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SAGRILAFT Policy

OBJECTIVE

To establish a comprehensive framework for the prevention, detection, control, and reporting of Money Laundering, Terrorist Financing, and the Financing of the Proliferation of Weapons of Mass Destruction (ML/TF/FPWMD) in the Company's operations.

 

SCOPE

This policy applies to all operations, activities, and business relationships of the Company, including:

  • Clients: Individuals or legal entities acquiring goods or services from the Company.
  • Suppliers: Individuals or legal entities providing goods or services to the Company.
  • Intermediaries: Individuals or legal entities acting on behalf of or representing the Company.
  • Employees: All individuals working for the Company, regardless of position or level.
  • Third Parties: Any individual or legal entity having a business relationship with the Company.

 

GUIDELINES

In developing the Self-Control and Comprehensive Risk Management System for Money Laundering, Terrorist Financing, and the Financing of the Proliferation of Weapons of Mass Destruction (ML/TF/FPWMD), the Company declares the following:

  • Compliance with Applicable Regulations: The Company shall comply with the current regulations on ML/TF/FPWMD prevention, not only to contribute to the objectives of the State and fulfill the law but also to protect the Company's image and reputation.
  • Compliance Officer Role: The Company shall implement the Compliance Officer function and allocate the necessary human, technical, financial, and operational resources to fulfill its responsibilities effectively.
  • Due Diligence and Risk Assessment: The Company shall employ reasonable self-disclosure and verification mechanisms to avoid formalizing business or contractual relationships with individuals or legal entities and their ultimate beneficiaries who, based on objective evaluation and available evidence, present a high risk concerning the origin of funds, legality of operations, or possible ties to illegal or terrorist groups.
  • Client and Partner Knowledge Culture: The Company shall promote a culture of prevention and awareness regarding customers, suppliers, employees, and associates through training and other available means.
  • Counterparty Risk Analysis: The Company shall take reasonable measures to gain sufficient knowledge of its counterparties. If a natural or legal person does not provide enough information, an individual risk assessment will be conducted, considering:
    • The possibility of obtaining information from publicly available sources.
    • The specific risk level posed by the counterparty and the operation.
    • Mitigation measures provided by the counterparty, such as compliance statements and internal due diligence regarding its ultimate beneficiaries and relevant third parties.
  • Collaboration with Authorities: The Company shall provide requested information to authorities in investigations related to ML/TF/FPWMD.
  • Confidentiality and Integrity: All employees must manage company-related transaction information and SAGRILAFT documentation confidentially and with integrity. Employees cannot use this information for personal or third-party benefit, inside or outside the Company.
  • Reporting Obligations:
    • No employee may disclose details of transactions reported as suspicious or attempted to the Financial Information and Analysis Unit (UIAF). Only the Compliance Officer is authorized to report information to the UIAF and submit required reports to Company Management.
    • All employees must strictly follow the guidelines in the Self-Control and Comprehensive Risk Management System document.
    • Any employee aware of a potential crime in the course of their duties must report it to the Compliance Officer, without prejudice to fulfilling any legal obligation to report criminal activities.
    • Employees must inform the Compliance Officer, who will immediately report to the UIAF any relevant information about financial transactions that do not align with clients' and suppliers' economic activities.
  • Training Requirements: Employees involved in approving, executing, and reviewing operations, businesses, or contracts must comply with all internal controls and mechanisms to prevent and control ML/TF/FPWMD. Attendance at relevant training sessions is mandatory.
  • Ethical Compliance over Business Goals: Employees must prioritize ethical principles over commercial targets to cultivate a culture of regulatory compliance in preventing and detecting ML/TF/FPWMD.
  • Accountability: The Board of Directors, Legal Representative, Compliance Officer, and all employees must fulfill their responsibilities regarding the implementation of the ML/TF/FPWMD Self-Control and Risk Management System.
  • Policy Compliance and Violations: All employees must comply with this SAGRILAFT program. Any violation will be considered a serious offense, as outlined in the Internal Work Regulations.
  • Business Relationships with Politically Exposed Persons (PEPs): The establishment of commercial, contractual, or conventional relationships with a counterparty classified as a PEP must be approved by the Company’s Legal Representative, who must consider:
    • Absence of conflicts of interest between the PEP’s official duties and the proposed business relationship.
    • Reasonableness and consistency between the purpose, amounts, frequency, and other characteristics of the transaction or contractual relationship in relation to the PEP’s position or functions.

 

COMPLIANCE OVERSIGHT

As an internal instruction, the SAGRILAFT Code will have an advisory team to support the Compliance Officer, ensuring adherence and promoting compliance.

 

SAGRILAFT RISK COMMITTEE

The advisory team for the Compliance Officer will be the SAGRILAFT Risk Committee, composed of:

  • Chief Financial Officer
  • IT Coordinator
  • Customer Operation Manager
  • Junior Data Developer
  • Sales Development Manager
  • Senior Quality Analyst
  • Security Director
  • Administrative and Financial Manager

All cases managed by the SAGRILAFT Risk Committee will be handled with strict confidentiality, regardless of the impact on the Company or the complexity of the investigation process.

A quorum for the SAGRILAFT Risk Committee will be achieved with a simple majority (half plus one) of its members.

It is essential for all Committee members to adhere to the Code of Ethics and maintain a strict Confidentiality Policy, given the sensitive nature of the information they will access.