Supplier Code of ​Conduct

May 10, 2024

Ecopetrol´s Code of Ethics and Conduct defines the standards of conduct expected by the organization and guide the actions of Ecopetrol S.A., of the Group Companies and of all the recipients of the Code, pursuant the highest ethical principles of integrity, responsibility, respect, and commitment to life.  

The accountability of the Code covers the activities and conduct of Ecopetrol´s suppliers and contractors, as it is mentioned on the official document. Therefore, the knowledge and application of this Code will be mandatory for the suppliers working alongside the Company or any of its subsidiaries, who must ensure that their actions are always framed within its rules. 

Principles of Ecopetrol´s Code of Ethics and Conduct: 


Some of the actions or behaviors expected for this principle are: 

  • Work with righteousness, loyalty, justice, honesty, and transparency. 

  • Impartiality in the decisions and actions, not intending to seek privileges, or personal benefits.  

  • Report conflicts of interest, inabilities, and incompatibilities.  

  • Zero tolerance to events implying compliance risks. 

(fraud, bribery, corruption, money laundering, terrorist financing, violation of the FCPA)  



Some of the actions or behaviors expected for this principle are: 

  • Responsibility of actions and omissions and compliance with local and international regulations and internal provisions applicable to the activities executed.  

  • Compliance with the internal and external regulations applicable, the internal work regulations, the culture principles and agreed obligations, and its enforcement. 

  • Accountability of mitigating business and activity risks, abiding by the pertinent controls and its respective execution.  


Some of the actions or behaviors expected for this principle are: 

  • Not discrimination or harassment for being of different sex, orientation, race, national or family origin, language, gender, religion, political or philosophical opinion, disability situation, or any other situation that goes against the diversity and inclusion policy adopted by Ecopetrol. 

  • Rejection any act of sexual harassment at work. 

  • Promotion of equality among my colleagues and the rejection of unfair competition.  


Some of the actions or behaviors expected for this principle are: 

  • Respect and promotion of human rights. 

  • Protection of the environment, preservation and improvement of environment and the social milieu.  

  • HSE policies compliance and enforcement; reporting incidents related to non-compliance with HSE rules. 

Ecopetrol has voluntarily signed the Global Compact of the United Nations, an initiative that promotes the commitment of the private and public sector and the civil society to align their strategies and operations with ten principles that are accepted universally on three thematic areas: Human rights and labor standards, Environment, and Business ethics: 

Human Rights and labor standards: 

Ecopetrol acts in a proactive and differentiated manner through the contractual and commercial relationships with its suppliers to respect, promote and guarantee the following rights and freedoms: 

  • Life, integrity and personal liberty. 

  • Freedom of union association and collective bargaining. 

  • Elimination of forced and compulsory labor. 

  • Abolition of any form of child labor. 

  • Dignified, favorable and adequate working conditions. 

  • Equality and elimination of discrimination in employment and occupation.  

  • Health and safety at work. 

  • Participation of ethnic groups through prior consultation. 

  • Collective and environmental rights. 

  • Freedom of expression. 

  • Privacy and protection of information and personal data. 

Ecopetrol ratifies its committed to the promotion, respect and assurance of Human Rights, guided by Political Constitution, the applicable national regulations, as well as Ecopetrol´s Human Rights Guide in which the Company adheres to: 

Ecopetrol recognizes the importance of the commitment with International Human Rights Law not only by its own operation but also its suppliers performance since their actions impact territories and communities where Ecopetrol operates. Therefore, it implemented the strategy of declaration, promotion, and appropriation of Human Rights, promoting in its suppliers and workers: 

  • Have a public declaration of respect and promotion of Human Rights and commitment to Diversity, Equity, and Inclusion. 

  • Implement practices or processes to prevent negative impacts on Human Rights, generated by the principle of due diligence. 

  • Promote respect for Labor Rights: decent, favorable and adequate working conditions, freedom of union association and collective bargaining, equality in employment and occupation, equal remuneration, abolition of any form of child labor, prohibition of human trafficking and of slavery, among others. 

  • Have practices to promote Diversity, Equity, and Inclusion, and prevent any form of violence, sexual harassment, workplace harassment or discrimination, with special consideration for vulnerable population groups that face greater barriers to social and labor inclusion. 

  • Strengthen prevention mechanisms for care and situations that affect Human Rights, violence, discrimination or sexual or workplace harassment. 

Ecopetrol also counts with internal polices, guidelines and normative which seeks to strengthen the supplier´s commitment with this crucial thematic: 




Guide for labor aspects in activities contracted 

Occupational aspects and conditions that must be taken into account in the planning, allocation, execution, balance and closing of a contract that requires the development of personnel by the contractor through the contractor and with exclusive dedication to the contract with Ecopetrol. 


Human Rights and Business Guide 

Determines the elements that lead Ecopetrol’ s management in Human Rights Aspects 


Guide for Diversity, Equity and Inclusion 

Policy and principles of action in Diversity, Equity and Inclusi in the development of the activities contracted by Ecopetrol and its commercial relationships. 


