Downloads

Business ethics

At Aleatica, corporate integrity is the cornerstone that guides our conduct and decisions.

Our management is founded on ethical principles that promote transparency, accountability, and compliance across all our operations.

We recognise that our ethical performance is a pillar of our double materiality, impacting both our financial strength and the social and environmental context in which we operate.

Our zero-tolerance policy towards misconduct has led to the strengthening of controls and preventive measures. We maintain a firm stance in respecting free competition.

To date, we have not received any convictions, sanctions, or fines related to corruption or unfair competition in any of the countries where we operate.

In 2025, we achieved ISO 37001 certification for anti-bribery management systems.

Additionally, we were recognised as one of the Most Ethical Companies in Mexico, Colombia, Chile, and Peru.

2025 Progress

Italy
We unified the Crime Prevention Model (Modelo de Prevención de Delitos, MPD) using the Bwise tool, strengthening our internal controls
Internal Audit conducted an audit of the Crime Prevention Model.
The MPD underwent an external review.
Held from November 10 to 14 under the theme “Integrity: Small Actions, Big Difference.” We recorded over 3,000 views and a 96% increase in comments. We link rewards for participation to the Aleatica Stars program.

Code of Ethics and Conduct

Safety First

Safety in Business Units; safety of customers and employees.

Social and Environmental Sustainability

Community engagement; environmental care.

Service Excellence

Customer service; quality and innovation.

Corporate Integrity

Zero tolerance for bribery; prevention of money laundering and terrorist financing; gifts; conflicts; insider information; free competition; data privacy; use of assets; brand protection.

Passion for the Team

Respect for human rights; diversity and inclusion.

I CARE, our ethical channel

The Compliance Department manages our ethics channel, I CARE, which is designed to guarantee confidentiality and protect people using it from retaliation while also enabling anonymous reporting. This channel is available to all our staff and stakeholders.

Through I CARE, we reaffirm our collective commitment to integrity and transparency. We value the opinions and concerns of every member of our team and our stakeholders, whether they are reporting unethical or illegal conduct, or raising questions or concerns. As part of Aleatica, we take responsibility for ensuring an ethical environment and for reporting any behaviour that is improper, illegal, or that could put our organisation at risk.

To submit inquiries or reports regarding irregular conduct or breaches of Aleatica's code of ethics and internal policies, the following channels are available:

Intranet

Corporate Integrity > Ethical Channel I CARE

Internet

http://icare.aleatica.com/

Phone

  • Chile: 1230 020 3559
  • Colombia: 0057 1381 65 23
  • España: 900 905 460
  • Italia: 800 727 406
  • Mexico: 800 681 6945
  • Perú: 0800 7 83 23
  • United Kingdom: 0 808 189 10 53
Other countries: go to http://icare.aleatica.com/. Please state the country of origin to get your toll-free numbers.

Compliance investigation process

When the Compliance Department decides to open an investigation, we appoint an investigator based on the nature of the allegation received.

This person coordinates with the relevant departments as needed to conduct the investigation and assesses the appropriateness of implementing precautionary measures throughout the process and its resolution.

We investigate all reports with sufficient grounds and notify the highest designated governance body for Compliance matters at least once a quarter.

Key compliance indicators

In 2025, a total of

179 complaints and inquiries were received

In 2025, we had no cases of corruption

for which we took disciplinary action.

Request additional information

No

I CARE
Report or enquiry

The Compliance Department acknowledges receipt to the reporting individual.

Is the information sufficient?

Yes

Appoint an investigator. Initiate the investigation.

Conduct interviews and collect evidence.

Analyse and evaluate the findings.

Close the case and follow up on recommendations.

Close the case and follow up on recommendations.

Prevention of money laundering and the financing of terrorism (AML/CFT)

At Aleatica, we implement measures to prevent money laundering and the financing of terrorism (AML/CFT) as part of our commitment to ethical and operational responsibility. Our primary goal is to mitigate critical risks by establishing robust barriers that prevent our structure from being used as a conduit for funds derived from illicit activities. We extend this commitment to transparency throughout our entire value chain through rigorous due diligence processes, ensuring that our business partners, suppliers, and customers always operate legitimately.

For us, this is not merely a legal requirement but the foundation of a compliance culture that permeates the entire team, fostering an environment where ethical behaviour is the norm, supported by ongoing training and secure reporting channels

Mexico

In Mexico, the entity responsible for managing the automatic toll collection system on toll roads is considered an obligated entity under the Federal Law for the Prevention and Identification of Transactions Involving Illicit Proceeds. In accordance with this regulation, the Ministry of Finance and Public Credit’s Financial Intelligence Unit is notified monthly of card issuances and cases where cardholders’ deposits exceed the legal limits.

Colombia

In Colombia, Autopista Río Magdalena (ARM) must comply with measures against money laundering and the financing of terrorism, as stipulated in its Concession Contract with the ANI. This involves controls to reduce risk or support compliance, ensuring transactions adhere to applicable regulations.

Before entering into business or professional relationships, a risk analysis is conducted. This analysis includes an assessment of both internal personnel—including managers, administrative, and operational staff—and relevant third parties such as suppliers, contractors, business partners, intermediaries, and potential grantees. The aim is to identify and mitigate integrity and compliance risks.

Transactions that are unusual in terms of amount,

frequency or nature must be reported immediately using the UIAF form via the SIREL online system, following the established procedures.

In 2025, we updated our processes in Colombia, switching from the SAGRILAFT system to SARLAFT 3 , in accordance with Resolution 2328 of the Superintendency of Transport. We have also updated and approved the relevant manuals and reviewed our Transparency and Business Ethics Program to ensure regulatory compliance and uphold our commitment to corporate integrity.
3 SAGRILAFT: Comprehensive Self-Monitoring and Risk Management System for Money Laundering, the Financing of Terrorism, and the Financing of the Proliferation of Weapons of Mass Destruction.

Conflicts of interests​

Each year, individuals holding management and board positions must declare their interests.

The results are presented to the Audit and Risk Committee. If a new conflict arises during the year, it must be reported to the Compliance Department via the established channels (intranet form or the I CARE ethics channel for anonymous reporting).

Zero tolerance for corruption

Indicators

Swipe right on the table.

Indicator
2022
2023
2024
2025
% of people who received anti-corruption training or communications
100%
100% (middle managers and executives)
99.8%
98.3% (executives, middle management, and administrative staff)
Members of the highest governance body who received anti-corruption training
8
6
3
4
Cases of corruption with disciplinary action
0
0
0
0

Third parties assessed for corruption risks

  • Total value
    779
  • Total value
    643
  • Total value
    764
  • Total value
    1,002

Swipe right on the table.

Type
2022
2023
2024
2025
Intermediaries
1
6
10
9
Customers
8
21
19
17
Grantees, sponsors and recipients
6
7
35
44
Provider entities
764
606
674
928
Partners
0
3
26
4
Total
779
643
764
1,002