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SAGRILAFT Policy
- For the proper operation of the SAGRILAFT policy, GAMMA INGENIEROS implements the following guidelines, which must be complied with by all shareholders, management team, employees, clients, suppliers, or third parties with whom the company has a relationship.
- Over the achievement of commercial goals. GAMMA INGENIEROS SAS, committed to the proper implementation of the SAGRILAFT Policy, will prioritize the results obtained through the monitoring and analysis of clients over any commercial goal or interest.
- For the acceptance and onboarding/negotiation/contracting of clients and counterparties. Gamma Ingenieros will not establish a relationship with any natural or legal person that is included on binding international lists for Colombia under international law (United Nations lists), OFAC lists, or other lists of criminals and terrorists which, by their nature, are considered high-risk activities for ML/TF/PFADW (LA/FT/FPADM), or when any of their shareholders, partners, or employees appear on restrictive lists.
- In the event that any property, asset, product, fund, or right owned by, or under the administration or control of, any designated country, person, or entity on restrictive lists is identified or verified, the Compliance Officer must immediately report it to the UIAF and inform the Office of the Attorney General (Fiscalía General de la Nación) through the channels designated for such purpose.
- Monitoring, control, and detection of unusual and suspicious transactions. Gamma Ingenieros will screen at least once a year all shareholders, management team, employees, clients, suppliers, or third parties with whom the company has a relationship, in order to monitor, control, and detect potential unusual and/or suspicious transactions.
- All payments and collections made with both clients and suppliers must be executed via wire/electronic transfers and/or checks through banking institutions, where the account holder must be the natural or legal person with whom the relationship/contract was established.
- Documentation for ML/TF/PFADW (LA/FT/FPADM) validation. Whenever a relationship/contract is executed, modified, or renewed (including automatic renewals), the submission of the necessary documentation to conduct the restrictive lists screening with ML/TF/PFADW information must be requested. This includes the Know Your Customer (KYC) form, a Certificate of Good Standing / Chamber of Commerce certificate issued within the last 30 days, Tax ID (RUT), a copy of the legal representative’s ID, and ownership/shareholding structure.
- Substantiation of all operations, transactions, and contracts with supporting documentation. Without exception, engaging in activities, transactions, and contracts without the respective internal and external supporting documentation, duly dated and authorized by the parties involved or preparing them, is strictly prohibited. Such supporting documentation may include contracts, commercial offers or proposals, and their corresponding purchase or service orders.
- Any document substantiating transactions, business operations, or contracts, in addition to constituting the support for negotiations and accounting records, serves as evidentiary backing for any investigations that competent authorities may conduct. Therefore, it must be retained for a period of at least ten (10) years from the time the transaction was identified, in accordance with Article 28 of Law 962 of 2005 and Chapter X of the Basic Legal Circular (Circular Básica Jurídica) of the Superintendency of Corporations (Superintendencia de Sociedades).