Code of Ethics and Conduct
Directive Message
At VMS ENERGY we know that to fulfill our mission of generating economic and social value we must put into practice the values we have cultivated. Acting with respect, honesty and integrity is an essential part of our culture at VMS ENERGY.
The VMS ENERGY code of ethics is the basis of our business conduct and the foundation of our policies, procedures and guidelines.
Updating this code allows us to reinforce the trust of our collaborators, clients, suppliers, and authorities. The VMS ENERGY code of ethics formalizes our ethical principles in a single document, unifies criteria and establishes a common framework of reference that gives us direction to always act in a comprehensive manner.
It is a work tool that guides us to make the right decisions in accordance with our values. I invite everyone who is part of the VMS ENERGY family to read and constantly consult our code of ethics. It is also very important that you report any irregularity that you observe or detect to us.
I count on your support, enthusiasm and commitment to continue growing and building success stories, strengthening the reputation of VMS ENERGY.
Ethics System
The ethics system at VMS ENERGY has its fundamental basis in the manifestation of our values and performance criteria declared in the VMS ENERGY Code of Ethics and Conduct. The Anti-Corruption Policy that expresses our commitment to compliance with current legislation and the anti-corruption system and the Corporate Social Responsibility Policy that regulates the interaction with our interested parties under ethical and transparent behavior.
Compliance with this value system is guaranteed through an Ethics Committee, an entity described to the General Management whose action criteria are the VMS ENERGY policies, the internal work regulations and the dispute resolution procedure. Our ethics system is deployed in the organization through the exercise of leadership in positions with responsibility and the use of clear communication channels free of retaliation (complaints box on the internal VMS page and external complaints box on the website) supported by a training program on specific topics of ethics and conduct.
Code of Ethics
INTRODUCTION
VMS ENERGY is a Mexican company that offers quality services for sale in electrical energy generation and distribution systems, with more versatile and sustainable solutions for our clients.
VMS ENERGY has defined five values that will help us fulfill our mission and that must be reflected in our daily actions. These values are the following:
- Truth: We strive to say what is true, authentic and in accordance with what happens, which allows us to be respected and recognized as a company that can be trusted.
- Motivation: We remain in this state to complete the agreements established with all our interested parties.
- Health and Safety: It is essential to be able to carry out our tasks without exposing anyone.
- Environment: Preserving our environment is a crucial part of our company.
- Nobility: We identify ourselves by not having ulterior motives in dealing with other people; Do not take advantage of the possible weaknesses or situations of inferiority of other individuals.
- Efficiency: We are committed to energy consumption and emissions reduction.
The Code of Ethics has been established as a framework of reference based on the reason for our vision and the principles that inspire our daily behavior.
Our Code of Ethics covers a wide range of business situations and procedures, however, its scope does not lie in detailing the decision for each situation, but rather in defining the key principles that are the guide for our stakeholders. In this sense, every person who collaborates in VMS ENERGY must conduct their actions in accordance with the language and essence of this Code, in addition to avoiding behavior that appears to be incorrect.
The commitment of those of us who work at VMS ENERGY is to give life to this document, through its application in all our actions, and always in compliance with the legislation of the places where we operate projects. We are convinced that a culture based on these principles strengthens our virtues and competencies. At the same time, it contributes to increasing, in a sustained manner, the value of the company for all interest groups: employees, community, suppliers, customers, shareholders, environment.
To whom does this code of ethics apply?
The Code of Ethics and Conduct and VMS ENERGY policies apply to all collaborators and interested parties.
Ultimately, each person is responsible for compliance with the laws, regulations, policies, procedures and guidelines applicable to their activity.
How to Report Code Violations:
VMS ENERGY fosters a culture of communication where employees can raise their COMPLAINTS AND SUGGESTIONS.
We invite all collaborators to express their views, defend their opinions and point out unacceptable behaviors and requests.
