Ethics Code

MISSION AND VISION

 

Mission

To be an ally of our clients and make specialized knowledge available to them on the management of proper institutional relations at both the government and Legislative Assembly levels and with different actors in society, to help resolve problems and limitations they face, as well as to positively impact and maximize opportunities that allow achieving common goals.

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Vision

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To be a leading and reliable company nationally and regionally that provides ethical and timely solutions, as well as support to its clients to meet their goals and positively impact society.

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PURPOSE AND SCOPE

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This Code of Ethics aims to establish the basic principles and commitments expected of and to be demanded from Boreal Consultants, all people working for this company, constituting a common integrity framework for all of them in carrying out their professional activities and in their relationships with stakeholders.

Its compliance is mandatory and without exception for the company's employees, regardless of their geographic location or hierarchical position in the organizational chart or the type of contract they have with the company.

We assume an ethical commitment in all our actions, understanding the impact that healthy corporate conduct has on our company, our clients and society.

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OBLIGATIONS DERIVING FROM THIS CODE OF ETHICS

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Know, apply and promote the values, principles and commitments contained in this Code, as well as the policies and procedures that develop and complement them. When there are discrepancies between local laws and regulations and this Code, the strictest standard will apply.

Participate in the training activities offered by the company for the proper application of this Code.

Have zero tolerance for behaviors that deviate from the principles and values included in this Code. No one can authorize or request an action that constitutes a breach, regardless of their position in the company.

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In case of suspicions of an action or situation that may violate the Code, even if said situation is not within your area of responsibility, it must be reported through established channels, always in good faith and avoiding unfair use or personal benefit from said channels.

Collaborate in the development of internal audits and investigations that may be carried out.

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PRINCIPLES AND VALUES

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Integrity

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Act guided by ethical standards, in accordance with this code, in your professional performance and guided by honesty and righteousness; without seeking undue favors.

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Transparency

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Our communications are characterized by being based on reliable information, using science and technique, and providing it clearly while guaranteeing confidentiality, as well as protecting personal data according to applicable legislation. Constant and reliable communication with customers, suppliers, competitors and collaborators is essential.

Responsibility

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Our actions impact the results of the company, as well as our environment, clients and society. Therefore, all actions must be governed by our duty of compliance, risk analysis and impact measurement.

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Consistency

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Consistency in acting and leading by example are essential for trust, both in the company's operations and in relationships with clients and relevant third parties.

 

Loyalty

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We believe in building lasting relationships based on trust, respect and discretion.

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Quality

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We are committed to providing a service that adds value to our clients, meeting the requirements agreed upon with clients.

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COMMITMENTS AND RESPONSIBILITIES

Commitment to ethical behavior

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• Our ethical commitment is in all our actions towards our clients and society.

• Our relationship with interested third parties is based on respect, integrity and compliance with legal frameworks.

• We are vigilant about complying with applicable laws and regulations and applying the provisions of this code.

We believe that compliance with the highest ethical standards, as well as the legislation of the countries in which projects are carried out, should prevail at the center of our actions.

Commitment to our clients

• Be consistent with our vision, as well as the legal and ethical commitments of the company.

• Honor our commitments with quality, timeliness and reliability.

• Avoid actions that reputationally or legally expose our clients.

• Confidentiality

Our clients are our driving force and raison d'être, hence our commitment to providing a rigorous, quality service to achieve shared goals.

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Commitment to a more just society and sustainable development

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• Respect for diversity and equal opportunities

We are called on not to participate in, promote or tolerate any discrimination of any kind, including on the basis of ethnicity, gender, nationality, religion, beliefs, ideologies, age, orientation or sexual identity, marital status, illness or disability.

• Absolute rejection of any form of abuse

It is everyone's responsibility to alert about situations that encourage, favor or facilitate any kind of abuse against people.

• Right to privacy

We believe in respecting the privacy of all collaborators and actors with whom we work, especially regarding their personal data. Access to such data is exclusive for the purposes for which they have been collected and under the corresponding authorization protocols for their use.

