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 inform the management of the company about the possible faults or omissions in the controls for the prevention of criminal activities that compromise the liability of the employees and of the company DC – Crude Oil Transportation Agreement – 018 – 2013 142 ◦ To design, schedule and coordinate the training plans in that regard necessary for the different employees of the Company to be duly informed and updated. ◦ To report to the UIAF the suspicious operations determined Officers in General Each one of Cenit’s employees will be responsible to apply the controls designed by the Company in the processes in its charge that present any LA / FT risk factor. The following are the bodies for the control of the LA / FT risk management system: Audit Committee: ▪ To support the Ethics and Compliance Officer in determining the suspicious operations ▪ To carry out reviews of Cenit’s compliance manual whenever an update or review is made Internal Audit: The internal audit must include within its work goals programs for the verification of the compliance with the prevention, control and detecting of money laundering and financing of terrorism according to the law and to the internal procedures established by the company. Statutory Auditor: Are functions of the external auditor regarding the LA / FT risk management system: ▪ To instrument the controls that allow it to detect breaches of regulations in force applicable to Cenit regarding the prevention of LA / FT. Said activity includes the examination of the functions complied by the managers of the entity and the Ethics and Compliance Officer regarding the system implemented. ▪ To present a report to the Board of Directors and to the Ethics and Compliance Officer expressing the conclusions obtained in the process of evaluation of the compliance with the provisions regarding the prevention and control of money laundering and financing of terrorism. DC – Crude Oil Transportation Agreement – 018 – 2013 000 X X X X X XX – Crude Oil Transportation Agreement – 018 – 2013 144 ACTIVITIES CLASSIFIED AS OF A HIGH RISK OF MONEY LAUNDERING AND FINANCING OF TERRORISM FORM 1 VERIFICATION ACTIVITY YES NO A. Corporations, Foundations and non – profit entities B. Publicly Exposed Persons
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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 – DC- Crude Oil Transportation Agreement – 018 – - 009 - 2013 141 145 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 inform the management of the company about the possible faults or omissions in the controls for the prevention of criminal activities that compromise the liability of the employees and of the company DC – DC- Crude Oil Transportation Agreement – 018 – - 009 - 2013 142 146 ◦ To design, schedule and coordinate the training plans in that regard necessary for the different employees of the Company to be duly informed and updated. ◦ To report to the UIAF the suspicious operations determined Officers in General Each one of Cenit’s employees will be responsible to apply the controls designed by the Company in the processes in its charge that present any LA / FT risk factor. The following are the bodies for the control of the LA / FT risk management system: Audit Committee: ▪ To support the Ethics and Compliance Officer in determining the suspicious operations ▪ To carry out reviews of Cenit’s compliance manual whenever an update or review is made Internal Audit: The internal audit must include within its work goals programs for the verification of the compliance with the prevention, control and detecting of money laundering and financing of terrorism according to the law and to the internal procedures established by the company. Statutory Auditor: Are functions of the external auditor regarding the LA / FT risk management system: ▪ To instrument the controls that allow it to detect breaches of regulations in force applicable to Cenit regarding the prevention of LA / FT. Said activity includes the examination of the functions complied by the managers of the entity and the Ethics and Compliance Officer regarding the system implemented. ▪ To present a report to the Board of Directors and to the Ethics and Compliance Officer expressing the conclusions obtained in the process of evaluation of the compliance with the provisions regarding the prevention and control of money laundering and financing of terrorism. DC – DC- Crude Oil Transportation Agreement – 018 – - 009 - 2013 000 X X X X X XX – 147 F O R M S DC- Crude Oil Transportation Agreement – 018 – - 009 - 2013 144 148 ACTIVITIES CLASSIFIED AS OF A HIGH RISK OF MONEY LAUNDERING AND FINANCING OF TERRORISM FORM 1 VERIFICATION ACTIVITY YES NO A. Corporations, Foundations and non – profit entities B. Publicly Exposed Persons