Employees may have concerns about certain practices and need advice and guidance to resolve them. Our policy dictates that any report of lack of professional ethics by the company, its collaborators, or even any third party with whom the company has contact will be thoroughly investigated, and appropriate measures will be taken, regardless of who is involved.
The route to pose a complaint in VMS Energy It is through two systems:
– Complaints and suggestions mailbox shared on the company website.
– Shared internal page (cloud).
If the situation is not resolved through this channel, you can contact the
Ethics Committee through number +523332181927 / +52 3321846905
RESPONSIBILITY OF STAFF AND INTERESTED PARTIES:
In compliance with this document, collaborators and interested parties have the obligation:
- a) Report to the competent authority and through the defined communication channels, queries, complaints and reports about acts or possible acts of bribery; as well as non-compliance with the established anti-bribery policy.
- b) Demonstrate commitment to the company to ensure compliance with the anti-bribery policy and the requirements of the anti-bribery management system.
- c) Understand and raise awareness regarding the importance of their daily activities and responsibilities, to contribute to compliance with the anti-bribery policy.
ETHICS COMMITTEE:
VMS ENERGY has an internal committee that regulates and promotes the application of the code of ethics. This committee must:
- a) Promote the submission of queries, complaints and reports in good faith, regarding acts or possible acts of bribery, in confidence and without fear of reprisals.
- b) Save and reserve the facts that are known in the investigative process and when it is information subject to confidentiality, use it only for the purposes provided for by law.
- c) Ensure the mitigation and elimination of the risk of retaliation against workers and interested parties who report, in good faith, acts or possible acts of bribery; as well as non-compliance with the established anti-bribery policy.
- d) Ensure the non-admission of false, reckless or bad faith complaints.
NO RETALIATION:
A collaborator who raises concerns in good faith will be protected from any retaliation. Likewise, the employee who believes that he or she is being subjected to retaliation must make it known through the same channels mentioned above.
We will ensure a fair process in the event of an investigation and respect the principles of confidentiality and presumption of innocence. Furthermore, any investigation must comply with current local legislation, especially with regard to the formal process.
In the course of an ethical investigation, it is mandatory that all persons involved cooperate fully and all information must be provided immediately upon request.
The person involved will be informed of the nature of the accusations made against them. You may not be informed immediately if, for example, it is necessary to verify facts, protect evidence or contact the relevant competent authorities.
All information communicated will be known only to those people who have a legitimate reason for doing so, either to ensure that the complaint is addressed or that appropriate measures are taken.
We will provide the results of the investigation to the person who raised the concern to the extent that it is appropriate and does not breach legal requirements or other confidentiality obligations.
Any accusation that is confirmed to be slanderous or made in bad faith may lead to disciplinary measures.
If you deliberately fail to comply with the Code of Ethics and Conduct or any applicable local law, you will be held personally accountable or subject to disciplinary action up to and including termination by the company, so it is essential that you know what is expected of you.
VMS Energy has a complaints and suggestions mailbox that ensures the confidentiality, anonymity and protection of complainants.
CODE VIOLATIONS:
It is the obligation of all VMS ENERGY personnel to comply with the provisions of this Code.
VMS ENERGY undertakes to analyze all reports of possible violations of this Code, entered through the complaints and suggestions mailbox.
The VMS ENERGY internal committee will be in charge of applying disciplinary sanctions in accordance with the applicable provisions which, depending on the severity of the case, can range from a reprimand through an administrative letter to termination of the employment relationship.
The consequences of failing to comply with the contents of this Code of Ethics, in addition to the labor-related sanctions previously indicated, may result in actions or sanctions of an administrative, civil or even criminal nature that will be applied by the competent authorities.
RELATIONSHIP GUIDELINE
RELATIONSHIP WITH THIRD PARTIES:
At VMS ENERGY we respect, consider and respond to the expectations and needs of our stakeholders.
- Our business relationships will be conducted in accordance with the company's ethical principles.
- In our commercial practices, strict compliance will be given to what is established regarding anti-corruption.
