6. SCOPE


At TECNAS S.A. we specialize in design, development, processing, assembly and trading of supplies and ingredients for food industry, accompanied by comprehensive technical advice and constant technological surveillance; working on continuous improvement at a personal and work level, hoping that all our actions allow us to maintain transparent business relationships and ethical conduct during the development of the assigned functions.

This Business Ethics Transparency Program and Transnational Corruption Prevention Mechanisms establishes the fundamental guidelines for professional and personal behavior that all those linked to TECNAS S.A. We must observe in the exercise of our work functions or the provision of the contracted service.


• Collaborative work
• Empowerment
• Consistency
• Nobility
• Love
• Friendly Service


Our principles are based in S-M-O-R culture: we are a company with a heart, which carries out all its activities with passion, to meet the needs and meet the expectations of our employees, customers and collaborators.

Self-motivation and self-leadership

Give meaning to what we do, managing our work with personal and collective meaning, leading it to self-leadership, facing challenges with love, responsibility and a managerial approach.

Motivation and self-motivation

We have the internal force that constantly drives us and gives us the vital energy to achieve personal and collective goals.


We use permanent observation as a fundamental tool, which allows us to identify opportunities, take advantage of our strengths, improve weaknesses and protect ourselves from possible threats.


We build relationships based on respect, transparency and trust, valuing the other regardless of their position, being fair and understanding that our decisions and actions affect our environment.


Tecnas S.A. is committed to developing all its activities, both technical and commercial, within a professional, ethical and legal framework, and maintaining a work environment that encourages the participation and commitment of its employees towards the quality of performance and results of the company, allowing people to achieve their self-realization, their well-being and that of their family through work.

To achieve the above, the following premises are presented:

• Tecnas S.A. has always searhing for competent employees, capable of making the right decisions in difficult situations, acting with integrity, being honest and fair in all aspects of their personal and business relationships, demanding the same from all those with whom they interact.

• The employees of Tecnas S.A. They must not engage in activities that raise questions about the integrity, fairness or reputation of the company.

• Tecnas S.A recognition due to the quality of its products, its team integrity of and its high ethical standards, it´s important to:

Shareholders, who have invested in the company.
The customers, whom we serve, and the suppliers, with whom we do business.
The community, in which we live and work.
All of our colleagues, employees throughout the country.
Consumers of our products.


5.1. General objective

Promote at all levels of the organizational structure, a culture of transparency and business ethics in order to seek the highest standards of ethical behavior of the people linked to TECNAS S.A. in personal, commercial and other business relationships with the company, colleagues, business partners, customers, suppliers, contractors, interested parties and the community in general.

5.2. Specific objectives:

• Have an ethical approach when conducting business, thus supporting the essence of the values.
• Support the achievement of our management policy, in a way that sustains its good reputation, both now and in the future.
• Maintain the highest standards of ethical behavior in business relationships with the company, colleagues, business partners, customers, suppliers, contractors, stakeholders, and the community.
• Promote at all levels of the organizational structure the culture of risk management of Money Laundering and Financing of Terrorism and Financing of the proliferation of weapons of mass destruction (ML / FT / FPADM), based on management and control of associated risks.


This PROGRAM OF BUSINESS ETHICS TRANSPARENCY AND TRANSNATIONAL CORRUPTION PREVENTION MECHANISMS applies and is binding on all employees and officers of Tecnas S.A. Likewise, it is extended, as applicable, to suppliers, contractors, interested parties.


Respect for principles and values ​​established in this BUSINESS ETHICS TRANSPARENCY PROGRAM AND TRANSNATIONAL CORRUPTION PREVENTION MECHANISMS is mandatory for all company employees.


For the purposes of the transparency and integrity assurance program in the Company, it must be understood that bribery and corruption in general is the will to act dishonestly in exchange for money or personal benefits, causing damage unfairly favoring few who abuse their power or your position. This not only creates unfair competition but also limits the path to organizational efficiency and people’s integrity.

• Business ethics program: These are the specific procedures aimed at putting compliance policies into operation, in order to identify, detect, prevent, manage and mitigate the risks of bribery, as well as others that are related to any act of corruption that may affect TECNAS S.A.

