Business Ethics
Code of ethics and conduct
Our code of ethics and conduct reflects best practices and represents our organisational culture. It is a core tool that guides our team to make the right decisions in all circumstances.
We develop annual communication and training plans to reinforce the core principles of the code of ethics and conduct, the Anti-Corruption Policy, and related internal policies.
Our ethical pillars:
Safety First
Ensuring the safety of our employees, business units, and customers is our top priority.
Social and Environmental Sustainability
Service Excellence
Corporate Integrity
Passion for the Team
I CARE, our ethical channel
We have implemented I CARE, our ethical channel (which stands for ME IMPORTA in Spanish), managed by the Compliance Department and designed to ensure confidentiality and protect whistleblowers from any form of retaliation. Reports can also be submitted anonymously. The channel is open to all employees and stakeholders.
Through I CARE, we reaffirm our collective commitment to integrity and transparency. We value the perspectives and concerns of every team member and stakeholder—whether to report unethical or illegal conduct or to raise questions or concerns. As members of Aleatica, we are all responsible for maintaining an ethical environment and reporting any actions that are improper, unlawful, or potentially harmful to our organisation.
Contact methods for reporting misconduct or breaches of Aleatica's ethics policies include:
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
Compliance investigation process
When the Compliance Department decides to open an investigation, an investigator is appointed based on the nature of the allegation. This person coordinates with relevant departments to carry out the investigation and evaluates whether precautionary measures should be taken while the process is underway.
All reports with sufficient basis are investigated. The designated governance body for Compliance matters is notified at least quarterly.
Key compliance indicators
In 2024, a total of
216 reports and enquiries were received.
In 2024, no confirmed corruption cases
resulted in disciplinary action.
Request additional information
No
I CARE
Report or enquiry
Compilance Department responds to the informant confirming receipt
Is there enough information?
Appoint an investigator. Initiate investigation.
Interviews. Evidence collection.
Analysiis and evaluation of results.
Decision-making, disciplinary, and corrective measures.
Closure and follow-up on recomendations.
Anti-money laundering and counter-terrorist financing
México
In Mexico, the company that manages the automatic toll collection system for toll highways is considered a regulated entity under the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds. In compliance with these regulations, we report monthly to the Financial Intelligence Unit of the Ministry of Finance and Public Credit on the issuance of cards and on any case in which the deposits made on these cards by any customer exceed the limits established by law.
Colombia
Autopista Río Magdalena (ARM) operations are subject to money laundering and terrorism funding prevention actions, as set forth in Chapter IV of the Concession Contract signed with the National Infrastructure Agency (ANI for its acronym in Spanish). This requires implementing specific controls to ensure that transactions comply with current regulations and lawful business practices.
To assess risk levels and prevent any suspicious activities, a thorough analysis is conducted before establishing any business or professional relationship. This assessment applies to persons holding an administrative, managerial, clerical positions, team members or persons working for the company, as well as brokers, agents, representatives and factors, provided that they perform services for or on behalf of the company.
When a transaction should appear atypical due to its amount, frequency or nature and cannot be reasonably substantiated, said transaction must be promptly reported in the form designed for such purpose by the Financial Information and Analysis Unit (UIAF for its acronym in Spanish), through the SIREL web environment IT system, with the appropriate formalities and procedures.
Zero tolerance for corruption
In line with our Anti-Corruption Policy, we maintain a firm stance of zero tolerance towards any form of corruption, both within and outside our organisation, in all operations and interactions with third parties—whether public or private.
During 2024, the Compliance Department delivered in-person courses on ethics and anti-corruption, strengthened the anti-harassment campaign, and placed particular emphasis on training for people in leadership positions and team members with direct reports on ethical conduct. In November, we held a Compliance Week, during which we launched an ethical culture survey.
The overall survey score was 90%
Conflicts of interests
In compliance with the Conflict of Interest Standard, all directors and board members at Aleatica Mexico are required to complete an annual Declaration of Interests. This document includes information on their professional activities with other organisations, affiliations, and family interests, among others, with the aim of identifying any potential conflicts of interest. The results are submitted to the Audit Committee.
If an employee or board member is involved in a conflict of interest, they must:
1.Report any conflict of interest to the Compliance Department
as soon as a potential or actual conflict of interest becomes known in commercial relations with customers, suppliers, or any other third party with whom Aleatica has any kind of relationship or whose activities are related or may generate reputational or regulatory risks. Employees or individuals in management positions must report any situation that appears to be a conflict of interest or seek clarification if they are unsure whether what they perceive involves a risk.
2. Such communication must be made in writing
by the employee or director involved in the potential conflict of interest to the Compliance Department, using the Conflict of Interest form available on the corporate intranet, or through I CARE, Aleatica's ethics channel, if they wish to remain anonymous.
3. Act diligently
Regarding the conflict of interest until it is resolved. Thus, once the employee has been notified of the existence of a conflict of interest, they must take the following measures:
- Refrain from making decisions that could undermine Aleatica’s decision-making processes.
- Do not use Aleatica’s data for personal gain.