ETHICS AND
HUMAN
RIGHTS
In the territories and countries where it operates, CAP Group has been able to build strong relationships with its stakeholders on the basis of ethical principles, an honest group of people and an unconditional respect for and abidance by the laws currently in place.
CAP Group ethics management model includes a number of internal policies, procedures and structures aimed to guarantee that corporate performance will be aligned with institutional values and that the required tools will be made available to stakeholders so these can request more information on these issues and report eventual infringements.
This system is mainly underpinned by the Code of Ethics and Good Practices as a reference framework ruling the organization labor life and as a guiding light helping Directors, executives and workers make their decisions and opt for the honest, respectful, reliable and transparent actions that characterize the Group.
Updated as of the end of 2015, the Code of Ethics and Good Practices serves as a reference framework for company Directors, executives and workers regarding the basic principles set up by the company concerning 13 priority dimension actions.
This document is circulated to all Group workers and is available for consultation by customers, suppliers and the general community on the website www.cap.cl.
It should be pointed out that the results obtained from the ESG survey applied in 2017 indicate that all these stakeholders make a favorable appraisal of the company ethical culture.
All Directors, executives and workers from CAP Group companies are required to report eventual infringement situations or breaches of the Code of Ethics and Good Practices through the whistleblowing hotline or to any member of the Ethics Committee. The information will be treated with strict confidentiality and reserve and efforts will be made to keep the informer’s identity anonymous.
The CAP Group Whistleblowing and Consultation Hotline was upgraded in 2017 through a new platform hosted by an external website managed by Fundación Generación Empresarial. It is available to all company stakeholders on a 24/7 basis and can be accessed from wherever required.
This service was developed after the annual review of CAP Group Crime Prevention Model pursuant to law 20393, which prevents bribery, asset laundering, terrorist financing and aiding & abetting offences.
Through this line, CAP Group workers and contractors as well as communities, customers, suppliers and shareholders will be able, in strict confidentiality and anonymity, to make questions and report irregularities, abuses and breaches of issues such as:
Integrated by three Board-nominated members, this group is in charge of reviewing and solving the serious grievances received through the different channels made available by the company.
Some of its responsibilities are the dissemination and promotion of the values and conducts contained in the Code of Ethics; respond questions regarding its interpretation and exercise; and propose content updates to the Board.
In 2017, a total of 24 reports were received; 5 of them were associated to non-discrimination issues.
CAP Group has certified the crime prevention model in four of its affiliates: CAP s.a., CAP Minería, CAP Acero and Cintac. this places the company in a top national position on these matters.
In order to comply with law Nº 23393 regarding criminal liability of legal entities for the commission of asset laundering, terrorist financing, bribery and aiding & abetting offences, in November 2016, CAP Group formalized and certified its Crime Prevention Model.
This instrument comprises a number of control and prevention measures for the processes and activities associated to the crimes covered under this legal instrument whose provisions are applicable to CAP S.A. and all its affiliate companies. Thus, its scope involves its Boards, the entire workforce and the processes under its direct supervision as well as the relationships established by CAP S.A. and the affiliate companies with their respective customers, suppliers, service providers, contractors and subcontractors.
Thus, the CAP Group Board, its high governance body and the company-appointed person in charge of crime prevention shall hold accountability for the model. On the other hand, its execution considers prevention and detection activities as well as response actions and supervision systems.
CONFLICTS OF INTEREST
CAP Group has also pledged to eradicate conflicts of interest, a practice that –as stated in the Code of Ethics and Good Practices- occurs when “the relationships kept between our Directors, executives and workers with third parties can impair the company’s interests”. In order to prevent such conducts, CAP has defined the obligations and prohibitions its workers are subject to in the three areas where conflict of interest situations are most likely to occur: work relationships and secondary Director positions; personal relationships at the workplace; and work relationships with politically exposed people (PEP).
"+PROBITY" PROGRAM
Since 2015, and with the purpose of strengthening business integrity policies and actions, mainly in anticorruption, conflicts of interest and free competition areas, CAP Group has been engaged in the “+Probity” program created by ACCIÓN Empresas. This is a collaborative initiative where the largest national companies share their experience and propose joint programs and initiatives to promote and disseminate good practices.
Each year, and pursuant to its “We are CAP: Leadership and Values” program, the company trains its collaborators on matters contained in the Code of Ethics and Good Practices and in the Group Crime Prevention Model (MPD).
As part of the awareness-building efforts, in 2017 training courses on the Code of Ethics were provided to all Cintac, CAP Acero and CAP S.A. collaborators. In 2018, this initiative will be extended to CAP Minería.
Likewise, the company posted an explanatory video on its website and other platforms for all people interested in learning how the whistleblowing channel works.
Finally, in order to continue to move forward in the crime prevention model, some reminders were issued on the main aspects contained in law 20393 while the Internal Control and IT Manager attended some lectures on this topic as annually required by this regulation.