Annex On Human Rights And Corporate Social Responsibility 

Commitment to human rights and corporate social responsibility 


Annex on Human Rights and Diversity, Equity and Inclusion  

Establish the respect of Human Rights and promotion of Diversity, Equity and Inclusion in the development of the activities contracted by Ecopetrol 


Guide of HSE Requirements for the Planning and Performance of Contracts at Ecopetrol S.A. 

Establish the HSE requirements and obligations (occupational health and safety, and environment) in all phases of the supply management process; so that an adequate and consistent execution of the activities responsible for contractors is ensured. 





Ecopetrol is strongly committed to the preservation of the environment, therefore it declares its responsible management in the following aspects, among others:

  • Efficient use of energy and natural resources.
  • Reduce greenhouse gas emissions.
  • Waste management.
  • Comprehensive water management in operations.
  • Generates environmental awareness.
  • Monitors continually the effects of climate change through the HSE management system.
  • Prioritize safety at work and in the environment, to protect the integrity of people, facilities, and areas where operations are performed.
  • Compliance of environmental policies, standards, procedures, laws, and applicable regulations.

Environmental Sustainability Program:

The Supply Chain Management counts with the Environmental Sustainability Program which seeks to generate an environmental awareness on Ecopetrol´s Suppliers, in 4 postulates:


Ecopetrol applies the decarbonization cycle with its value chain, impacting Scopes 1, 2 and 3 of the company’s Greenhouse Gas -GHG- emissions inventory. The decarbonization cycle starts collecting GHG emissions data from suppliers, achieving decarbonization goals commitment for contracts, and implementing reduction and compensation emissions initiatives with suppliers.

Materials and waste

Ecopetrol adopted its circular economy model for its supply chain which seeks to prolong the life cycle of the acquired materials and minimizing waste generation. Therefore, the purchases or services contracted must be aligned with at least one of the following objectives: 

  • Reduce non-renewable virgin materials.
  • Optimize the potential reuse of products and components, through reuse, remanufacturing and/or repair processes, as well as inclusion of buy backs agreements in contracting processes.
  • Optimize the recycling of products and materials, by incorporating options for waste management.

Natural capital / Biodiversity

Ecopetrol is looking to involve the supply chain into the Net Zero Deforestation Goal, through the commitment to the Intersectoral Pact for Legal Wood in Colombia and the legality of the source of the wood to be used for the activities with intensive use of wood, prioritizing categories of goods and services such as: Construction, Facilities maintenance, Packaging, Stationery and Logistics.

Zero water discharges 

In the zero water discharges roadmap, Ecopetrol reports and achieved the certification of its direct water footprint in big four assets. Ecopetrol is engaging the supply chain through the indirect water footprint, prioritizing the categories of goods and services with intensive use of critical materials and waste management, such as: Supply of Chemicals, Drilling, completion and subsoil services, Drills, Supply of Steel Pipe, Supply of raw materials and waste management. 

During 2023, Ecopetrol developed the internal document “Environmental Sustainability Guidelines for the Supply Chain Process”, which contains guidelines on environmental sustainability to be considered during the different phases of the supply management process under the framework of the 4 main environmental postulates (decarbonization, materials and waste, natural capital/biodiversity, and zero water discharges). Even though this document was formalized in December 2023, it not only compiles and strengthens the 34 “green clauses” regarding to circular economy and decarbonization that were already operating in the process, but also includes criteria for the supplier selection process, key indicators to evaluate the supplliers performance and integral contract obligations in the 4 environmental postulates, recognizing different market maturity levels. This document promotes the implementation of the best environmental practices during the contracts performance. 

Some of the goods and services set down into these clauses were:

  • Maintenance services
  • Electronic and electrical equipment
  • Batteries and lights
  • Chemicals
  • Transport
  • Transformers
  • Cleaning services
  • catering services
  • Medicines and pharmacons
  • Stationery

These clauses contemplated the responsible management of water, fuel, wood and the hazardous and non-hazardous waste generation, management and final disposal, likewise a decarbonization clause which contemplated greenhouse gases measure, mitigation, and compensation, such as carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O) in compliance with NTC (NORMA TECNICA COLOMBIANA) technical standard ISO 14064-1 during contracts performance.

Ecopetrol also counts with internal polices, guidelines and normative which seeks to strengthen the supplier´s commitment with this crucial thematic:





Decarbonization Clause

Establish different decarbonization options: estimation and reduction goal


Guide for Comprehensive Waste Management and Zero Waste at Ecopetrol S.A.

Establish guidelines and responsibilities for the comprehensive management of waste generated in accordance with current legal regulations and the pillars of Waste Management and Circular Economy; through strategies of reduction, reuse, use and monetization of waste focused on the Zero Waste Management System.


Guide of HSE Requirements for the Planning and Performance of Contracts at Ecopetrol S.A.