• Stakeholders: These are the entities that improve or affect processes such as customers, employees, suppliers, shareholders, contractors, the community and the state.

• Compliance Officer: It is the natural person, designated by the administrators to lead and administer the Transnational Bribery Risk Management System. The same individual may, if so decided by the competent bodies of the Legal Entity, assume functions in relation to other risk management systems, such as those related to money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction, the protection of personal data and the prevention of violations of the competition regime.

• Bribery: It is the act of giving, offering, promising, requesting or receiving any gift or thing of value in exchange for a benefit or any other consideration, or in exchange for performing or omitting an act inherent to a public or private function, regardless that the offer, promise or request is for oneself or for a third party, or on behalf of that person or on behalf of a third party.

• Transnational bribery: It is the act by TECNAS SA, through its employees, senior managers, associates or contractors, gives, offers or promises to a foreign public servant, directly or indirectly: sums of money, objects of pecuniary value or any benefit or utility in exchange for said public servant performing, omitting or delay any act related to its functions and in relation to an international business or transaction.

• Conflict of interest: When the interests between an employee of TECNAS S.A. and the interests of the Company are conflicting, which may lead the person to make decisions or carry out acts that are for their own benefit or that of third parties and to the detriment of the interests of the company.

Corruption: It is any act, attempt or deliberate omission to obtain a benefit for oneself or for third parties to the detriment of organizational principles, regardless of financial effects.

• Fraud: It is understood as the act or omission intentional and designed to deceive others, which is carried out with the purpose of appropriating, taking advantage of someone else’s property in an undue way, to the detriment of another person (natural or legal) .

• Usury: Anyone who receives or collects, directly or indirectly in exchange for a loan of money, or for goods and services, at a time, profit or advantage that exceeds by half the current bank interest that for the corresponding period are charging the banks, as certified by the Financial Superintendency (crime enshrined in article 305 of the Colombian´s penal code).

Due diligence: It is the initial and periodic review that must be done on the legal, accounting and financial aspects related to a national or international business or transaction, whose purpose is to identify and evaluate the risks of bribery and corruption that may affect to TECNAS SA

Anti-corruption and anti-bribery rules: These are the FCPA Act, the UK Bribery Act, the Convention against Transnational Bribery of the Organization for Economic Cooperation and Development (OECD), Colombian Anti-corruption Rules and any other applicable anti-corruption laws and bribery.

• Colombian regulations against corruption: It is Law 1474 of 2011 (Anti-Corruption Statute) by which regulations are issued aimed at strengthening the mechanisms of prevention, investigation and punishment of acts of corruption or bribery and the effectiveness of the control of public management, as well as as its regulatory decrees and the rules that modify, replace or complement it. In the same way, Law 1778 of 2016 is considered relevant, by means of which regulations were issued on the responsibility of legal persons for acts of transnational corruption and also provisions on the fight against corruption were issued.

• Foreign public servant: It is any person who has an administrative, legislative or judicial position in a country.

• Bribery: Crime that involves giving a bribe to corrupt someone and obtain a favor from them.

• Money Laundering: A crime committed by any person who seeks to give the appearance of legality to goods or money from some of the activities described in article 323 of the colombian penal code.

• Financing of Terrorism: A crime committed by any person who engages in any of the behaviors described in article 345 of the colombian penal code.

• Facilitation payments: Payments given to a business person to expedite a process.

• Ethical mailbox: Box located at the reception, and the innovation and development building and at each of the branches at the Tecnas S.A tradings shops, where employees and interested parties may report unethical behavior by physical means

• Compliance Audit: It is the systematic, critical and periodic review regarding the proper execution of the Business Transparency and Ethics Program and is do out by Internal Control area.


The Colombian Republic Congress promulgated the Law 1778 on February 2, 2016 in response to various international agreements that aim to combat corruption and bribery of foreign public servants in international commercial transactions. Article 23 of this Law establishes the duty on the part of the Superintendency of Companies to promote programs of transparency and business ethics in the legal entities subject to its supervision and that, for this, it will take into account criteria such as the amount of their assets, their income, the number of employees and corporate purpose.

