Common use of Ethics and Compliance Officer Clause in Contracts

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.