1.5 Ethics and
Compliance
1.5.1 Ethical Conduct
(GRI 2-23, 2-24, 2-25, 2-26, 2-27, 205-1, 205-2, 205-3, 206-1, 410-1, 412-1, 412-2, 412-3, 414-1) (SASB FN-CB-510a.2, FN-AC-510a.2)
The Ficohsa Group reafirms its commitment to ethical conduct consistent with its corporate values and compliance with its existing
self-regulation mechanisms, as well as with the regulations and legislation in force in the countries where it operates.
It has a Code of Ethics and Conduct, which is periodically updated according to the needs of the Group and its environment, and is applicable regionally to all its companies. It also has Codes for Suppliers and Clients, which establish the guidelines to follow for strong business relationships.
See the Code of Conduct for Suppliers
See the Code of Conduct for Clients
There is also a Conflict of Interest Policy, which is part of the Corporate Governance Manual and applies to both clients and employees.
See the Conflict of Interest
Policy (page 62)
1.5.2 Reporting and
concerns channel
Ficohsa has a secure, easy, confidential and anonymous platform to report unethical behavior or integrity. The system is operated by a third party, independent report management specialist called EthicsGlobal. It also has other totally anonymous and private reporting channels that strengthen confidentiality, such as:
Know the reporting channels
The follow-up of reported or identified cases is carried out by the Ethics Committee, an advisory and resolving body, functionally independent and solely subordinate to the Board of Directors; whose sole purpose is to ensure compliance with the Code of Ethics and Conduct by all employees of all companies in the group, it is composed of five full members, five alternate members and a secretary. This body is responsible for assessing possible sanctions, according to each of the offenses.
For the follow-up of cases with groups outside the organization, we have the support of an independent third party, in charge of carrying out the analyses and reporting them directly to the Ethics Committee.
1.5.2.1 Anti-Corruption and Bribery
Management System (SGAS)
As a success story, the ABMS has 4 years since its implementation; over this period it has provided FG with strong methodologies in mitigating the risks of corruption and bribery.
A review of the system’s components is conducted annually; among these, the update of the corruption and bribery risk event matrix is key. Each process integrates the potential corruption and bribery risks to which they are exposed and determines the controls necessary to mitigate them.
It has a specialized process for granting credit products to Politically Exposed Persons (PEPs), allowing for adequate reputational risk
management.
The SGAS has a regional scope and has been designed as a component that complements and strengthens the Compliance Program for the Prevention of Money Laundering, Terrorism Financing, and the Financing of the Proliferation of Weapons of Mass Destruction (LAFTFP).
There were 106 escalations of cases related to PEP at the regional level, of which 88% were recommended, allowing the operation to continue its process and for 12% no granting was recommended.
One of the mechanisms to strengthen the ESMS is Ficohsa’s commitment to ongoing training and awareness-raising through an
annual training plan designed to consider the competencies of both new hires and permanent employees.
The ESMS’s scope is based on the Anti-Corruption and Bribery Policy, which establishes guidelines for expected conduct for directors, oficers, employees, and counterparties. It emphasizes zero tolerance for corruption and bribery practices in GF’s activities. This document is available on the internal information portal.
The Integrity Committee is the operational pillar of the ESMS, and its purpose is to ensure the application, execution, and maintenance of the entire system.
Among its main
attributions:
Receipt, investigation and resolution of complaints.
Manage the appropriate disciplinary measures or actions.
Ensure that all staff are aware of and have access to confidential reporting procedures.
Coordinate and promote ongoing training on the ABMS.
Reputational risk analysis of potential business with politically exposed people, in funding applications.
Featured Activities:
Presentation of the ABMS and related cases to the United States Treasury.
Partnership for Central America (PCA) and Transparency International launched the ACT Project, which is an initiative against dishonesty in the management of public finances and in favor of corporate transparency in Central America.
Representation of Ficohsa Group in the first working table of PCA and Transparency International.
Certification ISO 37301:2021 Compliance
Management System (CMS)
In 2024, the implementation and external audit process, conducted by representatives of the certifying body (INCOTEC), was successfully completed, making Ficohsa the first financial institution in Honduras and one of the first in the region to obtain this certification.
This international certification endorses the Compliance Management System, which is part of the high-level structure and addresses the organization transversally, starting with the governing body, observing legal and regulatory obligations. It also ensures the company’s ability to manage compliance risks, comply with regulations, safeguard its reputation, and strengthen the trust of its clients, stakeholders, supervisors, investment banks, correspondent banks, among others. It provides tools for analyzing the organization’s context, promoting leadership, planning, support, performance evaluation, and systematic continuous improvement.
To achieve a Compliance Management System certification, organizations must demonstrate their commitment, among other aspects:
Comply with relevant laws and regulatory requirements.
Comply with industry and organizational standards.
Strengthen governance, empowering leadership through a
strong culture of compliance.
Systematically promote accepted best practices
(continuous improvement).
Commitment to the ethics and expectations of relevant
stakeholders.
