Code of Ethics – Soluciones Estratégicas en Información

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ethics

INTRODUCTION

A company’s Code of Ethics is a guide for action that will encourage its employees to conduct their activities in a manner consistent with the spirit of the company. As such, the development and implementation of documentation supporting this Code is an important basis for guiding activities. The application of the Code does not take precedence over legal provisions; rather, it seeks to achieve a higher level of excellence than that required by current law.

Experiences such as those of Odebrecht and Enron on a global scale, as well as a long list of companies in Colombia, have taught the world that having a Code of Ethics is not a panacea for preventing acts that violate moral and ethical principles, but documenting it definitely gives a strong impetus in the right direction and provides a tangible guide for employees at all levels.

In this vein, the document begins by defining the scope, the general principles in which the company believes, and the commitments made in this regard, and then details what are considered duties to each stakeholder group, with free competition and information management being equally relevant issues.

Maintaining SEI’s reputation as a responsible company will help attract and retain employees, contractors, customers, suppliers, and partners, as well as maintain good relations with the communities visited during its business. For this reason, SEI expects all its employees to comply with high standards of behavior and internal policies, as well as laws and regulations. Within this framework, this Code of Ethics supports SEI in building a culture of commitment and achieving long-term business results.

Thus, SEI’s partners, employees, and contractors recognize ethical principles as tools for ensuring transparency in the company’s management and its relationships with all its stakeholders. In line with this, its directors have deemed it appropriate to expressly and recognizably declare the content of the ethical principles that guide the company’s activities, with the purpose of making their observance public and, consequently.

AGREE

ARTICLE 1. ADOPTION.

SEI adopts the following Code of Ethics for the purpose of setting forth the values, principles, and standards that guide the attitude, behavior, and conduct of its partners, employees, and contractors.

In light of the foregoing, each and every one of them shall carry out their activities in such a way that the ethical provisions contained in this Code prevail throughout the performance of their duties, within a framework of transparency and fairness.

CHAPTER I. GENERAL PRINCIPLES

ARTICLE 2. PRINCIPLES.

All individuals associated with SEI, whether as partners, employees, or contractors, shall act under such relationship with:

CORPORATE EQUALITY. SEI partners shall have the opportunity to participate in discussions and debates prior to decision-making regarding the course of the company, without preferential or discriminatory treatment for any of them.

EQUALITY. SEI partners, employees, and contractors shall be treated equally without distinction based on race, religion, creed, sex, marital status, age, nationality, origin, social or economic status, sexual orientation, and without discrimination of any kind.

INTEGRITY. SEI partners, employees, and contractors shall act with consistency between what is thought, expressed, and done, acting in accordance with individual, institutional, and social principles, ensuring that actions are carried out with a sense of justice and fulfillment of duty.

LEGALITY. The actions of SEI’s partners, employees, and contractors shall be subject to constitutional and legal provisions and to the company’s decisions.

TRANSPARENCY. The actions of SEI’s partners, employees, and contractors shall be governed by transparency, understood as the expression of their management and behavior in a clear, consistent, and timely manner.

GOOD FAITH. The actions of SEI’s partners, employees, and contractors must be based on good faith.

LOYALTY. SEI partners, employees, and contractors shall act with integrity, trust, and loyalty, pursuing the company’s goals and objectives.

EFFICIENCY. This is the ability to meet SEI’s objectives within standards of quality, economy, and excellence. By virtue of this principle, partners, employees, and contractors shall make their best effort to achieve SEI’s objectives in a reasonable and appropriate manner, through the appropriate use of available physical, human, and budgetary resources.

ARTICLE 3: COMMITMENTS.

The fundamental commitments of SEI’s partners, employees, and contractors are:

3.1. To foster honest, constructive, professional, and appropriate relationships among partners, employees, contractors, and partners, as well as with all persons with whom they interact.

3.2. To promote equal opportunities for partners, employees, contractors, and people in general, regardless of their race, religion, creed, sex, marital status, age, nationality, origin, social or economic status, or sexual orientation.

3.3. Promote in its activities the prevalence of the principles of collective well-being, social improvement, and free and healthy economic competition, rejecting any practice that interferes with them and condemning in all cases the practice of bribery, intimidation, or undue favoritism.

CHAPTER II. DUTIES – STAKEHOLDERS

ARTICLE 4. DUTIES.

