The ethics hotline is a reporting system that SURA Asset Management S.A. makes available to its employees, directors, shareholders, and third parties such as clients, suppliers, and the public at large, to report any irregular, unethical or illegal actions in SURA Asset Management or its affiliates and lines of business. 

Complaint

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The Ethics hotline is a reporting method that SURA Asset Management, S.A. (hereinafter “SURA Asset Management” or the “Company”) makes available to its employees, directors, shareholders, and third parties such as clients, potential clients, suppliers, potential suppliers, business partners, distributors, and intermediaries, and any others, to report suspicious, irregular, unethical, or illegal actions in SURA Asset Management or its affiliates.
Employees of SURA Asset Management and its affiliates.
Shareholders, clients, potential clients, suppliers, potential suppliers, business partners, distributors, and intermediaries and, in general, anyone with knowledge about actions that should be reported (see section 4).
Users of the Ethics hotline may identify themselves or remain anonymous. Either way, SURA Asset Management guarantees the confidentiality of the information it receives.
Reports to the Ethics hotline can be sent in using any of the following methods:

Email: [email protected]
In person: By going to your local SURA Asset Management’s Legal and Compliance department.
Report: You can use this portal so submit your report using the form available here.
Anonymous report: Should the reporting party wish to remain anonymous, he or she can file their report using the form available here.
Any action or omission that is or could be irregular, illegal, corrupt, or fraudulent and/or goes against the corporate ethics of SURA Asset Management or its affiliates.

An action, or suspected action, should be reported when such action or suspected action is contrary to the principles of SURA Asset Management: Equality, Respect, Responsibility, and Transparency; to the laws applicable in each country where the company is present, and to the guidelines set forth in the Code of Good Corporate Governance and the Code of Conduct and Ethics of SURA Asset Management.
As an example, and without limitation, some of the actions or omissions that should be reported through the Ethics hotline are listed below:

Actions that go against the company’s principles
Actions that violate the principles of Equality, Respect, Responsibility, and Transparency adopted by SURA Asset Management.

Suspected money laundering or terrorist activities
Failure to comply with the duties of detecting, preventing, and controlling asset laundering (money laundering) and terrorist financing.

Failure to maintain with the confidentiality of the information
Actions that involve improper use of confidential or privileged information obtained through the positions in SURA Asset Management or its affiliates.

Fraud or potential fraud
Any action or omission that leads to improper benefits causing harm to a third party. Fraud can be perpetrated through one or more of the following actions: deceit, bribery, forgery, extorsion, corruption, theft, misappropriation of funds, improper appropriation of resources or assets, misrepresentation, concealment of actions, and complicity in fraudulent actions.

Conflicts of interest
Failure to comply with the obligation of avoiding, or disclosing, any actual or potential conflict of interest that affects or might affect objectivity and impartiality when acting as part of SURA Asset Management or its affiliates.

Violations to free economic competition
Failure by SURA Asset Management or its affiliates’ employees to abstain from performing or participating in the performance of any action that goes against free economic competition.

Actions of bribery, transnational bribery, or corruption
An action through which a public employee is offered or promised, either directly or indirectly, any benefit or profit in exchange for that public employee’s performing, omitting, or delaying any action related to his or her job.

Work-related irregularities
Any and all actions that involve work or sexual harassment, abuse at work and, in general, any act committed by an employee of SURA Asset Management or its affiliates against another employee, regardless of their hierarchical position.
In this section, the user of the Ethics hotline will be able to check the status of his or her report.

The user must consider that if the report is filed anonymously, this portal will be the only means of communication through which SURA Asset Management can indicate the status of the report and/or request additional information about the report.

It is very important for the user of this Ethics hotline who has filed a report to check regularly on the status of the report, using the report filing number.

To find out about the reports filed and resolved through the Ethics hotline, we invite you see the 2016 annual report by clicking here .
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