- We are committed to hiring people or supplier companies that engage in any practice that does not adhere to the Code of Ethics established by VMS ENERGY.
- We encourage the adherence of suppliers and contractors to this Code and the commitment to high ethical standards.
ANTI-BRIBERY:
At VMS Energy de México, we have the policy of developing all our businesses and contracts with ethics, integrity, and zero tolerance for public or private bribery, which is why we demand the same commitment and behavior from our collaborators, partners, suppliers and clients. Our policy is applicable to collaborators involved in the VMS Energy de México production chain by applying the following points:
Must:
- Ensure that our partners and intermediaries are aware of our Code and policies, and specifically commit to adhering to them when acting as company representatives in countries where there is a high risk of corruption.
- Report immediately through the complaints and suggestions channel if you observe any activity that could go against our corruption prevention policy.
- Report immediately through the complaints and suggestions channel if you are faced with extortion or attempted extortion, for example, cash payments or offering another object of value to prevent harm to an employee or representative, and properly document the request.
- Offer, promise or give money or objects of value (gifts, invitations, etc.) to employees or representatives of other companies that could induce them to breach their duty of loyalty towards your company.
- Accept or request money or objects of value (gifts, invitations, etc.) that could induce us to breach our duty of loyalty or influence a business relationship.
- Using third parties to do something that we are not allowed to do or that we did not personally want to do. This means that we must carefully select and monitor our advisors, subcontractors, agents and partners.
- a) Offer or give, directly or indirectly, gifts, invitations, hospitality, displays of hospitality or the equivalent in money to any Client, suppliers, users or third parties, with the purpose of seeking influence or an effect on a company process, or if it is expected that the favor must be returned seeking to gain an improper advantage.
- b) Directly or indirectly accept gifts, invitations, hospitality, displays of hospitality or the equivalent in money from any supplier, users or third parties, in order to gain an improper advantage or that may otherwise give rise to a conflict of interest. These gifts will be channeled to the human resources department to be raffled among all VMS ENERGY employees.
- c) Involve in any way in an act or possible act of bribery, either directly or through a third party; as well as, inducing a person to act illegally or inappropriately.
- d) Hide, change, omit records to conceal improper activities.
- e) Ignore or fail to report to the relevant authorities any sign that acts or possible acts of bribery have been carried out in the institution.
PREVENTING MONEY LAUNDERING:
At VMS ENERGY we understand money laundering as carrying out financial transactions designed to hide the origin and ownership of money when it comes from illegal activities or activities not regulated by current laws.
VMS ENERGY maintains transparency and accounting-financial record practices in accordance with current laws and regulations. Our accounting practices prevent cash flows from the company's business activities from being used for money laundering or outside the law. We have procedures to verify the identification of clients and suppliers in financial transactions, and we report any unusual activity or information to the competent activities.
UNDUE PAYMENTS:
Our staff, suppliers, customers and anyone carrying out activities on behalf of VMS ENERGY or in connection with its business are strictly prohibited from offering, paying or authorizing the payment of money or any Item of Value, whether directly or indirectly through any other person, to any person.
a) SUPPLIERS, SERVICES AND EXTERNALS:
These standards also apply to third parties acting on our behalf or on our behalf or for our benefit. Our suppliers, services, representatives or any external party that carries out activities that are entrusted by VMS ENERGY in relation to its business must not make improper payments or take any other action or measure that contravenes this code of ethics.
b) NEGOTIATIONS WITH OUR CLIENTS
Our goal is to become the best supply, training, maintenance and service option for our clients, establishing long-term relationships based on trust and credibility.
This is why:
- Our principle is to offer only what we can fulfill.
- We fulfill the commitments agreed with our clients.
- We are committed to the veracity and timeliness of the information required in negotiations with our clients.
c) FACILITATION PAYMENTS:
Facilitation Payments are strictly prohibited by this Policy. In some countries, these types of payments may be considered common commercial or normal practice to ensure the performance or expediting of some government action or routine agency, however, they are not permitted or accepted by VMS Energy in accordance with its standards and way of conducting its business.