In accordance with the above principles and commitments, SEI’s partners, employees, and contractors, regardless of their status, assume the following duties:

Article 4.1. Relationship with collaborators. Given that it is a competitive advantage, the selection and hiring of personnel is based on the ability, professional experience, and level of identification that candidates have with the company’s values, and therefore SEI seeks to foster a healthy and productive work environment. To this end, it gives high priority to: Complying with labor laws and regulations • Respecting and promoting absolute respect for the differences and opinions of others, with the consequent prohibition of all types of harassment and discrimination • Safeguarding its employees and facilities through safety equipment, devices, systems, and procedures • Protecting the environment and the occupational health of its personnel.

Article 4.2. Customer relations. SEI seeks to be the best option for its customers. That is why its employees must treat them with professionalism and integrity, while providing them with quality services and products in a timely manner. It does not establish discriminatory differences of any kind, but rather selects its markets based on business criteria. SEI’s products and services must be offered honestly and accurately. Engaging in deceptive or dishonest practices is a violation of SEI’s Code of Ethics and values and will not be tolerated.

Article 4.3. Relationship with suppliers. Developing relationships of trust and mutual benefit with suppliers is an important part of SEI’s success. For this reason, it seeks to ensure that relationships with them are always handled with transparency, respect, and integrity, ensuring equal opportunities.

Article 4.4. Relationship with visited communities. The relationships of SEI and those of its partners, employees, and contractors with individuals shall be framed within the limits of the principles, commitments, and duties set forth in this Code of Ethics. The disclosure of information that should be of general knowledge shall be guaranteed, and requests for information shall be addressed in accordance with current legal regulations.
Relationships with the communities visited are of great importance due to the risk involved in not following appropriate guidelines for behavior, such as not assaulting community members in any way, responding to suggestions to end the visit, or not entering areas without first contacting community leaders.

Article 4.5. Relationships within SEI. Relationships between SEI partners, employees, contractors, and partners, and among themselves, shall be based on courtesy and respect. Likewise, a spirit of collaboration, teamwork, and loyalty shall prevail, in strict compliance with the rules set forth in this Code of Ethics.

Article 4.6. Relations with the Government and authorities. The relations of SEI’s partners, employees, and contractors with the Government and other public authorities (legislative branch, judicial branch, regulatory, control, and surveillance entities) must be conducted with transparency and honesty within the framework of the Law and under the principles, duties, and commitments described in this Code of Ethics.

Article 4.7. Relationship between SEI partners, employees, contractors, and partners with consulting firms with similar corporate purposes to those of the company. The relationships of SEI’s partners, employees, contractors, and partners with consulting firms or entities with similar purposes must be conducted with complete transparency, so that there is no exchange of information that in any way goes against the interests of SEI or jeopardizes SEI’s qualification or selection in public or private bidding processes.

Article 4.8. Participation of SEI partners, employees, contractors, and partners with consulting firms or entities with similar objectives to those of the company. SEI partners, employees, and contractors must explicitly and promptly inform SEI of the nature of any ties or relationships they have with consulting firms or entities with similar objectives in all situations where they are competing for joint projects or that may affect the company’s interests.

CHAPTER III. OPERATIONS AND ACTIVITIES

ARTICLE 5. COMPLIANCE WITH FREE COMPETITION LAWS

Compliance with applicable laws is a fundamental part of the company’s corporate values. SEI considers it inappropriate to intentionally affect a particular company or undertake efforts to eliminate a competitor from the business and does not enter into agreements with competitors to illegally restrict the market, fix prices, or manipulate bids.

ARTICLE 6. ANTI-BRIBERY

SEI rejects any form of corruption. Giving or receiving bribes is illegal and highly unethical. Its employees must not promise, offer, commit, pay, lend, give, or in any way transfer anything of value to a government agent or official or a potential contractor in cases where such a contribution is illegal. You may not do indirectly what you are not authorized to do directly; therefore, you may not use intermediaries or third parties to make inappropriate payments.

ARTICLE 7. PREVENTING MONEY LAUNDERING

Money laundering is understood to be any transaction or series of transactions carried out to conceal the true origin of illicit funds or to make them appear to have been obtained from legitimate activities. SEI is committed to: • Never facilitating or supporting money laundering • Always complying with applicable laws and regulations relating to money laundering • Avoiding involvement in arrangements or operations that may be or are related to assets of criminal origin • Taking appropriate actions to evaluate its business relationships to ensure their integrity.

