Compliance

The Ethics Committee, a multidisciplinary committee with autonomy and independence, is responsible for overseeing the Ethics and Compliance Program, ensuring the availability, updating, and enforcement of the code of conduct, as well as the investigation of indications of misconduct, fact-finding, and the recommendation of corrective action plans.

The Ethics and Compliance Program guidelines translate our values into ethical principles and rules that guide the conduct of all those who work for or on behalf of CBAA.

CBAA’s Code of Ethics and Conduct is the document that brings together the fundamental principlesthat support the purpose of our business and reiterates the company’s commitment to integrity. In addition to reinforcing expected conduct, the code also includes the Anti-Corruption and Anti-Bribery Policy and provides guidance on Information Security and the Use of Social Media.

Click here to access the Code of Ethics and Conduct.

The Anti-Corruption Guide summarizes the key topics of the Ethics and Compliance Program related to suppliers and third parties. It provides definitions, expected conduct, and reinforces the duty to report any deviations in behavior.

Click here to access the Integrity Program.

We engage and train all our employees, suppliers, and third parties in the Ethics and Compliance Program.

The objective is to guide everyone on how to overcome dilemmas and make the best decisions in an ethical and responsible manner. The initiatives that are part of the Program include training on Ethics and Compliance, specific training for senior leadership and key department employees, and the promotion of dialogues between leaders and employees regarding ethical dilemmas.

To effectively measure and monitor potential risks at CBAA, we have a Risk Management Policy in place. The management of risks related to ethics and compliance is integrated into our governance practices and is based on two fronts. On the one hand, the parties directly responsible for a department, branch, or administrative area are involved in implementing and executing effective preventive and mitigation controls. They ensure the proper definition and execution of action plans and establish corrective actions for continuous improvement in risk management. On the other hand, additionally, the Ethics Committee is responsible for defining the code of conduct and for capturing, assessing, and addressing complaints, providing impartial assurance, including on the effectiveness of risk management and prevention, internal controls, and compliance.
Click here (link to Risk Management Policy) to learn more about our riskmanagement.

We have made a Transparency Program available at CBAA to enable anyone, whether inside or outside the company, to report suspected cases or instances of unethical conduct through an easy, fast, and practical reporting system. The program includes an exclusive tool for reporting incidents and attaching files containing evidence. It is structured to ensure a fair and independent investigation by maintaining strict confidentiality of shared information. The program prioritizes the protection of both the whistleblower and the accused party, guaranteeing the absence of retaliation or intimidation towards the whistleblower. All violations of conduct related to the Code of Ethics and Conduct or the Anti-Corruption Guide trigger corrective action plans.

The investigation process for reports is structured as follows:

1. The whistleblower submits a report through the dedicated tool provided specifically for this purpose, either anonymously or by identifying themselves.
2. The reports are received by the Governance and Processes department, where they are analyzed to verify the individuals involved. They are then directed for evaluation by the Ethics Committee. To ensure impartiality, confidentiality, and fair treatment, the departments involved in the report, even if they are part of the Ethics Committee, are not involved in subsequent actions.
3. The reports are evaluated by the Ethics Committee, which assesses if there is sufficient information, classifies them by themes and severity, and conducts an investigation into the reported conduct.
4. For confirmed cases of misconduct, the investigation results are shared with the leadership, and an action plan is developed to address and prevent recurrence of the behavior.
5. The action plan is executed by the responsible parties, and a final response is provided to the whistleblower by the Ethics Committee, thereby concluding the matter.

The Ethics Committee operates independently and confidentiality to guarantee a fair investigation of the facts, defining and monitoring correction plans for confirmed cases.

Correction plans can also be established for ethical lapses and conduct failures identified in day-to-day operations, regardless of a report in the Transparency Program.

As a general rule, correction plans include measures to promote process improvements, training initiatives, and feedback to employees. Depending on the severity of the allegations, employees involved may be subject to disciplinary sanctions, such as warnings, suspensions, or contract terminations.

The application of disciplinary measures for confirmed misconduct is provided for in the Code of Ethics and Conduct and is carried out equitably, in accordance with local legislation and the appropriate terms of collective bargaining agreements. Suppliers involved in serious violations of the Anti-Corruption Guide are also subject to punitive measures, such as fines or contract termination.