Scope of the Certification
The ISO 37301 certification covers administrative control activities for regulatory compliance in a wide range of services, including deposits, placement, corporate, business, mortgage, private, and personal banking, remittances, and trusts, both through physical and digital channels. It also covers operations at the Plaza Victoria and Plaza Ficohsa locations in Tegucigalpa.
Principles of the System
The Compliance Management System through
ISO 37301 integrates the PDVA model (Plan – Do – Verify – Act)
Compliance System Policy (CMS) of Ficohsa Honduras Bank
Ficohsa Bank provides the most innovative financial products and services with high quality standards and the latest technology, delivered by qualified personnel. This generates security and satisfaction for those who have placed their trust in us, always committed to being a socially responsible company. This commitment is:
Comply with and enforce the applicable requirements, including compliance obligations.
Continuously improve the Compliance Management System.
Encourage the raising of concerns, prohibiting any kind of retaliation.
The Vice President of Compliance is responsible for overseeing the operation of the Compliance Management System and has been appointed by the Board of Directors. To ensure its authority, autonomy, and independence in the exercise of its functions, it is provided with the necessary resources to acquire the appropriate skills and has direct access to the Governing Body.
Failure to comply with the obligations, policies, processes, and procedures of the Compliance Management System could result in consequences related to comprehensive risks.
1.5.3 Compliance
(GRI 419-1) (SASB FN-CF-220a.2, FN-CF-270a.5, FN-MF-270a.3,
FN-CB-510a.1, FN-AC-510a.1, FN-IB-510b.4)
This commitment is reflected in the development of best practices in our activities and businesses to ensure strict compliance with current laws and ethical behavior. To achieve this, all policies, codes, processes, and the Anti-Corruption and Bribery Management System (ASMS) are designed to strengthen the organization and ensure transparency in each of our operations by preventing fraud and money laundering and protecting user data.
At the regional level, there is a Vice President of Compliance who engages with the leaders of the Group’s Audit and Compliance Committee. The leaders in each country are also involved, which is key to overseeing the application of standards and the e ectiveness of internal controls.
During this year, no sanctions were recorded for noncompliance with national and local regulations in Guatemala, Nicaragua, Panama, and El Salvador. In Honduras, a monetary penalty of USD $8,000 was imposed for late submission of information to the National Banking and Insurance Commission.
Ficohsa, an organization that seeks to mitigate and maintain efficiency in its processes, periodically evaluates its compliance program by an independent firm specializing in risk management with global reach, which supports the adoption of top-level procedures.
The company’s commitment to customer compliance remains unwavering, o ering financial products with the highest standards of transparency. To this end, it has developed a marketing, communications, and sales strategy that highlights the features and specifications of each of its products, such as fees, interest rates, and restriction clauses, to name a few.
1.5.3.1 Compliance with
Human Rights
Ficohsa is committed to strengthening a culture of human rights, aligned with ethical conduct, principles, and values in all its companies and countries where it operates. This constitutes a fundamental element in its vision to strengthen responsible and sustainable business practices.
In 2024, the Outsourcing Policy was developed and approved to ensure that suppliers with commercial relationships with the Group internally comply with the minimum labor rights of their employees in their operations, thereby ensuring that their actions are aligned with the Ficohsa Group’s culture of respect for human rights.
Actions in the area of Human Rights continue to be strengthened under 3 fundamental phases:
This commitment translates into continuing to work day after day, improving business practices to ensure compliance with and respect for human rights.
1.5.3.2 Relationship to the
value chain
(GRI 204-1, 205-1)
For Ficohsa, suppliers are a fundamental part of its operations. By generating a commercial commitment, they become strategic allies, committed to the timeliness and quality of their services, and complying with all guarantees. They support the group’s growth through value-added solutions.
All suppliers undergo due diligence to certify them. This serves as a tool for validation and building trust, confirming that the contracting process is viable, effective, and reliable, ensuring compliance with all regulatory commitments that allow for the legalization of direct relationships with various local and international suppliers.
This year, a radical approach was adopted for the continuous improvement process, implementing monitoring and evaluation processes for critical suppliers. These processes have served to recognize the best-performing strategic partners, awarding them larger contracts based on their results. Suppliers with opportunities for improvement, opportunities to reinvent themselves, and seeking to adopt continuous improvement in their processes within their organizations have also been considered.
Ficohsa’s main initiative is the empowerment of women, taking proactive measures in procurement to expand relationships and
contracting with women-led companies throughout the value chain.
Asesuisa also carried out some outstanding activities:
Supplier training: More than 50 suppliers were trained in sustainability management, environmental management law, money
and asset laundering prevention, information security, and new regulatory frameworks in the country.
“Allies for a Safe Planet” Program: 18 suppliers participated in the implementation of good environmental management practices. They were trained and provided with tools for waste management and reducing their carbon footprint.
Diversity and inclusion: We work with 15 suppliers from businesses led by women entrepreneurs and small taxpayers, promoting diversity and inclusive development.
Suppliers 2024
