ETHICS AND COMPLIANCE
Ethics and transparency are part of our principles,
which are present in each of our actions.

CODE OF CONDUCT

This is an instrument relative to the behavior expected by the associates of Grupo SUMMUM, which in conjunction with ethics and personal training, will foster the adoption of conducts and decisions based on our corporate pillars, such as transparency, legality, professionalism, respect, loyalty and social responsibility, among others.

AML/CFT MANUAL

In execution of its business purpose and in accordance with the commitment to the highest ethical and regulatory standards, the companies of Grupo SUMMUM have adopted and implemented a Self-Control and Risk Management system against Asset Laundering and Terrorism Funding – SAGRLAFT, from its Spanish acronym – which strictly meets the applicable standards, as well as the recommendations and best international practices on this matter. The policies, controls and procedures implemented are the tasks that seek due-diligence and are intended to prevent the use of our companies for illegal purposes.

AML/CFT MANUAL

In execution of its business purpose and in accordance with the commitment to the highest ethical and regulatory standards, the companies of Grupo SUMMUM have adopted and implemented a Self-Control and Risk Management system against Asset Laundering and Terrorism Funding – SAGRLAFT, from its Spanish acronym – which strictly meets the applicable standards, as well as the recommendations and best international practices on this matter. The policies, controls and procedures implemented are the tasks that seek due-diligence and are intended to prevent the use of our companies for illegal purposes.

HUMAN RIGHTS POLICY

We recognize the responsibility to protect the Human Rights of all our stakeholders, for this we have protection measures, through mechanisms aimed at not violating the rights of third parties and adequately managing any adverse impacts that may occur.

DATA PRIVACY POLICIES

In compliance with Act 1581 of 2012, and its regulatory decree 1377 of 2013, which is intended for the protection of the fundamental rights of all natural persons to their privacy and information, and the rights thereof as title holders of the same, Personal Information Protection is regulated at Grupo SUMMUM companies. As the responsible party entrusted with the treatment of aforementioned personal information, Grupo SUMMUM discloses its policy for such purposes, as well as the mechanisms available to people to guarantee the exercise of their rights.
There's still more! Because our commitment to legality is immense

ANTI-CORRUPTION AND BRIBERY POLICY

The anti-corruption policy of Grupo SUMMUM companies is intended mainly to exhibit its strict compliance with Corporate Ethics and Transparency, before its stakeholder groups and in all its contractual and commercial engagements, based on the zero-tolerance philosophy facing all corruption related actions. This is in accordance with the strategic sustainability and good governance route, which is framed within the principles of legality and transparency that guarantee the continuity of the businesses, safeguarding the group’s reputation.

UN GLOBAL COMPACT

We are part of the largest Corporate initiative in the world of the United Nations, taking its four thematic axes in the pillars of our organization: Human Rights, Labor Standards, Environment and the Fight against Corruption.

UN GLOBAL COMPACT

We are part of the largest Corporate initiative in the world of the United Nations, taking its four thematic axes in the pillars of our organization: Human Rights, Labor Standards, Environment and the Fight against Corruption.

LATIN AMERICAN COMPLIANCE NETWORK

We are part of the Latin American Compliance Network of the International Institute for Anticorruption Studies, which aims to promote, train and strengthen good practices and national and international standards in the area of ​​prevention of money laundering, fraud and the fight against corruption.