Political contributions:
a) Those of us who participate in political activities of any jurisdiction do not involve VMS ENERGY, clearly establishing that we act in a personal capacity and not on behalf of the company.
b) We respect the ideologies of our collaborators and we actively participate in the exchange of ideas with politicians or political entities, but we do not use them to benefit our business interests.
Conflicts of interest:
- Make all decisions without being influenced by factors beyond professional judgment, always ensuring that an image of impartiality is offered.
- Prevent personal interests from prevailing over those of the Firm.
- Act legally and ethically in the event of any conflict of interest.
PERSONAL AFFECTIVE RELATIONSHIPS AT WORK:
With the aim of preserving a professional, productive and conflict-free work environment, the absolute prohibition of maintaining emotional relationships between colleagues within the work areas is established. This measure is implemented to avoid possible interference in work performance, conflicts of interest, undue favoritism, as well as to guarantee respect and equity among all team members. Any violation of this policy will be subject to disciplinary action, which may range from reprimands to termination of employment, depending on the severity of the situation and the particular circumstances involved.
ENVIRONMENTAL CONDITIONS:
Environmental responsibility is an integral part of VMS Energy processes under the following standards:
1) Environmental permits and reports: All required environmental permits must be obtained (for example, control of water discharges), approvals and registrations must be obtained, maintained and kept up to date, and operational and reporting requirements must be adhered to.
2) Pollution prevention and resource reduction: The use of resources and the generation of waste of all types, including water and energy, will be reduced or eliminated at source or through practices such as process modification, material replacement, conservation, recycling and reuse of materials.
3) Hazardous substances: Chemicals and other materials that pose a risk if released into the environment should be identified and managed to ensure their safe handling, transportation, storage, use, recycling or reuse, and disposal.
4) Liquid and solid waste: VMS Energy is committed to responsibly identifying, managing, reducing and eliminating or recycling solid waste (Non-hazardous). In addition, measures will be implemented to reduce the generation of liquid waste.
5) Emissions: Air emissions of volatile organic chemicals, aerosols, corrosive materials, particles, chemicals that affect the ozone layer and combustion derivatives must be monitored, controlled and treated, as necessary, prior to discharge.
6) Material restrictions: VMS Energy will comply with all laws, regulations and customer requirements related to the prohibition or restriction of specific substances in products and their manufacturing, including labeling for recycling and disposal.
HUMAN RIGHTS:
VMS ENERGY brings together collaborators with a wide variety of career paths, skills and cultures. The combination of such a wealth of talent and resources creates diverse and dynamic teams that constantly drive us toward success.
Must:
- Treat others in a respectful and professional manner.
- Be aware of local behaviors and customs that may be different from what you are used to, show sensitivity to differences, and be prepared to adapt your behavior accordingly when traveling or working in another office or country.
We must not:
Discriminate, harass or intimidate anyone based on:
- Sex.
- Disability.
- Marital status or family situation.
- Sexual orientation.
- Age.
- Political and philosophical opinions.
- Religious beliefs.
- Ethnic, social, cultural or national origins.
This prohibition against discrimination applies not only to the hiring of personnel, but also to decisions related to training, promotion, continued employment and working conditions in general, as well as to relationships with suppliers, customers, business partners and third parties.
HARASSMENT-FREE WORKPLACE:
Unwanted or annoying behavior by any VMS ENERGY employee that harasses another person, disrupts another's work or creates an intimidating, offensive, abusive or hostile work environment will not be tolerated.
This includes bullying, abuse of authority, excessive use of profanity, or any other form of aggression or hostility that may create a climate of intimidation.
Sexual harassment is a form of harassment that usually occurs when:
- Annoying actions are made as a condition of employment or when employment decisions are based on actions such as a request for a date, a sexual favor, or any other similar conduct of a sexual nature.
- An intimidating, offensive or hostile work environment is created through an annoying sexual advance, an offensive joke or any other offensive behavior, verbal or physical, of a sexual nature.
