribery and corruption that could arise against the company, promoting the establishment of a culture of compliance, safeguarding the company’s reputation and extolling the values incorporated in the Code of Ethics.

Estos lineamientos están diseñados para servir de guía en la actuación de todas sus Contrapartes, en función del cumplimiento de los estándares para la prevención y control del riesgo de soborno y corrupción adoptados por la compañía.

These guidelines are designed to guide the actions of all its Counterparts, based on compliance with the standards for the prevention and control of the risk of bribery and corruption adopted by the company.

The company’s strategy for the fight against bribery and corruption includes, among other related elements and systems, the Transparency and Business Ethics Program (PTEE),
the Code of Ethics, the System of Internal Control and the ML/TF/FPADM Comprehensive Risk Self-Control and Management System – (SAGRILAFT).


This anti-bribery and anti-corruption policy for international business and transactions applies to all processes, channels and procedures of Finart S.A.S. This means that it applies to end customers, suppliers, shareholders, members of the Board of Directors, employees and other counterparties according to the communication plan organized for this purpose.

Compliance with this Policy is mandatory, as are all related procedures that are duly communicated to the Counterparts.


a. Compliance Audit: It is the systematic, critical and periodic review regarding the proper implementation and execution of the PTEE

b. C/ST: Acronym used by the Superintendence of Companies of Colombia to refer to Corruption and Transnational Bribery.

c. Counterparts: They are the natural or legal persons with whom the company has business, contractual or legal ties of any kind and that includes Members of the Board of Directors, Shareholders, Clients, Suppliers, Contractors, Strategic Allies and Third Parties that interact with the company. Company.

d. Contractor: Refers, in the context of a business or transaction, to any third party that provides services to Finart S.A.S. or that has a contractual legal relationship of any nature with it. The Contractors may include, among others, suppliers, intermediaries, agents, distributors, advisors, consultants and persons who are parties to collaboration contracts, temporary unions or consortiums, or joint ventures with Finart S.A.S.

e. Corruption: These are all conducts aimed at a company benefiting, or seeking a benefit or interest, or being used as a means of committing crimes against public administration or
public or in the commission of conduct of Transnational Bribery.

An act of corruption is understood as criminal conduct listed in the chapters on crimes against the public administration, the environment, the economic and social order, financing of terrorism and organized crime groups, administration of resources related to terrorist activities and crime. organized in the Colombian Penal Code, those enshrined in Laws 1474 of 2011 and 2195 of 2022, electoral crimes or any punishable conduct related to public property, which have been carried out.

f. Ethics: It is the set of principles, values, customs and rules of conduct, acquired, assimilated and practiced in a strictly rational or conscious way. It corresponds to the free and conscious exercise of reason to justify our actions from the point of view of good and evil. Ethics is universal and objective.

g. Facilitation Payments: Also called “gratuities” or “tips,” these are small payments made to secure or expedite the course of a routine action or action necessary for the provider to
have a legal or other right. Facilitation payments are a form of bribery, for which it is found The execution of said payments is totally prohibited and each Collaborator is obliged to report said situation, to eliminate all types of legal and reputational risk that may arise from it.

h. Transparency and Business Ethics Program (PTEE): It is the document that includes the Compliance Policy, the specific procedures in charge of the Compliance Officer, aimed
at putting the Compliance Policies into operation, in order to identify, detect, prevent, manage and mitigate the risks of Transnational Bribery, as well as other risks related to any act of corruption that may affect a Legal Entity.

i. Responsible PTEE: They are the Collaborators who have within their functions to collaborate with the identification of bribery and corruption risks in each of the company’s areas.

j. Bribery: is the act of offering, promising, or giving any value in money or in kind (entertainment, gifts, products and services) in order to obtain or achieve an inappropriate benefit or advantage in favor of oneself or a third party.

k. Transnational Bribery: In accordance with article 19 of Law 2195 of 2022, this crime is committed by legal persons who, through one or more: (i) employees, (ii) contractors, (iii) administrators, or (iv) associates , own or of any subordinate legal entity give, offer, or promise, to a server foreign public, directly or indirectly: (i) sums of money, (ii) any object of pecuniary value or
(iii) other benefit or utility, in exchange for the foreign public servant; perform, omit, or delay, any act related to the exercise of their functions and in relation to an international business or transaction.


Finart S.A.S. (hereinafter the company), based on its organizational culture and corporate values, establishes the guidelines and directives that must be followed by Collaborators,
Members of the Board of Directors, Shareholders, Clients, Suppliers, Contractors, Strategic Allies and other Third Parties related to the company, in terms of managing the risk of transnational bribery and corruption.

  • The company does not promote, accept, or cover up acts framed within the concepts of transnational bribery and any other form of corruption in any of its business relationships.

  • The company carries out its activities in compliance with applicable laws and following its moral and ethical principles.

  • The company has Policies, Procedures and internal regulations that regulate contracts, operations and local or international transactions, which are mandatory.

  • The company expresses its position of zero tolerance against transnational bribery and corruption, in any form or type, and promulgates its decision to take all necessary measures to combat them.

  • The company promotes and establishes within its organization and with its Counterparts, an anti-bribery and anti-corruption institutional culture.

