Ethics Report
Integrity. Deception, simulations, falsifications and adulterations.::
Involves any action that is performed to make a situation appear to be something that it is not. It includes: falsifying a document by placing the client's digital signature without the client's knowledge or presence, adulterating any document or data after it has been signed, similar behaviors. See section 1 of the Code of Ethics.
Integrity. Fraud::
Implies any action or omission that causes material damage to GFF, for the personal benefit, direct or indirect, of the person who commits it. It includes actions such as: simulating business, manipulating results, usurping (impersonating) other people, with the purpose of pretending business that allows commissioning. Stealing funds from the accounts of clients or GFF, appropriating assets of GFF, clients or suppliers. See section 1 of the Code of Ethics.
Integrity. Moral misconduct and inappropriate behavior::
Implies actions contrary to morality performed in GFF facilities or during events or activities promoted by GFF or during the provision of the service. Includes actions such as: any type of physical contact of a sexual nature, including kissing (even if with a legitimate partner), masturbation or exhibitionism. See section 2 of the Code of Ethics.
Integrity. Conflicts of Interest. Services to collaborators::
It involves the illegitimate use of products and services provided by GFF, by an employee or family members, abusing their position in the company. It includes actions such as: applying prices, discounts, rates, credit limits or any other stipulation associated with a product, service, labor relations, under preferential conditions not authorized by the channels defined in the policies of GFF. See section I.1.1 of the Code of Ethics.
Integrity. Conflicts of Interest. Other work activities and personal endeavors::
Provision of services, undertakings or investments in companies that compete directly with any of the companies that are part of GFF or that generate any situation of conflict of interest. See section I.1.2 of the Code of Ethics.
Integrity. Conflicts of interest. Acquisition of properties::
Taking advantage of their position to acquire first and without authorization, any asset in which GFF has any acquisition interest. See section I.1.3 of the Code of Ethics.
Integrity. Conflicts of Interest. Kinship Relationships::
Maintain any kinship relationship that generates a conflict of interest, including: kinship between employees in the same area, kinship between employees with hierarchical dependence or functional dependence. The concept of kinship includes: any relationship of consanguinity or affinity, including non-formal sentimental relationships (courtship). See section I.1.4 of the Code of Ethics.
Anticorruption and Bribery. Participation or concealment in money laundering or financing of terrorism::
Any action or omission that constitutes or is intended to facilitate money laundering or terrorist financing. See ESMS policies and section I.1.5 of the Code of Ethics.
Anti-Corruption and Bribery. Making payments or bribes to public officials or employees::
Making payments to employees or public officials (in accordance with the ESMS Policy) for the purpose of influencing a decision or legal process. See ESMS policies and section I.1.5 of the Code of Ethics.
Anti-Corruption and Bribery. Making payments or bribes to customers or suppliers::
Making payments or bribes to customers or suppliers for the purpose of influencing a business relationship or any transaction, even if the benefit is for the company. See ESMS policies and section I.1.5 of the Code of Ethics.
Anti-Corruption and Bribery. Illegal contributions to political parties::
Any type of financial or any other type of contribution made to a political party that violates any current legislation related to the financing of political parties or the SGAS Policy. See ESMS Policy and section I.1.5 of the Code of Ethics.
Anti-Corruption and Bribery. Receiving royalties or bribes::
Receiving any goods or benefits (including gifts, travel, entertainment, etc.) in exchange for giving consideration, advantage, securing a business or transaction or influencing a business decision or relationship. See ESMS policies and section I.1.6 of the Code of Ethics.
Integrity. Conditional Trade Negotiations::
Any action by an employee that tends to condition the acquisition of a product/service, in a mandatory manner, as a requirement for the approval of a transaction or provision of another product or service. For example: making the opening of a bank account conditional on the acquisition of an insurance policy. See section I.2 of the Code of Ethics.
Integrity. Anticompetitive Conduct::
Any type of practice that is prohibited by local competition laws. This includes acts such as: corporate espionage, market sharing in conjunction with representatives of other competing companies, attempts to prevent GFF customers from entering into contracts with competitors. See section I.3 of the Code of Ethics.
Respect. Harassment at work (mobbing)::
Any recurrent and systematic practice, carried out by an employee or official, aimed at affecting another employee in relation to their work in GFF, usually with the intention that the victim resigns or is removed from their position. They include any form of physical or verbal abuse, imposition of less favorable working conditions than other employees (of the same position) of the same team or similar behaviors. See section II of the Code of Ethics.