Must
- Support and encourage VMS ENERGY's commitment to being a workplace free of harassment and intimidation.
- Be polite: Treat our co-workers and partners as we would like to be treated.
- Avoid unwanted behavior, signs, contacts, insinuations, rumors, obscene language, jokes, compliments or compliments with sexual connotations or intentions, as they are prohibited and will be punished.
- Refrain from showing or sending images of a sexual nature.
- Respect the private life of others.
We must not:
- Using bad words, referring to other people using derogatory names or comments, or verbal abuse.
- Make comments, jokes or materials, including emails, that others may find offensive.
- Carry out workplace harassment, threats or abuse of authority.
- Make comments, gestures or physical contact that are annoying.
- Display sexually explicit conduct, offensive images or any other material that is humiliating to other people.
PERSONAL INFORMATION:
We all have the right to privacy. VMS ENERGY is committed to respecting the confidentiality of the personal information of its counterparties, including its collaborators, clients and partners. VMS ENERGY only obtains and retains such data because it is necessary for effective operation.
Must:
- Ensure that the people we collect data from know the type of information we are collecting, what it will be used for and how they can contact us if they have questions.
- Collect only necessary personal data.
- Destroy or correct erroneous or incomplete data.
- Ensure that such data is stored securely.
- Ensure that we only provide this data to authorized persons, on a strict “need to know” basis.
- Please seek legal advice before transferring this personal data outside the country in which it was collected.
- Respect the right to privacy of our colleagues.
- Ensure that the third parties to whom we delegate the management of this information or who use the data comply with these principles.
We must not:
- Collect “sensitive” information (especially data on health, ethnic origin, sexual orientation, political ideology and religion) without the consent of the person involved and only in accordance with the law.
- Provide personal data outside of VMS ENERGY unless legally required, when we use technical service providers or when we have authorization.
DISCLOSURE OF INFORMATION:
Information related to labor, health and safety, environmental practices, business activities, structure, financial condition and performance of the participant will be disclosed in accordance with applicable regulations and prevailing industry practices. Falsifying records or falsifying conditions or practices is considered unacceptable.
DONATIONS AND DONATIONS:
Contributions, contributions, support or donations with political or electoral overtones or purposes to any person or entity, or those that are made as a means to obtain an objective or negotiation that would not have been obtained otherwise, are not permitted. If any type of donations to charitable entities are requested through a government or private official (customers and suppliers), these must be previously authorized by the General Directorate. In any case, Employees must immediately inform both their immediate boss and the Human Resources Management of VMS ENERGY of any requirement or request for a payment or other object of value made by or for the benefit of a government or private official.
We must not:
- Oblige collaborators or partners to donate gifts or funds for philanthropic projects in which VMS ENERGY participates.
- Involve VMS ENERGY in actions that do not reflect our ethical principles.
CONTROL AND FINANCIAL RECORDS:
This code of ethics prohibits falsification, alteration of books and accounting records; and requires compliance with certain accounting provisions, in accordance with applicable tax legislation. The purpose of the accounting books and records provisions is to prevent the concealment of bribes, improper payments or fraudulent accounting practices. The provisions on accounting books and records require the following: Maintain books, accounts and records that accurately reflect the financial situation of VMS ENERGY, as well as all operations or transactions of the company.
Must:
- Accurately record transactions. Guide by the principles of transparency and truthfulness.
- Write, thoroughly and clearly, in all your business communications including emails. Write being aware that, one day, records may become public documents.
We must not:
- Never provide incorrect or inaccurate information, or information that could confuse the person receiving it.
- Conceal the true nature of any transaction.
- Never destroy documents as a result of or in anticipation of an investigation or audit.
Anti-Bribery Policy [Discipline: QHSE+]
Establish moral and ethical standards that allow prohibiting, preventing, detecting and punishing all types of acts of bribery; guaranteeing transparency with collaborators and interested parties, fully complying with the applicable requirements, thus promoting the continuous improvement of the organization.