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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 – Contrato de Transporte de Crude Oil Transportation Agreement – 018 008 – 2013 141 130 Crude Oil Offloading Agreement 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 inform the management of the company about the possible faults or omissions in the controls for the prevention of criminal activities that compromise the liability of the employees and of the company DC – Contrato de Transporte de Crude Oil Transportation Agreement – 018 008 – 2013 142 131 Crude Oil Offloading Agreement ◦ To design, schedule and coordinate the training plans in that regard necessary for the different employees of the Company to be duly informed and updated. ◦ To report to the UIAF the suspicious operations determined Officers in General Each one of Cenit’s employees will be responsible to apply the controls designed by the Company in the processes in its charge that present any LA / FT risk factor. The following are the bodies for the control of the LA / FT risk management system: Audit Committee: ▪ To support the Ethics and Compliance Officer in determining the suspicious operations ▪ To carry out reviews of Cenit’s compliance manual whenever an update or review is made Internal Audit: The internal audit must include within its work goals programs for the verification of the compliance with the prevention, control and detecting of money laundering and financing of terrorism according to the law and to the internal procedures established by the company. Statutory Auditor: Are functions of the external auditor regarding the LA / FT risk management system: ▪ To instrument the controls that allow it to detect breaches of regulations in force applicable to Cenit regarding the prevention of LA / FT. Said activity includes the examination of the functions complied by the managers of the entity and the Ethics and Compliance Officer regarding the system implemented. ▪ To present a report to the Board of Directors and to the Ethics and Compliance Officer expressing the conclusions obtained in the process of evaluation of the compliance with the provisions regarding the prevention and control of money laundering and financing of terrorism. DC – Contrato de Transporte de Crude Oil Transportation Agreement – 018 008 – 2013 000 X X X X X XX – 132 Crude Oil Transportation Offloading Agreement DC – 018 Contrato de Transporte de Crude Oil – 008 – 2013 144 133 Crude Oil Offloading Agreement ACTIVITIES CLASSIFIED AS OF A HIGH RISK OF MONEY LAUNDERING AND FINANCING OF TERRORISM FORM 1 VERIFICATION ACTIVITY YES NO A. Corporations, Foundations and non – profit entities B. Publicly Exposed Persons
Appears in 1 contract
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 – Contrato de Transporte de Crude Oil Transportation Agreement – 018 017 – 2013 141 143 Crude Oil Offloading Agreement Attachment E CENIT’S Compliance Manual 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 inform the management of the company about the possible faults or omissions in the controls for the prevention of criminal activities that compromise the liability of the employees and of the company DC – Contrato de Transporte de Crude Oil Transportation Agreement – 018 017 – 2013 142 144 Crude Oil Offloading Agreement Attachment E CENIT’S Compliance Manual ◦ To design, schedule and coordinate the training plans in that regard necessary for the different employees of the Company to be duly informed and updated. ◦ To report to the UIAF the suspicious operations determined Officers in General Each one of Cenit’s employees will be responsible to apply the controls designed by the Company in the processes in its charge that present any LA / FT risk factor. The following are the bodies for the control of the LA / FT risk management system: Audit Committee: ▪ To support the Ethics and Compliance Officer in determining the suspicious operations ▪ To carry out reviews of Cenit’s compliance manual whenever an update or review is made Internal Audit: The internal audit must include within its work goals programs for the verification of the compliance with the prevention, control and detecting of money laundering and financing of terrorism according to the law and to the internal procedures established by the company. Statutory Auditor: Are functions of the external auditor regarding the LA / FT risk management system: ▪ To instrument the controls that allow it to detect breaches of regulations in force applicable to Cenit regarding the prevention of LA / FT. Said activity includes the examination of the functions complied by the managers of the entity and the Ethics and Compliance Officer regarding the system implemented. ▪ To present a report to the Board of Directors and to the Ethics and Compliance Officer expressing the conclusions obtained in the process of evaluation of the compliance with the provisions regarding the prevention and control of money laundering and financing of terrorism. DC – Contrato de Transporte de Crude Oil Transportation Agreement – 018 017 – 2013 000 X X X X X XX – 145 Crude Oil Transportation Offloading Agreement Attachment E CENIT’S Compliance Manual F O R M S DC – 018 Contrato de Transporte de Crude Oil – 017 – 2013 144 146 Crude Oil Offloading Agreement Attachment E CENIT’S Compliance Manual ACTIVITIES CLASSIFIED AS OF A HIGH RISK OF MONEY LAUNDERING AND FINANCING OF TERRORISM FORM 1 VERIFICATION ACTIVITY YES NO A. Corporations, Foundations and non – profit entities B. Publicly Exposed Persons
Appears in 1 contract