Consequently, the Superintendency issued Resolution 100-002657 of July 25, 2016, which establishes the criteria to determine which companies should adopt business ethics programs, and External Circular 100-000003 of July 26, 2016, which contains a guide with the administrative instructions related to the promotion of the aforementioned programs, as well as the internal mechanisms for auditing, anti-corruption and prevention of transnational bribery in the context of Law 1778 of 2016.


Ethical behavior can involve more than compliance with the law; however, it is part of this premise that each worker must know the basic regulatory legal requirements concerning the position they hold, since compliance with them is the responsibility of each and every one of the Tecnas S.A. employees.

Our employees and contractors are governed by law. Compliance with all applicable laws and regulations should never be compromised. In addition, employees must adhere to the internal rules and regulations as they are applicable in a each especific situation. These internal rules are specific to the company and may go beyond the requirements of the law.


We must all avoid conflicts of interest. This means that we should not place ourselves in situations that could force us to choose between our personal interests and those of Tecnas S.A.

A conflict of interest may arise in the following cases:

• If you or a member of your family owns an interest in a company, that you have or intend to enter into business relationships with the company (Tecnas S.A) or compete with it or with its clients.
• If a member of your family up to the second consanguinity degree or affinity works or will work in a competing company.
• If the Internal Control staff or the compliance officer during their work must report information to the UIAF to a member of their family up to the second degree of consanguinity or affinity, they must refrain from carrying out said process and inform the General Management so that it can be designate another official to carry out said process.
• If you are an executive, director, consultant or occupy some other key position within a company such as the one mentioned above.
• If he acts as a broker, agent or intermediary on behalf of third parties in any transaction of the company.
• Keep the company’s customers in over-stock in order to meet quotas and thus obtain higher commissions. In this case, corrective actions must be reported and implemented.
• Receive perks from third parties (suppliers, banks, service companies, etc.).
• Pressuring a subordinate to be permissive, contrary to a procedure.

The employee or contractors must make an individual and sincere statement, stating whether their relationship with Tecnas S.A. presents an event of conflict of interest. The person must voluntarily say so, understanding this act as in good faith towards the company and report it to the General Management, the Compliance Officer through the means provided for this.

In the event of conflicts of interest, the General Management with the Administrative Board will make the decision to terminate the employment contract, or the commercial relationship with the contractor.


12.1. GIFTS AND ENTERTAINMENT EXPENSES employees or contractors must not solicit, accept, offer or provide gifts, entertainment, hospitality or sponsorships for the purpose of inducing, supporting or rewarding wrongdoing, in connection with obtaining any business involving the company. Gifts, entertainment expenses or other courtesies for the benefit of a third party are not allowed. The employee or contractor must notify and request prior approval to the General Management.

The company will not make or use intermediaries or third parties for them to make inappropriate payments. Facilitation payments are prohibited. Such payments should not be made, even if they are common practice in a especific country.

All contracts or agreements signed by the company must contain clauses, statements or guarantees on anti-bribery and anti-corruption behavior.

When there is room to support the negotiation of a contract according to the purchase procedure, the expense generators are responsible for including said clauses in all contracts.

In addition to declaring and ensuring compliance with this program and applicable anti-corruption laws and regulations, the right to terminate the contract should be included when a violation of this program or any applicable anti-corruption laws or regulations occurs. In any case, the person responsible for the negotiation must ensure that the clauses are included before signing the contracts or agreements, if they are not observed, they must request them from Internal Control.


TECNAS S.A. does not make contributions to political parties, people or organizations that are sanctioned or disqualified by the control entities, are part of restrictive lists with information on money laundering, financing of terrorism or other crimes.

Donations made will be defined and authorized by the Administrative Board. Contributions are made in a transparent manner and in good faith, ensuring that: (a) the recipients are legitimate and the final destination of the contribution is not a third party; (b) the contribution is made within the framework of the law; (c) it is not made as consideration for favors or decision-making to exclusively benefit TECNAS S.A .; (d) the Company records the contribution in its accounting.

We respect the right of employees to participate in political activities that they freely choose to carry out, as long as such activities do not interfere with the performance of duties and responsibilities and are carried out strictly in their personal capacity.

