ATENCIÓN AL CIUDADANO | Información de interés | Programa de cumplimiento
Compliance Program
China Communications Construction
Company Limited (CCCC), China Harbour Engineering Company Limited (CHEC) and
its subsidiaries and related companies including METRO LINEA 1 S.A.S.
(“ML1”), have legally implemented a compliance program (“Compliance
Program”) that complies with the best standards of international compliance and
ethical practices.
The CCCC Compliance Program is properly
designed and implemented to determine and mitigate any compliance risks that
CCCC and its subsidiaries or related companies including ML1, face day by day
in the execution of their activities. This program includes within its scope,
among others, the implementation of existing policies, processes, practices and
other actions that act to minimize the risk of Money Laundering and Terrorist
Financing (ML/FT) in the operations, businesses or contracts carried out by
CCCC and its subsidiaries and related companies including ML1.
ML1 as a subsidiary of CHEC and related
company of CCCC, implemented a Compliance Program based on the guidelines of
the CCCC Compliance Program and in accordance with the requirements, standards,
terms and conditions of Multilateral Banks, i.e. the World Bank, the
Inter-American Development Bank and the European Investment Bank; as well as
with the Concession Contract No. 163 of 2019 executed with Empresa Metro de
Bogotá S.A.
This program is a set of policies and
procedures that seek to identify and prevent risks associated with Prohibited
Practices, corruption, bribery, Money Laundering and Terrorist Financing and
aims to encourage and create a culture of transparency and business ethics
within the framework of responsible business practices.
This Compliance Program was prepared
with the legal support of international and national expert compliance law firms,
namely Norton Rose Fulbright and Brigard Urrutia.
ML1's Compliance Program is mandatory
for all ML1 personnel, contractors and subcontractors, who must fully comply
with all obligations and duties outlined in each of the policies and procedures.
ML1 has established an Integrity Line for
reporting suspicions or acts related to Prohibited Practices, corruption,
bribery, Money Laundering and Terrorist Financing through the following
channels:
08/24/2021