Establish the HSE requirements and obligations (occupational health and safety, and environment) in all phases of the supply management process; so that an adequate and consistent execution of the activities responsible for contractors is ensured.





The actions and tasks developed by Ecopetrol´s suppliers and its employees must be characterized by transparency and ethical behavior; with total rejection and zero tolerance of any conduct that contravenes the postulates defined and adopted in the Ethics and Conduct Code.

Anti-corruption and conflict of interest:

  • Regime of inabilities, incompatibilities, and prohibitions applicable to current or former public servants, such us conflict of interest and ethical conflicts.
  • Prohibition of bribery and other forms of corruption
  • Integrity of accounting
  • Act against money laundering and terrorist financing (AML/CTF)
  • Prohibitions of gifts, entertainment, and hospitality


  • Rejection of any practice that promotes monopoly and that limits or violates free competition.
  • Protection of copyright and intellectual property is promoted.

Ethics, Transparency and due diligence

The supply management comprises a business ethics framework strengthened by high standards, mainly based in 3 fundamental pillars:

Looking to promote these 3 fundamental pillars, the process implemented high standards in this matter aligned with the Ethics and Conduct Code preserving the corporate principles and values in all the phases of process. Due to this strength, 96% of Ecopetrol´s suppliers and its employees consider the Supply Chain function as an ethical process; according to the average result of the ethics section of the annual stakeholder perception survey.

Ecopetrol always seeks to continuously improve and implement initiatives that enhance its performance assures its commitment with ethics, transparency, and compliance.


Ecopetrol´s suppliers are commited to:

  • Publishing job opportunities in the National Employment Service.
  • Formalizing through legal contracts the commercial agreements with suppliers and subcontractors.
  • Effecting opportune payments of labor and commercial obligations.
  • Deliver quality reports of payments made to collaborators, suppliers, and subcontractors in a timely manner.
  • Acting under the legality and free-market policies framework, avoiding intermediaries and undue pressures.
  • Contracting local goods and services and hiring local, diverse, and inclusive workforce to and generate value in the regions of operation.
  • Answering timely and integrality the requests, complaints and claims of workers, suppliers, community, and unions, without retaliations.
  • Avoiding commitments that cannot be fulfilled, as well as, collecting the requests to manage them with the respective authorities.
  • Reporting and denouncing with complete evidence acts of corruption, intermediation, commercial pressures, affectations and abnormal conditions.
  • Acting with transparency and complying with commercial and labor obligations, in accordance with fair market prices and conditions, applying the principles of Ecopetrol Code of Ethics and Conduct.

Legality and Transparency Pact

In 2021, Ecopetrol signed the Legality and Transparency Pact with Chambers of Commerce, which seeks to promote the local contracting under a framework of law compliance and free and fair competition principles.


Ecopetrol also counts with internal polices, guidelines and normative which seeks to strengthen the supplier´s commitment with this crucial thematic:




Rules of Ethics, Transparency and Compliance

The supplier declares that he knows and accepts the rules of ethics, transparency and compliance of Ecopetrol, such as provisions on conflicts of interest and ethical conflict, that its resources do not come from illegal activities, not to carry out illicit transactions or operations, or with people, companies or countries included in the restrictive lists of the OFAC or the United Nations, not participating in restrictive practices of competition or unfair competition and compliance with regulations on prevention and control of money laundering, financing of terrorism and proliferation of weapons of mass destruction applicable


Obligations of Ethics, Transparency and Compliance in contracting

The supplier declares thee compliance with the provisions of the Good Governance Code, the Code of Ethics and Conduct, and the internal regulations relating to ethical and compliance issues, anti-bribery laws, accounting standards and adoption of internal controls, not being involved in conflicts of interest, ethics, inabilities and incompatibilities, the rejection of sexual harassment and the acceptance of the right of termination for non-compliance that Ecopetrol has for any violation of anti-bribery laws, the Code of Ethics and Conduct or the obligations provided for in the guidelines of ethics and compliance, among others.


Commitment to Contractual Integrity

Ratificación del conocimiento por parte de los proveedores de los parámetros legales y regulatorios que aplican en su relación con Ecopetrol y compromiso con la aplicación del Código de Ética y Conducta, manuales anticorrupción, antifraude, LA/FT e instructivos sobre conflictos de conflicto de intereses y ético, y demás normas internas encaminadas a prevenir riesgos de cumplimiento, a lo largo de la relación contractual. 


Corporate Governance Code

Ecopetrol‟s Corporate Governance Code incorporates the best corporate practices for transparency, governability, and control to generate trust among stakeholders and the market. All acts undertaken by the company Board of Directors, Company Chairman, employees, contractors and contractor‟s employees, shareholders and investors, are included in the overall framework and provisions set out by this Code, so company government can develop its business activity framed within principles of transparency, Corporate governance and control over the business management.


LA/FT and shareholding statement

Certificate of compliance with the guidelines for the Prevention of Asset Laundering and Financing of Terrorism, established by ECOPETROL S.A, as well as shareholding information.


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