ARTICLE 8. CONFLICTS OF INTEREST

SEI employees must prevent conflicts of interest that prevent them from performing their work objectively, effectively, and in the best interests of the company. Such conflicts may also arise when, due to their job position, individuals seek personal benefits or benefits for a family member. Therefore, an SEI employee may not: • Participate in any business or activity that directly or indirectly competes with or interferes with the company. • Take advantage of their position in the company to obtain personal benefits, including family members or third parties. • Receive income and/or benefits from suppliers, competitors, or customers. • Be a supplier to the company while employed by it. • Participate in or influence—directly or indirectly—the requirements, negotiations, and decision-making processes with customers or suppliers with whom they have a family relationship. It should be noted that family members of SEI employees may work for the company, provided they meet the requirements established for their role.

ARTICLE 9. GIFTS, ATTENTIONS, AND OTHER COURTESIES

Courtesies of any kind that compromise, or give the appearance of compromising, a decision-making process in any current or future negotiation may not be accepted or given. It is not permitted to request, negotiate, or accept discounts or courtesies from a customer, supplier, consultant, service provider, or any other person for personal benefit, unless it is legal, ethical, and an accepted business practice between the parties.

ARTICLE 10. ENVIRONMENTAL RESPONSIBILITY

It is part of SEI’s philosophy and priority to conduct its operations in harmony with nature. SEI is fully committed to conducting its business activities in an environmentally responsible and sustainable manner to minimize the impact of its operations.

ARTICLE 11. HEALTH AND SAFETY IN THE WORKPLACE

SEI employees are committed to conducting the company’s operations safely and efficiently and to ensuring the well-being of all those who are on its premises or who may be affected by such activities. No action or decision should be so important as to sacrifice the health or safety of oneself, colleagues, or outsiders. All personnel, suppliers, and contractors must stop any activity that could be considered risky.

ARTICLE 12. FINANCIAL CONTROLS AND RECORDS

The recording, maintenance, and preparation of financial reports for the various stakeholders must comply with the relevant legal provisions, generally accepted accounting principles, and the control guidelines issued by the company.

ARTICLE 13. PROTECTION OF ASSETS

Assets owned by SEI, as well as the services available to those who work for the company, are to be used in the performance of their duties and for the benefit of the company itself. Each employee is responsible for the custody and safeguarding of the assets under their control. Under no circumstances should an employee participate in, influence, or allow situations or actions related to theft, misuse, loan, disposal, or sale of assets in an unauthorized manner. SEI’s facilities, machinery, and equipment should only be operated by authorized and trained personnel.

ARTICLE 14. ANTI-CORRUPTION

It is in SEI’s interest to support actions to strengthen transparency in contracting processes and accountability. Considering the above, it ratifies the provisions of the preceding paragraphs regarding bribes and other types of gifts, and formally undertakes not to enter into agreements or engage in acts or conduct aimed at collusion in selection processes or, as a result, the distribution of contract awards.

ARTICLE 15. ANTI-TERRORISM

Terrorism is commonly understood to mean acts of violence directed against civilians in pursuit of political or ideological objectives. SEI has no links with, nor does it support or finance, individuals or organizations associated with or linked to this scourge.

ARTICLE 16. AGAINST HUMAN TRAFFICKING

Understood as the recruitment, transportation, transfer, harboring, or receipt of persons, by means of the threat or use of force or other forms of coercion, abduction, fraud, deception, abuse of power or of a position of vulnerability, or the giving or receiving of payments or benefits to obtain the consent of a person having control over another person, for the purpose of exploitation. Considering the above, SEI opposes inherently harmful and dehumanizing practices such as forced labor, debt or involuntary servitude, slavery, sex trafficking, and any other related activity that contributes to the phenomenon of human trafficking, which it considers a violation of human rights and incompatible with the company’s fundamental values.

ARTICLE 17. AGAINST CHILD LABOR

SEI welcomes initiatives, regulations, and agreements that seek to prohibit the worst forms of child labor and take immediate action to eradicate it. At the same time, it considers that the best tool for preventing child labor is quality education, and that the prevention and eradication of child labor should be an integral part of educational policies.

CHAPTER IV. INFORMATION MANAGEMENT

ARTICLE 18. CONFIDENTIAL INFORMATION

Information must be administered and managed in a responsible, secure, objective, and lawful manner. SEI employees must not disclose or communicate confidential information to third parties, except in cases where they are authorized to do so. The following is considered, by way of example and without limitation, confidential information: • Accounting information, financial projections, business plans • Commercial and operational policies and practices • Organizational changes and personal or employment information • List of customers and suppliers, costs, and pricing policies.

