Ethics and Compliance Officer. ▪ To see to the disclosure and implementation of the ethics’ code and compliance manual to the entire company ▪ To facilitate the preparation of mitigation plans for the identified risks of corruption, fraud and money laundering and the financing of terrorism. The follow up of its implementation and effectiveness. ▪ To facilitate sessions to raise the awareness and training about issues related to corruption, fraud and money laundering and the financing of terrorism, both for employees and for third parties that so require it. ▪ To ensure the execution of the transparency compacts and / or representations in issues of fraud, corruption conflict of interest; and to analyze and assess the information declared in these pacts that evidence issues of corruption, fraud or conflict of interest. ▪ To see to the identification of risks and controls of corruption, and the periodic update of its assessment ▪ To report to the Board of Directors’ Audit Committee all the denouncements related to corruption, fraud and money laundering and financing of terrorism, according to the ethical process established ▪ To see to the training and the updating of the members of the team in order to ensure the skills and competencies related to the prevention, detection and answer to the risk of corruption, fraud and money laundering and financing of terrorism. ▪ To be the reliable advisor of the Top Management about red flags or events that can be fraud or corruption situations. ▪ To recommend to the top management preventive measures and / or actions before competent entities (courts or disciplinary) to strengthen the anti – corruption strategy.
Ethics and Compliance Officer. Are functions of Cenit’s Compliance Officer: ▪ To see to the effective, efficient and timely operation of the LA / FT risk management system ▪ To submit to the board of directors a semi – annual report about the compliance with the duties entrusted to it DC – Crude Oil Transportation Agreement – 018 – 2013 141 This report must include, on a semi annual basis, the following aspects: ◦ The results of the activities carried out ◦ The compliance that has occurred regarding the forwarding of the reports to the different authorities ◦ The effectiveness of he mechanisms and instruments established, as well as of the measures adopted to correct the failures of the system ◦ The results of the corrective measures and instruments established, as well as of the measures adopted to correct the faults in the system ◦ The results of the corrective measures ordered by the board of directors ◦ For events of direct placement of securities in the primary market, the results of the placement every time the term of the respective public offering ends ◦ A report regarding the control of money laundering and financing of terrorism made to the transfers in the secondary market, as the case may be ◦ To submit to the Legal Representative the requirements of IT, technologic, physical and human resources necessary for the compliance with its functions. ◦ To promote the adoption of corrective measures of the La / FT risk management system ◦ To assess the reports lodged by the Statutory Auditor and to adopt the relevant measures versus the deficiencies informed ◦ To see to and coordinate any requirement, request or act of competent judicial or administrative authority in this regard ◦ In the case of direct placement of securities in the primary market, to approve the participation of the investors that must be classified as publicly exposed persons. ◦ Ro verify the opportune and strict compliance with the legal standards established for the prevention of criminal activities in the international trade and in the foreign exchange operation ◦ To implement the general and specific procedures that it considers as adequate for the greater effectiveness of its work ◦ Ro control and verify, in a periodic manner, the execution of the measures adopted in this field as well as the information provided by the active clients of the company ◦ To carry out the studies necessary to determine whether or not an unusual foreign exchange or foreign trade operation can be considered as suspicious ◦ To info...
Ethics and Compliance Officer a. Within 30 days of the effective date of this Agreement, Contractor shall designate an Ethics & Compliance Officer, who is primarily responsible for Company’s Contractor Responsibility Program. The Ethics & Compliance Officer shall have the privilege and responsibility to report directly to the Company’s President and Chief Executive Officer.
