Compliance
The commitment materializes as effective management of a Compliance program led by the Compliance Division, which ensures that the company operates within the legal framework and internal bylaws aligned with corporate values.
The Compliance Program is based on a values-based Code of Ethics, a Crime Prevention Model (CPM) and a Free Competition Program. The Ethics Committee plays a fundamental role in design and governance, and commitment by Senior Management is critical to ongoing supervision and vigilance. SAAM also has a Complaint Channel and periodic training programs on issues such as detecting conflicts of interest, crime prevention and defense of free competition.
Code of Ethics
SAAM’s Code of Ethics provides guidelines for conducting business and stakeholder engagement based on five corporate values: Safety, Honesty, Respect, Responsibility and Service. It also establishes the value framework for corporate policies, internal regulations, manuals and procedures.
This framework of conduct is mandatory for all of its workers, executives and directors in Chile and in subsidiaries abroad. Any concerns or doubts about its interpretation can be promptly answered by immediate supervisors, area managers, the Chief Executive Officer, the Ethics Committee or the Compliance team.
Complaints Channel
SAAM has a formal complaint process for internal and external stakeholders. It guarantees security, confidentiality and non-retaliation in the management of complaints and investigations and allows users to file reports anonymously.
Crime Prevention Model
The Crime Prevention Model is a control system with rules, policies, procedures, protocols and controls. It ensures that the company upholds the management and supervision duties that prevent acts of corruption or any other crime for which the corporation could be held criminally liable under Law No. 20,393.
Compliance with the model, its standards, procedures, protocols and related activities is mandatory for all persons (directors, executives, representatives and employees, in general) working at the company, its domestic and foreign subsidiaries. The requirements extend to suppliers, contractors, agents, customers and other counterparts as appropriate and depending on their degree of involvement.
Free Competition Program
SAAM seeks to compete openly and independently in the markets where it operates, inspired by loyalty and respect for customers and competitors. It is committed to complying with the laws governing competition and actively promoting and protecting free competition.
SAAM is firmly committed to upholding the highest standards of free competition. To this end, the Board of Directors, its managers and senior executives have commissioned and supervised the development of a compliance program with antitrust regulations that provides internal guidelines for preventing risky or harmful conduct. The starting point involved identifying and mapping the main risks of non-compliance with antitrust regulations associated with the business.
Policy on Relations with Public Officials and Politically Exposed Persons
Our policy provides guidelines for relations with Politically Exposed Persons (PEP) and/or Public Officials (PO). It is part of SAAM’s Compliance Program or Crime Prevention Model for Corporate Criminal Liability and complements the company’s policy in its Code of Ethics.
SAAM’s operations play a strategic role in the economic development of the countries where they are located. The company maintains ongoing interactions with government entities, public officials and state-owned enterprises in accordance with the institutional and legal framework in force in each country and the highest ethical standards for the achievement of business objectives.