Respect. Violation of confidentiality of employees' personal information::
Any illegitimate disclosure of personal information of employees, classified as reserved according to the Information Security Policy. For example: sharing employees' salary, health or family information with unauthorized third parties. See section II.1 of the Code of Ethics.
Respect. Fair labor practices. Diversity and Discrimination::
Any action taken against another employee based on subjective criteria such as: gender, physical disability, religion, political affiliation, sexual preference, race or other conditions protected by laws dealing with discrimination. For example: disqualifying an employee for promotion, advancement, salary increase; imposing less favorable working conditions than other employees (with the same position) of the same team; preventing salary increases as a consequence of having a protected status. See sections II.2 and II.3 of the Code of Ethics.
Respect. Sexual Harassment::
Any type of action of a sexual nature taken against another employee, customer or supplier. For example: comments, invitations or insinuations of a sexual nature, offering work advantages in exchange for sexual favors, imposing less favorable working conditions in retaliation for a sentimental or sexual rejection. See section II.3 of the Code of Ethics.
Respect. Abuse of Authority::
Implies an excess in the use of authority derived from the position of the collaborator or official. For example: an employee who favors a relative or friend to be served before other customers, a manager who requires employees to buy products from a personal business, a manager who imposes a religious or political practice on employees, an employee who asks a subordinate to perform an illegal action. See section II.5 of the Code of Ethics.
Respect. Retaliation::
Any action that affects an employee, customer or supplier as a result of having made a report to any area of support, supervision or control, including the Ethics Committee. Any employee or officer who prevents others from making legitimate reports, under threat of a deterioration in working conditions. See section II.7 of the Code of Ethics.
Respect. Violence and physical or verbal aggression, threats::
Includes any action by an employee that causes or threatens to cause physical or moral harm to another person (employee, supplier or customer). See section 2 of the Code of Ethics.
Commitment. Damage to GFF Assets::
It implies any action or omission, intentional, performed by an employee or officer, with the purpose of damaging or deteriorating any asset, tangible or intangible, of GFF.
Commitment. Disclosure of Confidential Information::
It implies sharing with any unauthorized third party by any means, information qualified as reserved, belonging to GFF, customers or suppliers. For example: account, product, service or personal contact information. See section III.2 of the Code of Ethics.
Commitment. Excess, adulteration or manipulation of GFF Expenditures or Resources.::
It involves adulterating GFF's expense reports or reports of expenses and other resources or taking undue advantage of them to obtain a personal benefit or for a third party. See section III.3 of the Code of Ethics.
Compromise. Use of illegal software::
It involves the unauthorized installation, use or duplication of any software, even if used for the benefit of GFF, without the authorization of Information Security.
Commitment. Political Activities::
It involves engaging in any proselytizing activity on GFF premises, on work time or using GFF resources. It also includes participation in electoral processes, as a candidate for any position, without having previously declared it to the Ethics Committee. It also includes any action of financing political parties or campaigns. See section III.7 of the Code of Ethics.
Service. Misuse of GFF's Name or Signs::
Implies the unauthorized use or use for personal purposes, of the name or any distinctive sign of GFF. See section IV.3 of the Code of Ethics.
Service. Noncompliance with Fiduciary Obligations::
Failure to comply with fiduciary obligations including failure to protect fiduciary assets. See section IV.4 of the Code of Ethics.
Sustainability. Employee Participation in GFF Raffles or Sweepstakes::
Involves participating and winning, directly or indirectly, in any raffle, sweepstakes or promotion developed by GFF as part of its marketing activity. See section V.4 of the Code of Ethics. See section V.4 of the Code of Ethics.
Sustainability. Unfair treatment and unfair practices::
It involves taking advantage of any person (collaborator, customer or supplier) through manipulation, concealment, use of confidential information or falsification of relevant facts, with the purpose of obtaining a personal benefit or even a benefit for GFF. It includes any kind of unfair practices or operations. See section V.5 of the Code of Ethics.
Sustainability. Illegitimate Donations::
Any donation made on behalf of GFF without following the procedures set forth in the Donations Policy. See section V.6 of the Code of Ethics.
Sustainability. Environmental Damage::
Any malicious action or omission that damages or generates a risk to the environment. See section V.7 of the Code of Ethics.
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