As a State company, we consider integrity as one of our corporate values and we establish cross-cutting ethics in our performance and in the activities of all our areas.
In this line, we focus on establishing a culture of “zero tolerance” that drives Petroperu to act with probity and ethics, and not to tolerate any type of active or passive conduct that constitutes corruption, fraud or any other irregular or inappropriate act.
In order to maintain honest and transparent relationships with our stakeholders and citizens in general, it is essential to manage and address the anti-corruption issue. Therefore, we align ourselves with objective 5 of our strategy, which reflects our interest in strengthening corporate governance, fostering a culture of integrity and the fight against corruption.
In addition, we aim to prevent acts of corruption and fraud, detect them and take measures to avoid putting our image at risk, as well as the well-being of our stakeholders or citizens in general.
Systems that group internal management instruments
Integrity System
- Promotes and strengthens the culture of integrity in our company, and guides the behavior of our officials and workers to prevent irregular acts of fraud and corruption, and thus raise the standards of ethical conduct and maintain a good image of our company with stakeholders.
System for the Prevention of Crime of Corruption
- Early warning system that focuses on generating a climate of internal and external trust in the company, allowing to identify risky situations, prevent possible commissions of crimes, adopting appropriate measures for their mitigation.
- Law No.30424 “Law regulating the Administrative Liability of Legal Entities”, its Regulations and NTP-ISO-37001:2017 “” Anti-bribery management systems “are maintained on the basis.
- Attends to good practices recommended by international entities, such as the Organization for Economic Cooperation and Development (OECD), the United Nations (UN) and the Financial Action Task Force (FATF), so that companies assume responsibility for the commission of crimes that have been committed in their name and for direct or indirect benefit.
Money Laundering and Terrorist Financing Prevention System (SPLAFT)
- Petroperú, according to the law, is considered as a subject obliged to inform the Financial Intelligence Unit (FIU – Peru) and, as such, obliged to implement a System for the Prevention of Money Laundering and Financing of Terrorism (SPLAFT), given that it is a company that produces and markets chemical inputs that can be used in illegal mining, under the control and oversight of SUNAT.
Our management systems related to the fight against corruption are being established at the corporate level, and are being evaluated through indicators of the degree of compliance with the activities stipulated in their annual work plans.
Internal management systems and achievements in 2022
| System |
Objective |
Components |
Achievements |
| Integrity System |
Establish a standard of ethical conduct in all our internal and external workers. |
- Policy on Integrity and the Fight against Corruption and Fraud.
- Integrity Code.
- Integrity System Guideline (anti-fraud, anti-corruption, conflict of interest, gifts and attentions).
- Whistleblowing Channel: Integrity Line.
- Awareness raising and training.
|
- We approve the 2022 Integrity System Awareness, Dissemination and Training Plan.
- Our Board of Directors, with the participation of the General Management, signed the Annual Commitment to Integrity and Anti-Corruption.
- We conducted 13 ethics and integrity trainings with 796 attendees nationwide.
- We received 74 complaints through the company’s receiving channels. Regarding these, we recommend disciplinary measures in three complaints.
- 67% of the subjects obliged levels 4 and 5 and 100% of director levels 1, 2 and 3, complied with the presentation of the Affidavit of Interest of the Comptroller General of the Republic.
- We answered 330 queries about conflicts of interest.
|
| Corruption Crime Prevention System In accordance with Law No. 30424 and Legislative Decree No. 1352. |
Provide an early warning system regarding possible breaches or commission of crimes that allow timely measures to be taken and reduce the risk of exposure, in order to generate a climate of internal and external trust in our company. |
- Head of Prevention.
- Risk Assessment.
- Dissemination and training.
- Evaluation and monitoring.
- Complaints procedure.
- Supplier due diligence.
|
- We automate the Commitment to Adherence to the System for the Prevention of Corruption and Anti-Bribery Crimes, for its application at the national level.
- Attention to 85 queries.
- We conducted a training for the International Anti-Corruption Day, corresponding to the Crime Prevention System, with the participation of 179 workers from different areas.
|
| System for the Prevention of Money Laundering and Financing of Terrorism (SPLAFT) In compliance with Law No. 27693. |
Depending on the ML/TF risk factors, apply procedures and controls that allow timely detection and reporting of warning signs to prevent the products marketed by Petroperu from being used for purposes related to LAFT crimes. |
- Appointment of Compliance Officer.
- Strengthening of the internal regulatory framework of the SPLAFT (LAFT Prevention Manual, Code of Conduct, Procedures).
- Reports of the Compliance Officer (Work Plan, Semiannual Reports to the Board of Directors and the Financial Intelligence Unit – FIU)
- Risk Management of Money Laundering and Terrorist Financing.
- Due diligence in the knowledge of the client.
- Operations record (RO, in Spanish).
- Identification of warning signs, unusual and suspicious operations.
- Awareness and training for Senior Management and our workers on the SPLAFT.
- Evaluation of the SPLAFT (internal and external audit).
|
- We carry out the LAFT risk report with recommendations to improve its identification and evaluation.
- We strengthened the knowledge and internal regulatory framework of the system.
- We perform system maintenance through monitoring of LAFT warning signals and application of SPLAFT evaluation mechanisms.
|
Source: Compliance Officer and Corporate Management of Processes and Risks.
Common achievements of the three internal management systems during 2022
| System |
Common achievements |
| Integrity System |
- We achieved the automation of the commitment to adhere to the System for the Prevention of Corruption Crimes, the SPLAFT and the Anti-Bribery Management System, signed by 2500 workers, with which they undertake to comply with the Policy for the Prevention of Money Laundering and Financing of Terrorism, Corruption Crimes and Anti-Bribery Management.
- We carry out awareness-raising and training actions aimed at staff regarding issues of integrity, conflict of interest, affidavit of interest, whistleblowing channel, anti-corruption and anti-bribery and on the SPLAFT.
- We update and incorporate clauses to prevent LAFT, as well as corruption and bribery offences, in contracts and documents signed with our business partners.
|
| System for the Prevention of Crime of Corruption |
| Money Laundering and Terrorist Financing Prevention System (SPLAFT) |
Source: Compliance Officer and Corporate Management of Processes and Risks.
As part of the implementation of good integrity management practices, our Board of Directors, with the participation of the General Management, signed the Annual Integrity and Anti-Corruption Commitment Act with the aim of strengthening the Tone of the Top.
Through this act, we are committed to supporting the strengthening of a culture of integrity and the fight against corruption in our company, which allows us to maintain honest and transparent relationships with our stakeholders and citizens in general.
The instruments and respective reporting mechanisms allow to prevent, detect and control any irregular act, and are socialized by different means. In this way we improve our reputation, we guarantee compliance with these mechanisms and achieve our business objectives.
In this way, the realization of our business lays its foundations in corporate governance and ethical practices. We maintain a firm position of “zero tolerance” towards acts that generate affinity of negative externalities and that represent an obstacle to the development of Peru. These acts include fraud, corruption, deception, payment, improper authorization, bribery, money laundering, terrorism or other inappropriate conduct in the company, both internally and externally.
