For Amarilo the relationships with its workers, vendors, clients and other stakeholders are based on the idea that the mutual activities must be governed by the trust and the transparency. These fundamental premises of conduct are conceptually established and consolidated the Business Ethics’ Program (PEE), which contains our corporate values and principles, with which we endeavor to be differentiated as a leading company in terms of compliance and application of the regulations throughout all the relationships with the stakeholders. GRI 103-1, 103-2

When they first come to work for the company, the workers, without exception, must complete the PEE course as part of their induction process; in addition, and in order to guarantee the follow–up of the PEE internalization process, they must take and successfully conclude an annual refresher course. In 2020 we played a virtual game for the appropriation of concepts of the PEE and, after that, 100 % of the workers underwent the evaluation.

When faced with a situation or bad practice that endangers the integrity of the worker or the good name of the company, the employees must escalate the issue firstly with the direct supervisor, the respective head of department, the Secretary General, the CEO or with the ethical hotline. GRI 103-3, 102-1

We have three ethical hotline channels with the objective of identifying behaviors that are contrary to the ethics and the good uses, or cases identified as a violation of the Business Ethics’ Program, in which any person can report or denounce, in an anonymous and reserved manner. GRI 205-1

Amarilo contemplates the risk of Incursion in practices of domestic and transnational bribery and acts of corruption in the company. The risks are managed through the divulgation of the PEEA, the annual training of all the employees of Amarilo S. A. S. and the complaints’ ethical hotline. It must be underscored that for year 2020 there were no complaints regarding corruption through this medium.

In our value chain, the «Clients» group of stakeholders could be a potential source of risks of unethical or corrupt acts, with the acquisition / purchase of a home with funds that do not come from a licit source. For this reason, Amarilo S. A. S. has in place the System for the Self–Control and Management of the Money Laundering and Terrorism Financing Risk (SAGRLAFT for its acronym in Spanish), which is in force and continues being effective and efficient.

The main objective of the Compliance Committee is to periodically review, evaluate and define the actions that may be required regarding the Company’s compliance policies, such as the System for the Self–Control and Management of the Money Laundering and Terrorism Financing Risk; the Business Ethics’ Program; the Internal Work Rules and all other policies and guidelines that are mandatory for everyone in Amarilo. GRI 205-2, 205-3

GRI 102-33 Regarding the communication of the critical concerns, the Office of the Vice President, Financial Planning, in addition of being part of the Compliance Committee, also directly escalates and communicated to the Board of Directors the critical situations at the compliance level. In the situation that requires so, due to its complexity, Amarilo requests the professional opinion of labor lawyers to make the appropriate decision.

Also the following email address is in place: cumplimiento@amarilo.com, through which the concerns and doubts related to the company’s compliance policy are addressed.