MODEL FOR PREVENTION OF CRIME
At Sierra Gorda SCM we maintain an unwavering commitment to integrity and probity. For this reason, we have a Model of Prevention of Crime (MPC) aligned with the requirements of Law 20.393, which establishes the criminal liability of legal persons for the commission of various crimes, such as money laundering, financing of terrorism, bribery of public officials (local or foreign), corruption, receiving, misappropriation, conflicts of interest, among others.
Our MPC is led by a Crime Prevention officer whose function is to establish mechanisms to prevent and mitigate the criminal risks we face as a company. This includes defining segregation of duties, obligations and prohibitions for all our employees, including contractors and advisers. All with the aim of ensuring full compliance with the applicable legal requirements.
A fundamental part of this model is to develop a matrix of risk management and control to regularly evaluate the processes or activities that are exposed to the commission of crimes within Sierra Gorda SCM.
To ensure the continued effectiveness of our Crime Prevention Model, it has been decided to submit it to a certification process every two years, in line with the recommendations of Law 20.393.
This certification process involves a thorough review, carried out by an independent third party, a certifying entity that must be registered with the Financial Market Commission of Chile.
This certification confirms the seriousness and credibility of our program, and its full compliance with all established legal requirements. It is a strong attestation to our commitment to integrity and crime prevention in all our operations.
In Sierra Gorda SCM we conduct regular training on the risks, protocols and requirements of Law 20.393, to all the workers of the company and with special emphasis on those who hold positions more exposed to the commission of crimes.
In addition, we implement various mechanisms to foster and strengthen a culture of compliance in Sierra Gorda SCM: We disseminate widely through our various communication channels relevant topics, such as information from the Channel of Reporting, the Crime Prevention Policy, management of conflicts of interest, among others.
Additionally, the Governance, Risk and Compliance Management (GRC) developed and implemented a Crime Prevention course, in accordance with Law 20.393, which is available to collaborators in an online format at the Sierra Gorda SCM Academy where workers can access through the intranet.
COMPLIANCE AND RISK COMMITTEE
To promote a culture of compliance and risk management, we organized several Compliance and Risk Committee sessions as part of our Corporate Governance framework. Its main objectives were monitoring the compliance process and risk management, improving inter-area communication, centralizing communication channels, supporting risk managers as needed, expediting decision-making and making recommendations.
This committee meets bimonthly and is composed of representatives from different areas of the Company, including the General Manager, the Vice-President of Finance, the Vice-President of Human Resources, the Vice-President of Supply Chain, the Vice-President of Operations, the General Counsel, and the Executive Director of Business Development, being the Risk and Compliance Governance Manager the responsible for preparing the agenda, facilitating the meeting and following up on the different commitments agreed.
Please see our certificates:
Are you interested in our Crime Prevention Model?
The person responsible for the supervision and monitoring of the MCP is the Crime Prevention Officer – the official appointed by Sierra Gorda SCM Owners Council, pursuant to Law 20,393. Crime Prevention Officer contact information:
Wojciech Dabrowski
