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Anti-Corruption Policy: Staria has implemented a series of procedures and quality standards committed to the eradication of corruption and bribery, as the company has a “zero-tolerance” policy toward such practices.
Likewise, this policy reaffirms our commitment to complying with municipal, state, federal, and international laws and regulations that apply to the nature of our operations. The purpose of this policy is to inform and train our board of directors and employees on these guidelines so that they are able to identify and report any conduct that could be considered a bribe or that could, in any other way, be considered corrupt. Corruption is defined as any act intended to obtain a benefit of any kind by violating established rules and procedures.
A bribe consists of giving a person any form of benefit—whether in the form of a sum of money, a gift, or the performance of a favor—in order to secure, obtain, or omit an action or benefit. This policy is based on our Code of Ethics and Conduct, which applies to all Staria employees and executives in all regions where the company operates, as well as to all related parties and stakeholders, including customers, suppliers, contractors, and, in general, anyone with whom a business relationship is established, whether directly or indirectly.
Our code states that:
“Employees must never be involved in fraud or other dishonest conduct involving the property, assets, financial records, or accounting of the company or a third party.”
Offering or providing improper benefits in order to influence the recipient’s decision may not only result in disciplinary action but also lead to criminal liability. Improper benefits may include anything of value to the recipient, including employment or consulting contracts for closely related parties.”
Regarding favors and exchanges with customers or suppliers, our code states:
“Employees, either directly or through intermediaries, must never offer or promise an improper personal or financial favor—or any other type of favor—in order to obtain or secure business or an advantage from a third party, whether public or private. Employees must also not accept such an advantage in exchange for providing preferential treatment to a third party.”
In accordance with the above, employees exposed to a situation involving misconduct are required to consult the policy applicable to their area. In case of doubt, or if such a policy is not documented, employees must adhere to the most restrictive practice in order to avoid compromising or inappropriate situations, or consult their immediate supervisor or the Legal Department for guidance."
In addition to this committee, the Internal Audit Department, in coordination with Human Resources Management, will be designated as responsible for disseminating this policy and the code of ethics to which it refers to all Company representatives, as well as for coordinating with other departments to ensure that third parties are made aware of it. There is an internal committee designated to receive, investigate, and follow up on complaints, as well as cases in which the company is implicated in acts of corruption or conflicts of interest. The head of the Legal Department will be responsible for implementing and ensuring compliance with the decisions made by this committee, always seeking to safeguard the integrity of the company and those who work there.
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