Comply with regulations and ensure ethical conduct in accordance with international standards.
To this end, following the enactment in 2009 of the criminal liability law for legal entities in Chile (Law 20.393), ME Elecmetal decided to implement a Crime Prevention Model to comply with this law and ensure that its operations were framed within ethical standards related to the crimes indicated by the regulation. Originally, the law established three crimes, which have gradually increased. These crimes are related to money laundering, terrorism financing, receiving stolen goods, bribery, and incompatible negotiation, among others.
The crime prevention model was designed and developed, which includes different activities and governance or support areas.
There are 4 instances to monitor and manage the different activities carried out:
- Audit Committee: composed of three directors of ME Elecmetal, plus two members of management (General Manager and Corporate Finance Manager) and the Internal Audit Manager, who meet quarterly.
- Ethics Committee: made up of two members of ME Elecmetal management, specifically the General Manager of South America and the People Manager, plus the Internal Audit Manager. It meets every three months.
- General management
- Support management
The activities managed and monitored in the Model are related to prevention, detection, response, and monitoring / updating concerning employees, clients, and suppliers.
At the prevention level, one of the most relevant activities is employee training, a mandatory activity conducted annually online, in which operators and administrative staff participate, with a special focus on supervisory and administrative positions, the latter being more exposed to risks related to the crimes typified in the Law due to the responsibilities they may have.
Additionally, for new clients, ME Elecmetal applies a due diligence process to ensure the nature of their ownership as well as their financial solvency.
Having a robust model to comprehensively address risks related to the crimes indicated in the law. Furthermore, this allows ME Elecmetal to operate confidently in case any compliance risk materializes.
Specifically, ME Elecmetal's Model addresses: instruments, the risk and control matrix, whistleblowing channel, training, and governance for its management and monitoring.
Prevention Model
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“At ME Elecmetal, how business is conducted matters. It must be carried out within a framework of ethical responsibility, ensuring strict compliance with local laws and regulations and the expectations of our stakeholders.”
In October 2022, the certification of the Crime Prevention Model was renewed for two more years, until 2024.
Currently, work is already underway for the next certification process.
Regarding training conducted in 2022, the number of trained employees increased by 7% compared to 2021.
In 2022, an electronic form for declaring conflicts of interest was also implemented through a platform with an external provider, which improves the quantity and quality of information related to conflicts and potential conflicts of interest that Elecmetal employees may have.
BH Compliance, who monitor the risk matrices and the controls applied for their mitigation and grant certification of the Crime Prevention Model.
B-GRC, who technically manage the conflicts of interest form.
Fundación Generación Empresarial, who technically manage ME Elecmetal’s Whistleblowing Channel.
