Policy for Combating Fraud
PURPOSE
Establish the guidelines for the prevention, detection, reporting, and investigation of and response to actual or potential fraud situations, reaffirming Kreston Colombia’s commitment to transparency, integrity, and regulatory compliance
SCOPE
It applies to all operations representing actual or potential fraud involving direct employees, members of Management, suppliers, and clients.
GUIDELINES
- Kreston Colombia adopts a zero-tolerance policy toward fraud and corruption. No circumstance justifies conduct contrary to ethics and current regulations.
- Fraud is understood as any intentional act aimed at obtaining an undue benefit through deception, concealment, manipulation, breach of trust, or deliberate non-compliance with internal or legal regulations.
- All employees, suppliers, and clients who join the organization accept and commit to acting in accordance with corporate values: Truth, Integrity, Sensitivity, Quality, and Collaboration.
- It is the responsibility of all Kreston Colombia employees to immediately report any suspicion or evidence of actual or potential fraud to the General Manager and National Operations Manager so that they may be investigated.
- Reports must be made through the official channel provided by the organization: eticaeindependencia@kreston.co
- Kreston Colombia guarantees the protection of the whistleblower against any type of retaliation and will maintain due confidentiality regarding their identity and the investigation process.
- Malicious reports or those made in bad faith, if duly proven, will be considered a serious offense.
- It is the responsibility of the Ethics and Independence Committee or the Audit Committee, as applicable, to lead the fraud response program, ensuring objective, impartial, and timely investigations.
The Ethics and Independence Committee or the Audit Committee, as applicable, must develop the fraud response program, considering, among others, at least the following aspects:
a) Monitor compliance with controls aimed at preventing fraud.
b) Conduct investigations corresponding to reports of possible fraud and fraud occurring within the organization in the shortest time possible.
c) Report to Welfare Management to proceed with the application of disciplinary actions in accordance with the Internal Labor Regulations.
d) Define a mobility plan with the Welfare Management area for those employees who have made reports.
The following are considered fraud events, including but not limited to:
a) Embezzlement of assets, money, or funds.
b) Falsification or modification of accounting or financial records.
c) Alteration or concealment of relevant information.
d) Misuse or unauthorized disclosure of confidential information.
e) Acceptance or offering of undue benefits related to the engagement of suppliers or third parties.
f) Undeclared conflicts of interest.
g) Extortion or conspiracy.
h) Any other conduct that affects the assets, reputation, or sustainability of the organization.
It is the responsibility of the Human Resources area, with the support of the Legal Department, to initiate and execute the corresponding disciplinary processes once investigations are concluded.
Upon suspicion or materialization of fraud, the General Manager and the National Operations Manager must review and strengthen internal controls aimed at risk mitigation.
Reports to the competent authorities must be approved by the Ethics and Independence Committee or the Audit Committee, as applicable, together with the Legal Manager.
The official response to the media regarding fraud-related situations will be issued exclusively by Senior Management, following validation by the corresponding Committee.
This policy will be reviewed periodically to ensure its validity, effectiveness, and alignment with applicable regulations and best corporate governance practices.