MONEY LAUNDERING AND TERRORIST FINANCING (MLFT) RISK MANAGEMENT POLICY

Transcription

1 MONEY LAUNDERING AND TERRORIST FINANCING (MLFT) RISK MANAGEMENT POLICY Suramericana S.A., its Affiliated Companies, and Subsidiaries Risk Vice Presidency

2 Date: 21/10/2016 Page 2 of 7 ELABORADO POR Juan Felipe Piedrahita Moreno Analista de Gestión de Riesgos Operacionales Corporativo REVISADO POR Luis Felipe Villegas Gerente Riesgos Operacionales Corporativo Suramericana S.A APROBADO POR Board of Directors Suramericana S.A., Acta 114 del 22 de Diciembre de 2016 Nombre del Documento: Política en Prevención y Control del Riesgo de Lavado de Activos y Financiación del Terrorismo (LAFT). Ubicación: A:\Corporativo\5_LAFT\Politicas CONTROL DE CAMBIOS VERSIÓN AUTOR DESCRIPCIÓN DEL CAMBIO 1 Directores Gestión de Riesgos Documento inicial

3 Date: 21/10/2016 Page 3 of 7 TABLA DE CONTENIDO MONEY LAUNDERING AND TERRORIST FINANCING (MLTF) MANAGEMENT AND CONTROL POLICY Introduction Objective of the policy Scope General guidelines Responsibilities Board of Directors Top Management Risk Areas Employees Gobernabilidad de la Política Divulgación Actualización Documentos de apoyo... 7

4 Date: 21/10/2016 Page 4 of 7 MONEY LAUNDERING AND TERRORIST FINANCING (MLTF) MANAGEMENT AND CONTROL POLICY 1. Introduction Because of its complexity, the financial system is used as a mechanism for money laundering and terrorist financing by hiding assets and resources of an illicit or illegal origin. This is the reason why the countries supervision and monitoring bodies, together with inter-government organizations such as GAFI, UNODC, EGMONT, OECD, and others, promote a risk management culture, emphasizing the importance of adopting and implementing a System for Managing the Risk of Asset Laundering and Terrorist Financing, in which an adequate and robust knowledge of all their clients, employees, and suppliers is a key factor in the actions of the entities that are part of this system. The provisions contained herein are complementary to the national and international regulations on the topic of MLTF risk prevention, the Corporate by-laws, and the Code of Conduct, and they apply, regardless of the hierarchical position and type of contract, to every employee 1, Insurance intermediary (consultants, agencies, brokers, etc.), suppliers, and administrators (members of Top Management and Board of Directors) of de Suramericana S.A. 2. Objective of the policy This document is intended to set up a framework for action and a general guideline so that Suramericana S.A., its affiliated companies, and subsidiaries, are able to respond to and mitigate the risk of being used as an instrument to perform money laundering operations and/or to divert resources to carry out terrorist activities. 3. Scope This policy applies to Suramericana S.A., its affiliated companies, and subsidiaries, and Fondo Sura, (hereinafter, the Companies), which shall implement it according to the individual needs and requirements of their different business units and jurisdictions. 1 The term "employees" includes account executives, health professionals and commercial managers, MST managers, operating consultants, consultants from insurance promotion firms and agencies, auto and general insurance inspectors, automobile repair shops, and any other type of work relation supported by a work contract of any type, and under the regulations that exist in the various geographic jurisdictions in which the company operates.

5 Date: 21/10/2016 Page 5 of 7 4. General guidelines The company does not accept, under any circumstances, actions, behaviors, faults, or situations that are willfully fraudulent and/or corrupt, committed by its employees and/or suppliers. Any fault of this kind is considered a grievous fault and could lead to disciplinary action. I. The companies must implement and make operational an MLTF management system as part of Integral Risk Management, in accordance with local conditions and consistent with existing regulations. II. III. IV. The companies must allocate and make available any resources required for the MLTF risk management system to operate properly, as part of the process of client analysis and knowledge. The Companies shall not hire, establish, and/or maintain business relationships, or carry out operations with, individuals or companies included in restrictive or connecting lists. The Companies shall abstain from establishing any kind of contractual relationship or carrying out commercial operations with third parties without first applying the mechanisms to know the client, and the due diligence procedures that have been defined. V. The companies shall define and implement appropriate mechanisms to know their clients, employees, and suppliers. Such mechanisms shall make it possible to obtain the necessary information and the most significant characteristics for monitoring, preventing, and detecting unusual or suspicious operations. VI. VII. VIII. Every employee, insurance intermediary (consultant, agency, broker, etc.), and supplier is responsible for complying with any applicable legislation, with the internal regulations about the MLTF risk management system, and for committing to the Company s ethics standards. The Companies shall ensure that every employee, in his or her onboarding process, receives information about the MLTF risk management policies and program, and is given permanent documentary access to them through the available dissemination channels. Compliance with the guidelines and regulations contained in this policy shall prevail over compliance with business goals and other indicators that have been established to measure the performance of the Company s employees and suppliers.

6 Date: 21/10/2016 Page 6 of 7 5. Responsibilities 5.1 Board of Directors The Board of Directors is responsible for approving the policy for managing and controlling the risks of money laundering and terrorist financing, and for promoting the application of the guidelines established therein. The Board is also responsible for appointing the Compliance Officer. 5.2 Top Management Top Management will be in charge of providing adequate resources to ensure compliance with this policy, translating the strategy defined by the Board of Directors into effective mechanisms so that the guidelines on the risk of MLTF are internalized and included in the Companies actions. 5.3 Risk Areas The Risk Area will develop and implement an MLTF risk management program that is appropriate for the specific needs of each Company. The program will be reviewed and modified at regular intervals to ensure that it is effective and timely. 5.4 Employees Every employee is responsible for: I. Following the guidelines and mechanisms defined herein. II. III. IV. Reporting to the Compliance Officer, in a timely manner and using the available channels, any facts or circumstances defined as warning signals or unusual operations. Cooperating in any investigation carried out by the Company with respect to MLTF, adhering to the principles of confidentiality and privacy. Abstaining from providing or disclosing information about the internal supports, reports, and documents about suspicious operations, or any other confidential document about the MLTF risk management process. V. Successfully completing the training programs prepared by the Company for identifying and controlling the risk of MLTF. VI. Their actions and omissions related to this policy, regardless of their responsibility, position, or function.

7 Date: 21/10/2016 Page 7 of 7 6. Gobernabilidad de la Política La presente política será aprobada por Board of Directors de Suramericana S.A. El Área de Compliance será la instancia encargada de supervisar, apoyar y velar por el cumplimiento y aplicación de los lineamientos aquí contenidos. 7. Divulgación Esta política será publicada en un repositorio único de información con acceso a todos los empleados y proveedores de las Compañías. 8. Actualización Esta política será modificada por la Board of Directors de La Compañía o quien esta designe cuando lo considere necesario. 9. Documentos de apoyo Manuales de Gestión del Riesgo de LAFT o sus equivalentes en cada compañía junto con sus anexos respectivos.