In order to strengthen our ethical culture, we have developed an Integrity System with three components:
We have instruments that help us comply with this component, as they guide the conduct of our workers and are disseminated among the different stakeholders. These instruments are part of the contracts or agreements that, under any form of contract, are signed with natural or legal persons.
We seek the continuous strengthening of a culture of integrity, based on our clear stance of Zero Tolerance against fraud, corruption, bribery and any irregular act.
Therefore, in 2022 we approved the Awareness, Dissemination and Training Plan, and we managed to carry out 13 training activities on issues of ethics and integrity, transparency and access to information.
Our Integrity Code is part of our corporate culture, and represents a guide to focus the behavior and actions of our workers.
This code aims to execute the business strategy and fulfill the mission of our company, therefore, it seeks to do the right thing and maintain integrity, good values and transparency.
Our Integrity Code is a document disseminated among the different stakeholders, and is part of the contracts or agreements that, in any form or modality, we sign with any natural or legal person.
Content of the Integrity Code:
You can find more information about our Integrity Code at the following link.
This document represents a behavioral guide designed to guide our action in the face of different situations that we may face in carrying out our activities.
It establishes the complementary guidelines to the Integrity Code, in relation to fraud, corruption, conflict of interest, acceptance and granting of gifts and attentions, and implementation of the culture of “zero tolerance”, in order to develop preventive actions and detect inappropriate acts.
You can find more information about our Integrity Code at the following link.
It sets out the general principles for implementing a culture of integrity and “zero tolerance” for unethical acts, corruption or fraud. To reinforce this work, we have mechanisms designed to detect, prevent and control risks related to acts of corruption, conflict of interest, bribery or related crimes, in accordance with the Prevention Systems implemented to protect the assets and reputation of our company.
You can find more information about our Integrity Code at the following link.
We have a whistleblowing channel called Petroperú Integrity Line that works as a confidential whistleblowing system 24 hours a day, seven days a week.
Our integrity line aims to ensure that our workers and citizens in general can report any suspicion of evidence of non-compliance with the Integrity Code and related standards.
Within this framework, we provide the following channels:
The Integrity Hotline is operated by an independent company in order to ensure the confidentiality of the whistleblower’s identity and allow anonymity. The treatment and handling of complaints is regulated through the Whistleblowing Response Plan procedure for Breach of the Integrity System. Once the complaints have been received by the operating company, they are evaluated by our professionals in the investigation of complaints and, if they meet the admissibility requirements, they begin their investigation.
It should be noted that, at the end of 2022, we registered seventy-four (74) complaints through our receiving channels, eight (08) of which corresponded to alleged cases of corruption, which represents approximately 10% of the total. These cases are subject to investigation by the competent authorities. Thus, forty-three (43) of them are attended and/or closed.
| 2021 | 2022 | |
|---|---|---|
| Number of complaints | 107 | 74 |
| Percentage of allegations of corruption | 15% | 10% |
Source: Compliance Officer and Corporate Management of Processes and Risks.
Likewise, we recommend the application of disciplinary measures in 3 complaints for non-compliance with the Integrity System; in this regard, it is important to note that the imposition of a sanction is subject to the verification of the reported fact.
It should be noted that, in accordance with principle 22 of the Code of Integrity and Conflicts of Interest of the Code of Good Corporate Governance of Petroperú, the General Management and the Board of Directors are informed of cases of non-compliance and/or any risk event that may affect the provisions of the Code of Integrity. In this framework, during 2022, the status of complaints that enter the Integrity Line is periodically reported to the Audit and Control Committee, made up of three (03) members of the Board of Directors. Likewise, in accordance with the Corporate Governance Action Plan, at the end of the year the Board is informed of the actions taken within the framework of conflict of interest management. On the other hand, the Annual Work Plan of the Prevention Systems (Integrity System, Corruption Crime Prevention System and LAFT Prevention System) are approved at the Board level, and the progress of compliance with the aforementioned plan is reported through the Monitoring System of Agreements and Orders of the Board – SSAP Application.
Due to the deactivation of the Integrity and Discipline Committee in 2021, Corporate Compliance Management (today called Corporate Processes and Risks Management) assumed the role of handling complaints. During 2022, this Management was in charge of the functions previously carried out by the Integrity and Discipline Committee.
This function has been reinforced especially in the following points:
