ANTI-BRIBERY POLICY
This ANTI-BRIBERY POLICY demonstrates APOLO ABOGADOS’ highest commitment to ethical conduct, integrity, and legal compliance in the performance of its activities.
At APOLO ABOGADOS, we are committed to combating unlawful acts of bribery in all their forms by fostering a culture of integrity and ethics and implementing policies and procedures designed to guide the conduct of all members of the organization, professional service providers acting on behalf of APOLO ABOGADOS, and business partners.
APOLO ABOGADOS STRICTLY PROHIBITS BRIBERY in any form, whether direct or indirect, in relation to any stakeholder of the organization, as well as any conduct that constitutes a violation of applicable anti-bribery regulations.
The MANAGEMENT COMMITTEE has approved this POLICY, aligned with the requirements of the ANTI-BRIBERY MANAGEMENT SYSTEM based on ISO 37001:2016, and has allocated the necessary resources for its implementation in order to manage any bribery risks to which APOLO ABOGADOS may be exposed.
Accordingly, APOLO ABOGADOS is committed to complying with the Ecuadorian anti-bribery regulations applicable to our organization, ensuring at all times compliance with the regulations governing the prevention of and fight against corruption applicable within the Ecuadorian jurisdiction.
This ANTI-BRIBERY POLICY is mandatory for all members of the organization in the performance of activities involving:
“ETHICS AND COMPLIANCE ARE THE PRIORITY IN OUR ORGANIZATION”
As an organization committed to transparent and ethical conduct in our daily activities, we have undertaken the management of the bribery risks to which we are exposed, deciding to control those risks assessed above a low level and establishing control plans aimed at preventing their occurrence and mitigating their impact.
At APOLO ABOGADOS, we are committed to the CONTINUOUS IMPROVEMENT OF THE EFFECTIVENESS OF THE ANTI-BRIBERY MANAGEMENT SYSTEM, ensuring that it operates as a system capable of adapting to changing circumstances within our environment.
In order to guarantee the independence and transparency of the ABMS, APOLO ABOGADOS has appointed a Compliance Officer, who shall have the autonomy, independence, and authority necessary to ensure the design, implementation, and continuous improvement of the ANTI-BRIBERY MANAGEMENT SYSTEM. The designated Compliance Officer is available to all members of our organization to advise, guide, and support them regarding ethical conduct and compliance matters.
Every employee of APOLO ABOGADOS and/or any person authorized to act on behalf of our organization is required to report and/or disclose any action, conduct, information, or evidence that may constitute or raise a suspicion of a violation of this POLICY or the requirements of our organization’s ANTI-BRIBERY MANAGEMENT SYSTEM, including conduct that could constitute a criminal offense by act or omission.
We have established communication channels through which any person may report any suspicious fact or conduct or raise any question or inquiry in this regard.
At APOLO ABOGADOS, we positively value and strongly encourage the reporting of any indication or suspicion of a violation of the law by any member of our organization or by any legal entity or individual associated with it.
At APOLO ABOGADOS, we are committed to safeguarding and ensuring the CONFIDENTIALITY of all reports and communications received, as well as PROTECTING individuals who contribute to our efforts to combat bribery through reporting and disclosure from any form of threat or coercion.
This Policy constitutes a mandatory internal standard. Accordingly, any violation thereof shall constitute a breach of the Policy, and the Organization shall adopt the appropriate disciplinary measures in accordance with applicable labor legislation and the procedures set forth in the Code of Conduct, without prejudice to any other liabilities that the offender may have incurred. Likewise, APOLO ABOGADOS reserves the right to take any measures it deems appropriate against those who fail to comply with this Policy.
The Management Committee, together with the Compliance Officer, shall periodically review the content of this Policy, ensuring that it incorporates the applicable Ecuadorian recommendations and best practices in force at any given time, and shall propose any amendments and updates that contribute to its development and continuous improvement.
GENERAL MANAGER
ATTY. JOSÉ GABRIEL APOLO
MAY 2024