ARTICLE 19. PERSONAL DATA

SEI recognizes and protects the right of all individuals to know, update, and rectify the information that has been collected about them, that is, their personal data, in databases or files that are subject to processing by public or private entities. The criteria of voluntary and informed participation, respect for dignity, protection of rights, and well-being of the subjects of study shall prevail. The purpose and characteristics of each evaluation will be explained to participants, in accordance with the instructions given in the training, and will be recorded in a consent form, where their acceptance will be requested. SEI will guarantee the security, confidentiality, and, if possible, anonymity of the person providing the data. The use of data for purposes other than those authorized by the study subject is not permitted. If applicable, biological samples shall be used exclusively for the purposes authorized by the study subject.

ARTICLE 20. CONFIDENTIAL INFORMATION

Confidential information includes, among other things, information relating to the management of SEI’s own affairs, the disclosure of which could result in damage or loss to SEI or to third parties with whom the company establishes relationships.

ARTICLE 21. GENERAL DUTY OF CONFIDENTIALITY

All information known to partners, employees, and contractors during SEI’s activities and whose confidential nature is sensitive or relevant to the company must be kept confidential, even after the termination of the relationship with SEI.

ARTICLE 22. ACCESS TO CONFIDENTIAL INFORMATION

Only those who, by virtue of their activities and their relationship with SEI, have a need to know this information shall be allowed access to it. Similarly, only duly authorized and legitimately constituted public authorities that request such information may access it.

ARTICLE 23. USE OF INFORMATION

The information may only be used by partners, employees, and contractors for the purpose of carrying out activities related to their relationship with SEI and solely for the benefit of the company; consequently, they must refrain from using it for their own benefit or that of third parties.

ARTICLE 24. NON-CONFIDENTIAL INFORMATION

All information obtained, used, or known in the context of the relationship with SEI shall be understood as confidential and may only be disclosed with the express authorization of the Legal Representative, without prejudice to the proper use that must be made of it. This includes all information published on the SEI website or in the company’s media outlets.

CHAPTER V- ADMINISTRATION OF THE SEI CODE OF ETHICS

ARTICLE 25. INTERPRETATION QUESTIONS

The SEI Code of Ethics applies to the entire organization, and it is the responsibility of its employees at all levels to comply with it and enforce it. Each person can contribute by promoting business values and behaviors and by being a positive role model. SEI encourages employees to ask questions when they have doubts and to report possible inappropriate behavior to the Ethics Committee.

ARTICLE 26. INTERPRETATION QUESTIONS

Any differences arising from the application of this Code of Ethics will be resolved by the Committee appointed by management.

ARTICLE 27. EFFECTIVE DATE

This Code sets out the ethical principles that SEI has been developing and applying. Its provisions shall take effect upon approval by the Committee.

ARTICLE 28. PENALTY CRITERIA

If a violation of any article of the Code of Ethics is identified, an extraordinary meeting of the Ethics Committee shall be convened, during which the type of penalty to be applied will be decided by vote, depending on the severity of the offense committed. Penalties may range from monetary fines to the expulsion of the partner, employee, collaborator, or contractor, always in accordance with the laws of the territories in which SEI operates and depending on the nature of the relationship with the offender.

CIBERGRAFÍA.

They asked the great Persian mathematician Al-Khwarizmi
about the value of a human being, and he replied:
If a person has ethics, then their value is equal to 1.
If they are also intelligent, add a zero, and their value becomes 10.
If they are also rich, add another zero, and their value becomes 100.
And if, in addition to all that, they are also a person of good appearance,
add yet another zero, and their value becomes 1,000.
But if they lose the 1 — which represents ethics —
they will lose all their value, for only the zeros will remain.
It’s that simple:
Without ethical values or solid principles,
what remains are only delinquents, the corrupt,
and people without worth.

DERES-Corporate Social Responsibility. (October 8, 2801). Pdf. Manual for developing CODES OF BUSINESS ETHICS. Retrieved from http://campusvirtual.ubjonline.mx/course/view.php?id=585

GRUPO AVAL ACCIONES Y VALORES S.A. (n.d.). Pdf. CODE OF ETHICS AND CONDUCT. Retrieved from https://www.grupoaval.com/wps/wcm/connect/grupo-aval/2ba7b052-3cbc-41df-a869-64388b2ab99c/Code-of-ethics-and-conduct-.pdf?MOD=AJPERES

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