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We have a management and oversight system designed to guarantee compliance with regulatory requirements and fulfi l- ment of our external and internal obliga- tions and in all the countries where we operate.

The work of the Ethics and Compliance Offi ce has contributed to enhancing a cul- ture of compliance across the organiza-

tion. It has also improved procedures for identifying and monitoring compliance and integrity risks by establishing preven- tive and detective measures and penaliz- ing conduct that could result in corporate and personal liabilities; all in compliance with associated international standards such as ISO 19600 and ISO 37001.

5.2 ETHICS AND COMPLIANCE

Analysis of businesses/regulation/risks. Policies and processes. Training. Communications. Complaints channels. Integration of management processes.

Investigations. Checks. Controls.

Plan for fi nes. Traceability. Effective supervision.

CONTINUOUS IMPROVEMENT

PREVENTING DETECTING MITIGATING

512018 ANNUAL AND CORPORATE RESPONSIBILITY REPORT

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