During the exercise of any political activity, you should not involve or relate to TECNAS S.A., or use the name, symbols, logos or any other sign that may be associated with the company. Additionally, political activities are not allowed on company premises or we use company resources for this purpose.

Employees are free to make political contributions in their personal capacity. However, we must ensure that any personal contribution in which TECNAS S.A. do not interfere, do not be associated with our company.

The company is not responsible, in any case, for the performance of its staff in the performance of political activities. The possible intervention of the personnel in political activities does not imply, in any way, a political tendency or affiliation on the part of the Company.


TECNAS S.A. must keep and maintain records and accounts that accurately and accurately reflect all transactions carried out. Company employees may not change, omit or misrepresent records to conceal improper activity or that does not correctly indicate the nature of a recorded transaction.

The company has internal controls to prevent bribes or other improper payments from being hidden or disguised in transactions such as: commissions, fee payments, sponsorships, donations, representation expenses or any other item that serves to hide or conceal the improper nature of the payment.


Each of us is responsible for ensuring that company assets, including confidential information, are only used for business activity. The facilities, materials, equipment and services of the employees or contractors of TECNAS S.A. not be used for any other purpose than our business activities, without requesting the pertinent permission.

By “company property” we mean more than just buildings. Most of the information that you compile as part of your work is the property of the company, that is a valuable asset of society. This type of information could include technical, strategic, financial and human resources plans, as well as documents, databases or plans, all of them of a confidential nature.

You should always keep in mind that much of our confidential information is stored on electronic media. Electronic data must be protected with the same care as any paper document.

You should be careful not to share company proprietary information with others, including your colleagues, unless they need to know it for a legitimate reason related to your job.

Unauthorized disclosure could destroy the value of the information and provide an unfair advantage to third parties, not belonging to the company.

Remember also that unintentional disclosure, for example through indiscreet conversations in public places such as airplanes, elevators, restaurants, etc., can be exactly as detrimental to Tecnas S.A.

If you no longer belong to the company, you should not take any type of confidential information from Tecnas S.A., nor disclose it in your new company. Likewise, if you come from another company, you should not reveal the confidential information of the same. In the same way that we value and protect our own information, trade secrets and intellectual property rights; we value and respect those of others.


We all prepare or handle information of some kind during our work: financial reports, accounting records, business plans, regulatory presentation of information, expense accounts and so on, which is why we must commit ourselves to the proper handling of these types of documents and protect them. Many people, inside and outside the company, trust in the truthfulness and accuracy of these reports. These individuals include auditors, co-workers, contractors, shareholders, government agencies, and the community in which we operate.

Tecnas S.A. has established accounting procedures to protect its assets and to ensure the accuracy and veracity of its financial information, so that it can be reviewed by tax auditors, investors or government entities in a transparent way.


Tecnas S.A. do not want business that has been obtained through the improper use of commercial courtesies. Sometimes you may need to use your best judgment to determine what care is appropriate, always keeping the following principles in mind:

• Overly generous invitations or gifts to suppliers, contractors, clients or others with whom they do business should be avoided, and they should not expect this type of treatment from us.
• Gifts and entertainment may be acceptable in the following cases: if they are consistent with accepted business practice, if they are not extravagant and there is no possibility that they will be construed as bribery or commission.
• Gifts of small value may be given or accepted as a testimony of respect and friendship. Money is never appropriate.
• Discounts and promotions to customers must always be authorized by the General Management, Commercial Management and Commercial Logistics Directorate and there must be evidence of said approval.
• Giving or receiving something of value from a person (money, gifts, loans, rewards, favors, commissions, entertainment), as an inappropriate reward for obtaining business or any other type of benefit (bribery).
• Obtain benefits for themselves or for third parties to the detriment of organizational principles, regardless of the financial effects on the company (corruption).
• Deceive others by improperly taking advantage of the good of others, to the detriment of another, generally due to the lack of malice or knowledge of the affected party (fraud).