Our commitment to confidentiality is maintained even after the relationship with the company ends.

• Professional development

The professional development of our collaborators is important both as individuals, but also adds value to the company and society.

• Respect for proper compensation and rest for employees

We are committed to complying with national labor legislation, as well as promoting work-life balance, while always ensuring adequate service delivery to our clients.

• Rejection and condemnation of harassment at work

With a strong commitment to gender equality and rejection of violence, a hostile, discriminatory, intimidating, hateful and offensive work environment is prohibited. A work environment in which verbal, physical, sexual or psychological harassment is not allowed is promoted.

• Safety and health at work

Occupational health is essential to promote the physical and psychological integrity and life of employees; hence, preventive actions are required and mechanisms must be in place during operations to comply with occupational health standards.

• Teamwork, respect and effective communication

Teamwork enables better use of the capabilities of those who provide their efforts and knowledge to the company, so it is important that information flows and transparent and clear communication mechanisms are in place, which allows more effective use of talent and time, while allowing for better interpersonal relationships and respect.

• Responsible use of information and knowledge

In a company whose main asset is knowledge and information, proper and timely use is required to achieve business objectives and objectives shared with clients. Likewise, it is important to respect confidentiality and risks arising from access to and management of information.

• Responsible use of social media

In societies where information dissemination through social media enables the spread of false content that can deepen polarization, discrimination, violence, delegitimization of public entities and authorities, responsible use of social media becomes even more critical, not only in terms of the information disseminated but also the assessments or analysis made. Therefore, we are committed to rigorous use of our media and social networks.

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We believe that respect for human dignity, as well as contributing to achieving greater justice and equal development opportunities, should prevail at the center of our actions.

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Commitment to third parties

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• Avoid conflicts of interest

Any scenario that contrasts personal interests or those of a third party with the interests of the company should be avoided as much as possible. It is important to notify, according to the appropriate protocols, if a risk or reasonable doubts about this type of problem is observed, in order to guide decision-making.

• Anti-corruption practices

Any action aimed at offering, requesting, accepting unjustified benefits or advantages, as well as gifts, payments or commissions by or through third parties, is absolutely prohibited. This applies at all business levels, understanding that these practices cannot be used to get a client or achieve project objectives.

• Ethical relationship with State institutions, public officials and stakeholders

All interactions with public authorities, as well as technical teams from State institutions, must be carried out within the country's legal limits, and must also observe the highest ethical standards. Therefore, any kind of favoritism for public officials is prohibited, nor are benefits granted by any state actor allowed.

• Commitment to the fight against money laundering, irregular payments and terrorist financing

The means of payment and collection established by the company must be respected in order to achieve adequate traceability and transparency. If there are doubts about the origin or irregular nature of payments, they must be communicated, according to the appropriate protocol, for proper analysis.

• Free competition

We believe in respecting free competition and therefore avoiding practices that engage in unfair competition and market distortions.

• Responsibility to suppliers

Objectivity criteria must always prevail to avoid conflicts of interest. In addition, suppliers are required to fulfill their legal and contractual obligations, both in terms of compliance with human rights, labor, ethical and sustainability standards.

• Corporate Social Responsibility

We are fully convinced that companies can contribute to the sustainability and development of a country, so good corporate practices must be observed to reduce negative impacts on society.

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We must be vigilant in achieving a favorable reputation for our company and clients before society, avoiding compliance risks.

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ADMINISTRATION AND APPLICATION OF THE CODE OF ETHICS

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To properly implement the scope of this code of ethics, the figure of a compliance officer is established, who reports directly to the partners, and who is responsible for:

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1. Ensuring the proper functioning of communication channels in service of implementing the Code of Ethics.

2. Managing reporting channels.

3. Responding to inquiries received regarding Compliance.

4. Coordinating and conducting investigations into possible breaches.

5. Presenting conclusions and recommendations for disciplinary measures or legal actions to be initiated and improvement recommendations identified.

6. Annually preparing reports on the compliance level.

7. Proposing compliance procedures and controls.