Conduct that violates the anti-bribery policy must be reported to the ethics committee, which will be subject to their respective administrative disciplinary, civil and/or criminal sanctions.
Reports made in good faith or based on reasonable belief will be protected under the confidentiality of information without risk of retaliation.
1. General Obligations of collaborators and interested parties: In compliance with this document, collaborators and interested parties have the obligation:
- d) Report to the competent authority and through the defined communication channels, queries, complaints and reports about acts or possible acts of bribery; as well as non-compliance with the established anti-bribery policy.
- e) Demonstrate commitment to the company to ensure compliance with the anti-bribery policy and the requirements of the anti-bribery management system.
- f) Understand and raise awareness regarding the importance of their daily activities and responsibilities, to contribute to compliance with the anti-bribery policy.
2. Obligations of the personnel in charge of investigating and processing complaints: To maintain an anti-bribery management system that fosters a culture of detection and action in cases of bribery, the personnel in charge of investigating and handling complaints must:
- e) Promote the submission of queries, complaints and reports in good faith, regarding acts or possible acts of bribery, in confidence and without fear of reprisals.
- f) Save and reserve the facts that are known in the investigative process and when it is information subject to confidentiality, use it only for the purposes provided for by law.
- g) Ensure the mitigation and elimination of the risk of retaliation against workers and interested parties who report, in good faith, acts or possible acts of bribery; as well as non-compliance with the established anti-bribery policy.
- h) Ensure the non-admission of false, reckless or bad faith complaints.
- f) Offer or give, directly or indirectly, gifts, invitations, hospitality, displays of hospitality or the equivalent in money to any Client, suppliers, users or third parties, with the purpose of seeking influence or an effect on a company process, or if it is expected that the favor must be returned seeking to gain an improper advantage.
- g) Accept directly or indirectly gifts, invitations, hospitality, displays of hospitality or the equivalent in money from any supplier, users or third parties, in order to gain an improper advantage or that may otherwise give rise to a conflict of interest.
- h) Get involved in any way in an act or possible act of bribery, either directly or through a third party; as well as, inducing a person to act illegally or inappropriately.
- i) Hide, change, omit records to conceal improper activities.
- j) Ignore or fail to report to the relevant authorities any sign that acts or possible acts of bribery have been carried out in the institution.
NOTE:
A) When gifts of an unacceptable nature are received, they must be delivered to the human talent department, to be raffled among VMS ENERGY staff at an event organized by the department.
B) Meal invitations to interested parties will be authorized by general management.
C) When services or visits are carried out in areas controlled by groups and they request facilitation through passage, this action must be authorized by management.
SOCIAL RESPONSIBILITY POLICY
1.-INTRODUCTION
The Corporate Social Responsibility (CSR) Policy is constituted as a framework influenced by the values of our company, which aim to positively impact the communities with which we interact and improve and protect the environment.
2.-SOCIAL RESPONSIBILITY
Its objective is to align the business strategy focused on permanent growth in the level of security in the environment, the community and the organization to address global issues of sustainable development; considering the needs and expectations of interest groups.
It is the responsibility of the company for the impacts of its decisions and activities on society and the environment, through ethical and transparent behavior.
3.-RESPONSIBLE PRACTICES
Comprehensive Management System (SGI): Manages the way in which projects are developed at vms energy, becoming a modeler of organizational culture through industrial safety and occupational health management tools (ISO 45001), quality (ISO 9001) and environment-related (ISO 14001), anti-bribery system (37001) and energy efficiency (ISO 50001).
SUPPLIERS:
Enable an agile and transparent communication channel to offer an identifiable and effective management model for the acquisition of goods and services in accordance with the ethical, social, quality and environmental requirements established by the company.
Guarantee a procedure based on objectivity, transparency and non-discrimination, in coherence with the principles included in the VMS ENERGY Code of Ethics.
CUSTOMERS:
To offer sales and quality services in power generation and distribution systems, with more versatile and sustainable solutions for our customers.