Regarding suppliers or contractors, the policy is to select them fairly, based on the price, quality, presentation and suitability of their product or service. This means the following:

• The purchasing policy established by Tecnas S.A. must be followed.
• Any disguised agreement, such as an agreement to keep another supplier out of business, should be rejected.
• A bribe should never be accepted.
• Merit-only business will help us maintain the quality of our relationships and our products.


The work of Tecnas S.A. It consists mainly of the manufacture and commercialization of products that are safe and of high quality for the people who consume and use them; taking care that our activity does not entail any damage to our colleagues, the community or the environment, establishing the following objectives:

• Provide a safe and healthy workplace with potable water, adequate sanitary areas, evacuation routes, basic security services, and good lighting.
• Comply with legal regulations and establish our own regulations, when they do not exist, or when the existing ones, at the discretion of Tecnas S.A, are insufficient.
• Provide quality and safety of products.
• Preserve the environment and ensure compliance with all applicable laws and regulations of the country.
• Minimize the emission of dangerous substances and guarantee the disposal of the different waste generated in the company.


Every employee or contractor of Tecnas S.A. must report behaviors and situations that are considered unethical and that could go against company policies and guidelines.

The company has mechanisms so that all company employees or contractors, regardless of their position, and other stakeholders can communicate doubts or advice needs in relation to compliance with the Transparency, Business Ethics and Prevention of Transnational Corruption Mechanisms Program, so you can also report behaviors that are in any of the forms of bribery or corruption. The consultation is received guaranteeing the confidentiality of the information and the person who presents it, protecting it against any type of retaliation. You can report it through:

• Ethical mailbox
• Email:
• To the General Management
• Compliance officer


The Board of Directors, Administrative Board and Leaders of TECNAS S.A, are responsible for the administration, prevention and detection of the risk of fraud, bribery or other conducts that affect transparency. Furthermore, they must promote by example a culture of transparency and integrity in which bribery, corruption and any other inappropriate act are considered unacceptable.

The Shareholders’ Meeting: is responsible for appointing the Ethics Officer and providing the economic, human and technological resources that he requires. Define and approve policies and mechanisms for the prevention of bribery and other corrupt practices within the company. Order the pertinent actions against senior executives, when they violate the provisions of the Transnational Program for Transparency, Business Ethics and Mechanisms for the Prevention of Transnational Corruption and review the reports submitted by the Ethics Officer, expressly recording them in the respective minutes.

Transparency and integrity committee: The Administrative Board is the governing body of the Transnational Program for Transparency, Business Ethics and Mechanisms for the Prevention of Transnational Corruption, its responsibility is to ensure the correct application of the program and the implementation of the necessary corrective actions to guarantee management in accordance with the principles of the company.

Ethics Officer (Compliance Officer): He is responsible for the implementation and articulation of the Business Ethics and Prevention of Transnational Corruption Mechanisms and in charge of executing the entire logistics operation of investigation and due process. Coordinate and document the investigative processes. It must report to the General Management and at least every four months, the reports on its management, the cases received and the recommended strategies for the investigation. It must assess the risks of bribery and corruption, coordinate employee training on this matter and propose process improvement. In the case of the company, it will be the same Compliance Officer, who, although in charge of everything related to SAGRILAFT, was appointed for the execution and monitoring of this program.

All TECNAS S.A employees: must ensure transparent management in their respective areas. Any employee who has knowledge of any conduct contrary to those established in this program must report it immediately through the established means (ethical mailbox, ethical email, General Management, Compliance Officer) in the Transparency, Business Ethics and Prevention Mechanisms Program of Transnational Corruption.

In all cases, the employee enjoys confidentiality and a presumption of good faith, and must do so based on evidence and / or real facts. Due to the nature of their duties, the president and managers will face ethical dilemmas more frequently and have a duty to set an appropriate example of ethical behavior within the terms of this policy.

Tecnas S.A. does not tolerate the participation of its employees or contractors in any form of unethical, illegal or criminal behavior.

When unethical behavior transcends the criminal sphere, the company will make the respective complaints, complying with the legal provisions.


