CMI CAPITAL
SUSTAINABILITY REPORT 2020
2.1.2.1 Fight against Corruption CONTENT GRI 205-2, 205-3 Our fight against corruption is based on the Money Laundering Prevention Policy, and is applied to all our customer’s operations. Its application is carried out by management officials called Compliance Officers for our Real Estate Development and Finance Units. For the Energy Unit, this figure only exists in the operations in El Salvador.
sets. In the Energy Unit, each employee must sign a conflict-of-interest discharge, which allows us to support our commitment to prevent corruption.
These positions (except for the one in El Salvador, who is an external consultant) report to Senior Management and keep a close link with the Legal Area to ensure compliance with current regulations. We do not do business with people of dubious reputations or financing, on which there might be suspicions of illegal activities. The Real Estate Development Unit holds the chairmanship of the Committee of Real Estate Compliance Officers, which is in charge of unifying criteria of the real estate sector with the Bank Superintendence. On the other hand, in the Real Estate Development and Finance Units, we ask each of our associates to submit an annual declaration of as-
During 2020, we had no proven corruption cases.
2.1.2.1.1 Communication and training in anti-corruption policies and practices During 2020, we trained a total of 162 people in the Real Estate Development Unit on different Strategic Business Lines that make up the Unit, as follows:
Communication and training in anti-corruption policies and practices 2020 Positions:
Shopping malls
Corporate Business Complexes
Construction
Total Real Estate Development Division
Sales
#
%
#
%
#
%
#
%
#
%
Directors
0
0%
3
100%
0
0%
0
0%
3
100%
Managers
0
0%
10
100%
1
100%
1
100%
12
63%
Coordinators
27
100%
24
100%
17
100%
10
100%
781
100%
Administration
9
100%
42
100%
6
100%
12
100%
69
93%
Operations
0
0%
0
0%
0
0%
0
0%
0
0%
Total
36
100%
79
100%
24
100%
23
100%
162
100%
2.1.2.2 Preventing Money Laundering In Guatemala to prevent money laundering or other assets and financing of terrorism, we must ensure that all negotiations with business partners such as tenants in shopping malls are approved by compliance officers who review their respective files.
To reinforce the importance of these preventive actions by training on corporate values, we use the case analysis methodology. The cases are presented so that the attendees themselves can determine if the values have been violated or not. In addition, we invite our team to review the This regulation also applies to those who purchase a house in our resi- Prevention of Money Laundering or Other Assets and Financing Terrodential complexes, the companies that provide us with goods or servi- rism Policy. ces, and our employees. In the face of any reasonable evidence, we cut This document integrates multiple measures aimed at preventing opeoff the existing link with the person indicated in order to safeguard our rations that could launder the origin of goods and capital of dubious corporate image, by being sure that we are not exposed to or are party origin. This is a risk control measure of this practice, based on the review to commit a crime. of relevant and detailed information. Finally, at least twice a year we conduct trainings on this issue.
This data refers to two trainings per year in this work category.
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