We recognize that corruption is a significant threat to sustainable development and good governance, and we are determined to combat it in all its forms. This anti-corruption policy sets out the guidelines and procedures for preventing, detecting, and addressing any corrupt activity within our organization.
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Scope of Application

This policy applies to all employees, officers, board members, consultants, contractors, and anyone acting on behalf of PANDATECH. It is also applicable to relationships with third parties, including suppliers, customers, and business partners.

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Definitions

  • Corruption: Abuse of power for personal gain, including but not limited to bribery, extortion, fraud, embezzlement, and money laundering.
  • Bribery: The offer, promise, delivery, acceptance, or solicitation of an undue advantage as inducement to perform an illegal or dishonest action.
  • Conflict of Interest: A situation in which an employee's personal interests may influence, or appear to influence, his or her professional performance and company decisions
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Guiding Principles

· Integrity: All employees must act honestly and transparently in all business activities.

· Compliance: Comply with all applicable laws and regulations related to anti-corruption.

· Accountability: All employees are responsible for reporting any suspected corruption or illicit activities.

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Prohibitions and Obligations

  •  Prohibition of Bribery:It is strictly forbidden to offer, give, receive, or solicit bribes under any circumstances.
  • Gifts and Hospitality:Gifts, hospitality, or other benefits that may influence, or appear to influence, business decisions should not be offered or accepted.
  • Conflicts of Interest: Employees should avoid situations where their personal interests may conflict with the interests of the company. Any potential conflicts should be properly reported and managed.
  • Donations and Sponsorships: Donations and sponsorships must be transparent, duly authorized, and recorded. They should not be used as a means of obtaining undue advantages.
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Reporting and Management Procedures

· Whistleblowing Channels: PANDATECH provides several secure and confidential channels for reporting suspected corruption, including an anonymous whistleblower line and a dedicated email address.

· Whistleblower Protection: Protection from retaliation will be guaranteed for those who report corrupt activity in good faith.

· Investigation and Sanctions: All allegations of corruption will be investigated thoroughly and impartially. Appropriate disciplinary action will be taken against anyone who violates this policy, which may include termination and criminal prosecution.

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Training & Awareness

  • Ongoing Training: All employees will receive regular training on the company's anti-corruption policies and procedures.

  • Awareness: The company will promote a culture of integrity and transparency through awareness campaigns and the dissemination of good practices.
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Review & Update

This policy will be reviewed and updated periodically to ensure its effectiveness and adaptation to changes in legislation and the business environment.

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Responsibilities

  • Senior Management: PANDATECH senior management has the ultimate responsibility for ensuring compliance with this policy.
  • Compliance Department: The Compliance Department is responsible for the implementation, monitoring, and review of this policy.
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Conclusion

At PANDATECH we do not tolerate corruption in any form. We are committed to maintaining the highest standards of ethics and continuously working to prevent and combat corruption in all our operations.

This policy is a living document and forms an integral part of our commitment to ethics and integrity in all our business activities.