Tecnas S.A. has its doors open to both men and women, without discrimination and consideration of their ethnic, social or personal beliefs. We promote diversity, respect personal dignity, privacy, religious and political affiliation and personal rights of each employee, and we are committed to maintaining a workplace in which there are no situations of discrimination or workplace harassment, therefore, employees must not discriminate with respect to origin, nationality, religion, race, gender, age or sexual orientation, nor must they have any type of verbal or physical abuse, based on the aforementioned or any other reason.

Employees who feel that their work environment does not comply with the principles mentioned above, can raise their concerns and suggestions to the president of the Labor Coexistence Committee, or to the Human Resources Department.


Deprivation of liberty and forced labor: Tecnas S.A. under no circumstances does he use or obtain any benefit from the imposition of forced labor. Work generated in any kind of enslaving way is prohibited, as is the use of psychological punishment, confinement, threats of violence or any other form of harassment or abuse as a method of discipline and control.

Child labor: any form of child labor exploitation is strictly prohibited. Child labor is understood to be any mentally, physically, socially or morally dangerous or harmful work for children, which directly interferes with their compulsory education needs, defined as such by the corresponding authority.

Working hours: Tecnas S.A. is responsible for ensuring that its employees work in accordance with applicable laws and industry standards regarding the number of hours and days of work.

Remuneration: Tecnas S.A. provides its employees with salary and benefits that comply with applicable laws, including those related to overtime pay and surcharges for night work or sunday / holidays.


The company complies with labor human rights related to:

Stable employment: Tecnas enables employment without discrimination, provides training and education, avoids unjustified dismissals and promotes transfers and promotions among its employees.

Corresponding salaries: Tecnas guarantees equitable remuneration that satisfies the worker and pays contributions to the social security system, allowing the employee to retire in the future through the pension system.

Comfortable working conditions: Tecnas establishes working hours that allow the employee the necessary rest to recover after a day’s work. It has also implemented the OH-SMS occupational health and safety management system and an occupational welfare plan, which enables adequate conditions for a job in decent and healthy conditions.

Social Security: Tecnas guarantees the adequate affiliation and payment to the social security system of its employees and interested parties that protect the worker from contingencies derived from illness, disability, old age, death or unemployment.

Gender equity law: At Tecnas there is equality between men and women in relation to access to employment under the same conditions of wages, recognition, physical and psychological respect, and the enjoyment of a good work environment.

Minor workers’ rights: Tecnas does not hire minors under 18 years of age.

Trade union freedom: Tecnas recognizes the right of workers to organize and defend their fundamental human rights as workers

Collective contracting: Tecnas recognizes the possibility that workers have to reach negotiations with the company according to the possibilities.

Strike: Tecnas recognizes the right of workers to express their disagreement with labor rights that they consider to be unfair

Labor Justice: Tecnas recognizes the possibility that workers have access to the Colombian Labor Justice to resolve a labor dispute, in the event that it is not possible to resolve it in a concerted manner with the company.

Employees, in the performance of their duties, have a special obligation to behave and act in an ethical manner, in accordance with the duties and responsibilities established in this BUSINESS ETHICS TRANSPARENCY PROGRAM AND TRANSNATIONAL CORRUPTION PREVENTION MECHANISMS and to seek guidance when needed.

Tecnas S.A. supports all employees, stakeholders, to act within the highest standards of transparency and business ethics.

Remember that the BUSINESS ETHICS TRANSPARENCY PROGRAM AND TRANSNATIONAL CORRUPTION PREVENTION MECHANISMS must become a permanent consultation tool. The duties set forth in it must be fulfilled consciously and forcibly, and are part of the other obligations contained in the internal labor regulations, individual contracts, circulars and procedures of Tecnas S.A.

Failure to comply with the BUSINESS ETHICS TRANSPARENCY PROGRAM AND TRANSNATIONAL CORRUPTION PREVENTION MECHANISMS will be considered a serious offense, and may lead to the termination of the employment contract, after due disciplinary process, or the termination of the commercial contract for the provision of services, depending on the case.


The Board of Directors and Legal Representative approve this manual, which supports the transparency and business ethics program, through minutes of the Board of Directors.

Therefore, it is issued to take effect as of April 29, 2021.

It may be modified and / or adjusted at any time, which will be recorded in the minutes of the respective company area.

Legal representative