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Other Business Compliance Programme Ethical Guidelines
Feb 16, 2023
Applicable Law to the business, according to the jurisdiction where the business is carried out, considering the legal nature of the company.
Ecopetrol S.A. and its Business Group comply with the applicable provisions contained in the Political Constitution, national and international laws, as well as internal regulations. This includes, but is not limited to laws, decrees, procedures, manuals, guides, instructions and other formal guidelines. In particular, the provisions on internal control, the fight against money laundering, the financing of terrorism, the financing of the proliferation of weapons of mass destruction, fraud, bribery and corruption and others that regulate the mitigation of compliance risks.
Money laundering, financing of terrorism and financing of the proliferation of Weapons of Mass Destruction
Ecopetrol complies with current regulations on the System of Control and Integral Risk Management of Money Laundering, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction, and therefore has a system for the management of these risks approved by the Board of Directors through the
which establishes, among others, roles and responsibilities, guidelines for the acceptance of counterparties, verification controls, due diligence, monitoring and reporting of suspicious transactions.
Conflict of interest
Responds to the actions of public servants in matters in which they have a particular and direct interest in its regulation, management, control or decision, or their spouse, permanent partner, or any of their relatives within the fourth degree of consanguinity, second degree of affinity or first civil degree, or their partners in fact or in law, in accordance with the provisions of article 40 of Law 734 of 2002.
Additionally, according to Ecopetrol´ s internal regulations, an ethical conflict of interest is also considered a violation of the principle of integrity, therefore any action or circumstance that may imply a conflict of interest or that detracts from objectivity, fairness, independence or impartiality, in view of the fact that private interest may prevail or that decisions may be taken for personal or third party benefit and/or to the detriment of the Company's interests.
We have express and rigid regulations on conflicts of interest and internal procedures for reporting and deciding them. In accordance with these provisions, it is forbidden to seek privileges, to obtain undue personal benefits, as well as to carry out favoritism, nepotism or clientelism.
Prohibition of bribery and other forms of corruption
At Ecopetrol we do not allow or tolerate acts of bribery, such as the offer or proposal of a payment in money or the delivery of any object of value, such as products or services in kind, an offer, a plan, or a promise to pay something (even in the future), directly or indirectly, in exchange for an undue personal benefit, for a third party or for the company.
In this regard, we pledge not to violate the Foreign Corrupt Practices Act (FCPA), which makes it a crime to pay or offer anything of value, directly or indirectly, to a non-U.S. government official to obtain or retain business or to gain an improper business advantage, subject to appropriate sanctions by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). Nor is it permitted to violate the prohibitions of Law 1778 of 2016, which regulates bribery with foreign officials.
Accounting integrity
Ecopetrol has an Internal Control System that, in financial and accounting matters, ensures that the company's assets are properly managed and administered and that, in reasonable detail, they accurately and correctly reflect the transactions and dispositions of the company's assets.
All transactions, assets and liabilities are recorded in accordance with International Financial Reporting Standards, in accordance with local and international standards in each jurisdiction. All information recorded in the accounting records must have sufficient supporting documentation.
Gifts, entertainment, and hospitality
Ecopetrol employees are not authorized to give, offer, demand, request or accept gifts, hospitalities, courtesies, meals, travel, or other benefits outside the parameters defined in internal regulations. This prohibition extends to members of the employee's family and counterparties. It is therefore a duty to be aware of and apply the relevant provisions.
Facilitation payments
A facilitation payment is a payment made to a government entity or official in order to expedite or guarantee the execution of an activity that is part of its functions.
Ecopetrol. If any Ecopetrol employee or contractor is asked to make such payments or is pressured to do so, he/she must immediately contact the established reporting mechanisms to receive advice on this matter (Ethics Hotline).
Political contributions and lobbying
Political contributions and the financing of electoral campaigns are prohibited in Ecopetrol and the companies of the Business Group. Likewise, no lobbying or paying for lobbying activities may be carried out directly or through third parties (Anti-Corruption Manual).
Other ethical guidelines
- Protect and make appropriate use of the company's resources.
- Appropriate treatment of personal and sensitive data, and protection of company information.
- Act with social responsibility and respect for human rights, complying with regulations and standards that guarantee their protection.
- Duty to report facts that transgress the Code of Ethics and Conduct and the procedure for their processing, without tolerating reprisals against the complainant.