  • The company is an organization committed to the sustainability of its operations, investments and businesses. Therefore, the company has guidelines for the prevention
    and resolution of conflicts of interest, rules of conduct in order to prevent the promotion of any form of bribery and
    corruption and rules of conduct to properly manage the giving and receiving of gifts, contained in its Code of Ethics. Said guidelines and rules of conduct are understood to be
    incorporated into the “Procedures Manual of the Transparency and Business Ethics Program” (AN-02962) and the additional annexed documents derived from said manual “Legal Aspects of Bribery and Corruption Transparency and Business Ethics Program – PTEE” (AN-02963), “General Risk Theory” (AN-02964), “Conceptual Aspects of Bribery and Corruption Transparency and Business Ethics Program – PTEE” (AN-02965), and “Methodology of identification, measurement, control and monitoring of Risk Factors ” (AN02966)
  • The company generates an environment of transparency, maintaining the appropriate channels to favor the communication of said matters within the company and coordinating the set of actions necessary to prevent, detect and respond to possible situations of transnational bribery and
    any other form of corruption.

  • The company prioritizes activities to prevent transnational bribery and any other form of corruption, without reducing efforts aimed at detecting and correcting situations related to
    the same scourges.

  • The company evaluates the alleged indications of transnational bribery and any other form of corruption, under the principles of confidentiality, integrity, transparency and

  • The company manages in a timely manner all reports of acts of transnational bribery or any other form of corruption, regardless of their amount or personnel involved, guaranteeing confidentiality, objectivity, respect and transparency. No collaborator will suffer any type of rejection or any other negative consequence for preventing, rejecting or reporting an act of transnational bribery or any other form of corruption.
    It is the responsibility of senior managers to inform all employees under their direction of the rules, procedures and protocols that must be observed to prevent and control the risk
    of transnational bribery and any other form of corruption and apply the necessary controls to prevent the company and/or its collaborators facilitate activities of this nature.
  • The company does not tolerate that its Counterparts achieve economic, commercial or any other results, in exchange for violating the law or acting dishonestly.

  • The company strictly prohibits its Counterparties from making or accepting facilitation payments, understood as those payments made or received to ensure or expedite the course of a routine action or actions necessary for the counterparty to have a legal or other right.

  • The company establishes demanding requirements for the linking of Board of Directors Members, Shareholders, Collaborators, Clients, Suppliers, Contractors, Strategic Allies
    and other Third Parties with whom it interacts and rejects the establishment or renewal of a contractual relationship, which does not comply with the requirements demanded by the Law and the internal regulations of the company.

  • The company will not maintain links with counterparties that have been convicted of criminal activities related to foreign bribery or any other form of corruption.

  • All information derived from the application of this policy is subject to confidentiality, which means that it can only be known by the competent judicial or administrative authorities.

  • Therefore, the company commits the Members of the Board of Directors, Collaborators, Clients, Suppliers, Contractors, Strategic Allies and Third Parties related to the company,
    to keep absolute confidentiality regarding the information that is prepared and distributed in relation to the PTEE, especially that which has been reported internally or made available to the competent authorities, unless required by said authorities.

  • Likewise, all the aforementioned have the obligation to safeguard and limit the use of the same to the purposes strictly established in the Law and in this policy, among which is that of meeting the information requirements of the Attorney General’s Office. , competent authorities or control entities.

  • The company prohibits bribery of public or private officials, domestic or foreign, whether through third parties or through intermediaries, in exchange for a prohibited benefit or improper advantage.

  • The company promotes within it awareness of best practices related to the prevention and control of the risk of transnational bribery and any other form of corruption.

  • The company has a confidential and anonymous means of reporting called the Attention and Report Line so that all its Counterparts report dishonest conduct by our Collaborators
    or related Third Parties that generate breaches of the Code of Ethics or acts of transnational bribery or any other forms of corruption that affect or harm our interests, which are managed in a timely manner and that, if applicable, legal actions will be initiated respective.

  • The linking of collaborators and third parties must be carried out in accordance with the provisions of the existing procedures in the company. The hiring of third parties that have
    contact or negotiations with public officials must have an agreement and/or written statement that specifies the knowledge and compliance with this policy established by the
    company, as well as the legal regulations that cover the risk of transnational bribery and any other form of corruption.
  • The company refrains from making contributions to candidates for public office, political parties, political movements or significant groups of citizens.

  • The company has the organizational structure, economic, human and technological resources and will implement training and dissemination activities necessary to strengthen
    the culture of prevention and control regarding these risks in operations, businesses or transactions.
    international it performs.

  • The PTEE requires supervision and monitoring of the risks of transnational bribery and any other form of corruption, periodically evaluating the potential risks of the processes
    and sub-processes to ensure that the established control activities protect the company from corrupt actions.

  • The company has a system of sanctions established in the Internal Labor Regulations, which regulates the consequences generated by the serious violation by the worker of contractual or regulatory obligations, as is the case of the PTEE.

  • The company may report to the competent authorities the acts of transnational bribery or any other form of corruption identified in the investigations or previous verification tasks.

  • Non-compliance: The company considers a serious fault and a non-compliance with the PTEE Model, the omission or non-compliance with the Code of Ethics, the Internal Labor Regulations, the Employment Contract and any of the controls, information management or other guidelines defined here for the prevention, detection and control of activities provided for in the PTEE in international business and