ANTI-BRIBERY POLICY (Anti-bribery Management System -SGAS-)

ANTI-BRIBERY POLICY (Anti-bribery Management System -SGAS-)

Esteban Donoso & Asociados is committed to implementing due diligence and decision-making procedures based on transparency and ethics, through the Government Body (senior management), with a view to preventing, mitigating, and reducing the risk of bribery; promoting each one of our employees´ compliance with this policy, the Internal Regulations, the Ethics Code and the applicable legal regulation; based on respect for human rights and ethical behavior. The firm guarantees the confidentiality of the complaints that might arise while carrying out its activities, as well as their correct handling and investigation.

WE EXPRESSLY PROHIBIT bribery in any form, be it direct or indirect through personnel of the firm or third parties towards and in relation to a public official or a private individual, and any type of behavior or conduct that might constitute a violation of the current legislation.

A bribe is defined as the act of giving, offering, promising, requesting or receiving something of value as a consideration for an undue benefit or inappropriate advantage or as consideration for the performance of any public or private function, independently of whether that offer, promise or request is for themselves or a third party, under the same name of that person or on behalf of a third party.

For the development of this ANTI-BRIBERY POLICY and ANTI-BRIBERY MANAGEMENT SYSTEM of Esteban Donoso & Asociados, we have taken into consideration as a starting point the requirements as set out by Standard ISO 37001:2016 and the current standards, laws and regulations in the field of compliance and prevention of bribery and corruption, in relation to which we demand the strictest adherence, specifically:

  • In carrying out Judicial Management activities
  • Administrative management
  • Contracts and advice

The scope of application of these policies is understood by all members of the firm and by all personnel contracted, subcontracted, partners, employees, prescribers, and other physical and legal entities that act with authorization on behalf of our organization.

El responsable de la Función de Cumplimiento es un órgano independiente y con autoridad, el cuál será responsable de la implementación y revisión del SGAS así como del seguimiento a la observancia de sus directrices y aseguramiento de los recursos necesarios para su mantenimiento.

Las sanciones al incumplimiento de esta política son aplicables a todo el personal de Esteban Donoso y Asociados, mismas que se establecen en el Reglamento Interno de Trabajo. Para sancionar las conductas contrarias a lo establecido en la presente POLÍTICA ANTISOBORNO y los incumplimientos de los restantes requisitos del SGAS, incluyendo las conductas delictivas. Su aplicación se hará de forma equitativa y proporcional, bajo el principio de no discriminación y respetando la legislación laboral aplicable

The personnel in charge of the of the Compliance of this regulation are part of an independent and authoritative body, responsible for the implementation and review of the SGAS as well as the monitoring of and compliance with its guidelines and ensuring the necessary resources for its maintenance.

The sanctions for non-compliance with this policy are applicable to all personnel of Esteban Donoso & Asociados, same sanctions which are set out in the Internal Work Regulations. To sanction conduct in contravention of the ANTI-BRIBERY policy and non-compliance with the additional requirements of the SGAS, sanctions will be applied equitably and proportionally, under the principal of non-discrimination and respecting the applicable labor legislation.

In addition, we have a CODE OF CONDUCT FOR BUSINESS PARTNERS, applicable to all such partners, from whom we expect conduct that is both ethical and legal, especially in our commercial relationships with them.

Manage complaints received through the complaints channel

Reduce the number of residual bribery risks identified and evaluated as higher than “moderate”.

Prevent acts or behavior that violate current legislation or that are perceived as not ethically acceptable.

These objectives are reflected and specified in our objective’s module on the BBComply (Business Continuity and Compliance) platform, which is periodically reviewed and updated, with the approval of the General Management.

Esteban Donoso & Asociados is committed to complying with the requirements as set out in Standard ISO 37001:2016.

Any member of our organization be it: employee, partner, shareholder, manager, representative and/or those who act on behalf of Esteban Donoso & Associates, has the obligation to inform and/or report any act, conduct, information, or evidence that is suspected of violating the ANTI-BRIBERY POLICY, or the requirements of the ANTI-BRIBERY MANAGEMENT SYSTEM, or when suspecting a criminal act or conduct.

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