COMMUNITY:
In alliance with civil society organizations, we contribute within the communities where we operate to generate positive social impact and grant the social license to operate.
COLLABORATOR:
We provide employment and growth opportunities within a work environment distinguished by high standards of job security, which translates into well-being for those who make up the VMS ENERGY team.
COMMITMENT TO SOCIETY:
Act in a socially responsible manner, in compliance with the laws, assuming the responsibility of respecting cultural diversity and the customs and principles in force among the people affected by its activities.
TRANSPARENCY:
- Disseminate relevant and truthful financial and non-financial information about the performance of the company's activities as specified in the Code of Ethics.
- Maintain responsible, fluid and two-way communication with the main interest groups, professionals, clients, suppliers and Society.
COMMITMENT TO THE ENVIRONMENT:
- Contribute to better management of environmental resources and the fight against climate change.
- Promote energy efficiency in the company's facilities.
- Raise awareness among employees about the importance of sustainable activities.
RESPECT FOR HUMAN RIGHTS:
Respect human rights and individual freedoms, the construction of democracy and freedom of expression. Quality education and information with rigor and independence are the guarantee of the future for responsible citizenship. In particular, VMS ENERGY expresses its total rejection of child labor and forced or compulsory labor.
GOVERNMENT:
We operate under strict regulatory compliance.
COMMITMENT
- Comply with the law and promote transparency in operations.
- Properly manage resources, energy and waste management.
- Promote the personal, family, work and social development of all staff.
MECHANISMS
- VMS ENERGY Philosophy
- Code of Ethics.
- Internal Regulations.
- Comprehensive Management System (SGI).
INTERNAL ANTI-MONEY LAUNDERING POLICY
At VMS Energy de México we are committed to preventing and combating money laundering and terrorist financing by implementing effective measures that ensure compliance with relevant laws and regulations.
Know Your Customer (KYC)
- Customer Identification: All customers must provide valid and verifiable identification documents prior to opening an account or conducting any significant transaction. Acceptable documents include passports, national IDs, and driver's licenses.
- Identity Verification: The institution will carry out verification procedures to confirm the authenticity of identification documents. Verification technologies will be used, such as document validation through government databases.
- Client Risk Assessment: Clients will be classified into risk categories (low, medium, high) based on factors such as occupation, origin of funds, and geographic location. High-risk clients will have more intensive monitoring.
Transaction Monitoring
- Monitoring System: A transaction monitoring system will be implemented that will detect unusual or suspicious activities based on predefined transaction patterns.
- Activities Review: Transactions that exceed certain pre-established thresholds or show unusual patterns will be reviewed by compliance staff.
Suspicious Activity Reports
- Reporting Procedure: Employees must immediately report any suspicious activity to the institution's Compliance Officer. A Suspicious Activity Report (SAR) must be filed if it is determined that the activity could be related to money laundering or terrorist financing.
- Confidentiality: Reports and details related to suspicious activities must be treated with the utmost confidentiality.
Training
- Initial Training: All employees will receive training on anti-money laundering policies and procedures upon onboarding.
- Continuous Training: Ongoing training will be offered to keep staff up to date on the latest regulations and prevention techniques.
Internal Policies and Procedures
- Documentation: All internal procedures related to the prevention of money laundering will be documented and updated regularly.
- Policy Review: The policy will be reviewed and updated at least annually to reflect changes in legislation and best practice.
Audit and Review
- Internal Audits: Periodic internal audits will be carried out to evaluate the effectiveness of anti-money laundering policies and procedures.
- Corrective Actions: Areas of improvement identified during audits will be addressed through corrective actions.
Compliance and Sanctions
- Responsibility: All employees have the responsibility to comply with this policy and applicable anti-money laundering laws.
- Sanctions: Violations of this policy may result in disciplinary action, including termination of employment and legal action.
Sincerely:
Victor Octavio Pacheco Gomez
General Director VMS Energy de México S de RL de CV