5Ethics and
Compliance
5.1 Ethical Conduct
As Ficohsa Financial Group we are committed to acting under ethical conduct attached to our corporate values and compliance with the mechanisms of autoregulation we have, as well as the regulation and legislation of the countries where we have a presence.
Since 2012, we have had a Code of Ethics and Conduct which applies to all entities, as well as to the di erent internal stakeholders, such as Shareholders, Directors, Advisors, and Employees, which is regularly updated according to the needs of the Group and its environment.
In addition, we have Codes for Suppliers and Customers, which set the guidelines of conduct and ethics that we expect in the business relationships we carry out.
Also, there is a Conflict-of-Interest Policy, which is part of the Corporate Governance Manual, and applies to both customers and employees.
También, existe una Política de Conflicto de Interés, la cual forma parte del Manual de Gobierno Corporativo, que aplica tanto para clientes, como para colaboradores.
To strengthen and promote a culture of ethical compliance, at FFG we have the Regional Code of Ethics and Conduct which is transversal and applies to all subsidiaries. It aims to train and raise awareness of the rules and policies of the institution.
We have our Reporting System, a secure, easy, confidential, and anonymous platform for reporting unethical conduct or integrity. The system is operated by a third-party, independent report management specialist called EthicsGlobal.
In addition, we have other anonymous and private reporting channels that strengthen confidentiality, such as:
Telephone Reporting Line
Email Reporting Line
Web Assistant
Mobile App
WhatsApp
Physical mailboxes at strategic points
The Ethics Committee, composed of five members, five alternate members and a secretary, reports directly to the Board of Directors. This body is responsible for assessing possible sanctions, according to each of the offenses.
For the follow-up of cases with groups external to the organization, there is the third support that performs the analysis and follow-up of them, and report directly to the Ethics Committee.
5.1.1 Anti-Corruption and Bribery Management System (ABMS)
At Ficohsa we care about generating business by ensuring the value of integrity in practice. The Anti-Corruption and Bribery Management System (ABMS) emerged as an initiative of the management team, with the aim of consolidating our culture of integrity, facilitating the identification, evaluation, and monitoring of real or potential risks relate to corruption and bribery issues.
ABMS complements our Compliance Program for the prevention and detection of money laundering.
Objectives of the Anti-Corruption and Bribery Management System
Policies and rules that ensure transparency
in each of our operations
- Anti-Corruption and Bribery.
- Integrity Committee Regulation.
- Ethics and Conduct Regulation.
- Ethical Requirements for FFG Business Partners.
- Minutes – Ethical Requirement for FFG Business Partners.
- Conflicts of Interest Policy.
- Conflict of Interest Policy for Family Relations for Employees.
- Supplier Certification Policy.
- Donation Policy and Process.
- Sponsorship Policy.
- Channel of Complaints.
ABMS Governance
We highlight the efforts made through our ABMS training and awareness plan, in which we develop campaigns aimed at our employees with valuable messages about our various internal communication channels, as well as interactive activities to commemorate and consolidate our efforts in our fight against corruption.
Internal and external communication activities in 2022:
Week commemorating the celebration of ABMS.
Commemorative Week for the International Anti-Corruption Day (UN Designated).
Informative notes.
Institutional videos.
System awareness to stakeholders.
Our System is a reference for strengthening the internal culture of integrity. During 2022, for the third consecutive year, we implemented our annual training and awareness program for employees of all FFG companies.
In addition, as part of our processes, we execute revisions and updates to the policies, manuals, and processes of the ABMS; integrating modifications identified in its continuous improvement efforts.
During this year we continue to hold socialization meetings with our banking correspondents about our system. We also highlight our meeting with the United Nations Drug and Crime Unit (UNODC) where we explain the functionality of the ABMS.
Consistent with our commitment to strengthen our risk prevention programs, and ensure responsible business execution, in 2021 we started the ISO 37301 certification process for Ficohsa Bank Honduras; in 2022 this diagnosis was completed, and we are currently developing activities corresponding to the requirements of the standard for closing gaps.
By 2023 we expect to have the certification of the Compliance Management System (CMS) for Ficohsa Bank Honduras (Standard ISO 37301:2021).
