STATEMENT
At the Organization we reaffirm our commitment to and contribution toward the prevention of Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction (AML/CFT/PF) and other related offenses. We promote a Culture of Compliance that transcends legal and regulatory obligations, aligning ourselves with the highest international standards and best practices in the sector. Our management is grounded in the principles of integrity, responsibility, and sustainability, ensuring that our operations, business relationships, and value chain are carried out under ethical, responsible criteria and in compliance with the regulations in every country where we operate.
All employees and stakeholders of the Organization commit to:
- Strictly and unexceptionally comply with national and international regulations, as well as with the standards and best practices for the prevention of AML/CFT/PF, ensuring alignment with the regulatory framework of each country where we operate.
- Maintain a risk-based approach, based on a conscious assessment of the industry, operations, stakeholders, businesses, processes, distribution channels, and other factors that are part of what we do at the Organization.
- Operationalize this policy through the effective management of the AML/CFT/PF Risk Management System, which incorporates mechanisms aimed at identifying, mitigating, and controlling the risks of money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction. These mechanisms are applied transversally across all of the Organization's processes and businesses, ensuring regulatory compliance and the integrity of operations.
- Effectively implement the controls and procedures that develop the AML/CFT/PF Risk Management System, from the role and responsibility that corresponds to each individual within the framework of the Organization's internal control system.
- Apply due diligence in the knowledge of customers, suppliers, and other stakeholders, assessing the level of risk in terms of money laundering, terrorist financing, proliferation of weapons, and other AML/CFT/PF-related offenses before and during the business relationship, in accordance with the highest due diligence standards. At the Organization, we do not engage with third parties whose due diligence reveals legal and reputational risks.
- Systematically monitor the transactions, businesses, and processes of the Organization, in order to identify possible risk situations or opportunities for improvement that strengthen the AML/CFT/PF Risk Management System.
- Measure the level of compliance and define timely action plans together with process owners to ensure adequate management of AML/CFT/PF risks.
- Be a responsible agent in promoting integrity in relationships with stakeholders and in the development of businesses and processes, ensuring the effective application of the System and strengthening the Culture of Compliance.
- Actively participate in training on the AML/CFT/PF Risk Management System and all associated procedures and mechanisms adopted by the Organization.
- Reject any practice that could undermine the principles of Compliance, such as improper payments, simulated transactions, opaque structures, or transactions lacking legitimate economic justification.
- Integrate the elements of the AML/CFT/PF Risk Management System into all of the Organization's business and process projects and activities and consult the Compliance Officer on everything related to said System to ensure its integration and effective execution.
- Promote transparency and traceability in operations and records, ensuring that every transaction carried out by the Organization's companies has a legitimate economic justification and adequate documentary support.
- Maintain adequate evidence supporting the veracity and transparency regarding compliance with the obligations and responsibilities established by the AML/CFT/PF Risk Management System.
- Proactively cooperate with national and international regulatory and judicial authorities, providing truthful, complete, and timely information in supervision, inspection, or investigation processes.
Report any suspicious or alert-worthy situation detected in relationships with the various stakeholders and in the development of the Organization's businesses and processes. This report must be made through the Compliance Officer or the Organization's Ethics Line https://ethics.sofgenpharma.com/. The Compliance Officer is responsible for reporting any confirmed suspicious situation to the relevant authorities.