In addition, at the regional level, we continue to conduct third-party independent reviews of compliance programs for the prevention and detection of money laundering of member companies, this is a voluntary adoption by a firm specialized in the design and strengthening of prevention systems, through the integration of best practices to mitigate risk.
5.2 Compliance
(GRI 3-3, 419-1) (SASB FN-CF-220a.2, FN-CF-270a.5,
FN-MF-270a.3, FN-AC-510a.1, FN-IB-510b.4)
FFG is firmly committed to developing all its activities and businesses in strict compliance with applicable laws and ethical behavior. To achieve this, all our policies, codes, processes and the Anti-Corruption and Bribery Management System (ABMS) itself aim to strengthen us as an organization and ensure transparency in each of our operations by preventing fraud, money laundering and data protection.
At the regional level we have a Vice-President of Compliance who works hand in hand with the Group’s Audit and Compliance Committee.
Also involved are those responsible in each country, this is key to monitor the implementation of our rules and the e ectiveness of internal controls. Thanks to this during the year 2022, we have not had sanctions with respect to non-compliance with national and local regulations, within the countries where we operate.
We maintain a commitment to compliance with our customers by o ering financial products under the highest standards of transparency. To do this, we developed a marketing, communication and marketing strategy that highlights the qualities and specifications of each of our products, such as tari s, interest rates, restriction clauses, to name a few.
We make sure to communicate the main customer support channels. In this way, our clients will be able to make any kind of inquiries or complaints. For further details, please refer to the Client Experience section of this report. These e orts allowed us not to have sanctions in the year for bad practices related to our financial products and services.
5.2.1 Relation of the Value Chain
The year 2022 came with new opportunities for our suppliers with the development of large projects. We are aware of their importance for our companies as they become our strategic allies. The Purchasing department works on cultivating long-term relationships with them, to be able to close deals under a «Win-Win» scheme.
We have focused on performing an agile process to make certification more user-friendly for them and become an opportunity to strengthen their bases and competitiveness within the local, regional, and global market. We made available a digital tool for receiving information, which facilitates the administration of documentation and its due diligence. In addition to registration, we have been working on a categorization process to identify high-risk suppliers, which impact the operation, effciency, and continuity of the business. In addition to the sense of responsibility and compliance with local and international laws, if applicable, it is important that they comply with:
- Code of Ethics for Suppliers
- FFG Code of Conduct
- FFG Anti-Corruption and Bribery Policy
- Supplier Certification Policy
The Group always seeks to include new suppliers, mainly all those entrepreneurs that arise in our country and seek to develop and are the fundamental engine for the economic development of the countries where we operate.
Our main suppliers are divided into the following categories:
- Technology (Procurement of equipment, infrastructure, and telecommunications) and software development
- Data security
- Licensing
- Marketing
- Promotional items
- Legal advice
5.2.2 Compliance with Human Rights
Aligned with our ethical conduct, principles, and values, at FFG we are committed to strengthening a human rights culture in all our companies and countries where we have a presence; this is a fundamental element in the Group’s vision that strengthens our practices of responsible and sustainable business conduct. We have a Human Rights policy, we implement due diligence in our operations and processes, as well as with our suppliers, clients, and other business relationships; to identify, prevent, mitigate, respond, and take appropriate measures to manage impacts.
In 2022 we were part of the pilot project «Human Rights Management» led by the Honduran Council of Private Enterprise (COHEP), with the purpose of strengthening our actions in the field of Human Rights.
During the first phase, we carried out a thorough review of our Human Rights policy, which incorporated due diligence processes, evaluation of human rights impacts and complaint mechanisms to strengthen the evaluation, monitoring and reporting of cases issues.
In the second phase, we conducted a Human Rights impact assessment for the creation of the risk matrix.
In the third phase, we reviewed each of the complaint mechanisms to strengthen our processes to prevent and, where appropriate, minimize or remedy any human rights violations that occur.
We continue working every day to improve our business practices to ensure compliance and respect for human rights; by 2023 we will be socializing our
policy initiatives with di erent stakeholders.