Policy for the Whistleblower System

Purpose:

This policy governs the process of reporting and investigating allegations of financial or fraudulent misconduct in general, faults to the Code of Ethics and procedures for investigating such complaints and/or accusations. They can be made directly or anonymously following the procedure described in this document.

This policy applies to employees, suppliers/contactors, clients or another third party.

Scope:

Examples of behaviors that can generate investigations:

  1. Accounting and Auditing matters, including a deliberate error in the preparation, evaluation, review or audit of any financial statement or accounting record of the organization, or any inexcusable deficiencies in complying with the organization’s internal controls.
  2. Any dishonest or fraudulent act.
  3. Misappropriation (robbery or theft) for own benefit of money or property under their responsibility or that of a collaborator, including the misapplication of funds, mishandling of cash and accounting and billing errors.
  4. Falsification, alterations, or confections of all or any part of documents, contracts, or records.
  5. Inappropriate activity with suppliers or contractors (including inappropriate negotiations or illegal activities with respect to receiving prize payments for preference of suppliers or contractors).
  6. Any other illegal or irregular use of the properties or assets of the organization.
  7. Pay bribes or give anything of value to a government official directly or indirectly for the purpose of securing an inappropriate advantage, except for donations or gifts that have been previously consulted and expressly approved by the Administration.
  8. Receive or collect in a personal capacity benefits arising from the relationship with the organization´s customers referred to third parties.
  9. Any type of situation that generates illegality or infractions to the norms established in the Code of Ethics, in the Equal Opportunity and Human Rights Policy, or any other policy that applies.
  10. Any type of harassment in the workplace such as psychological, verbal, sexual, etc., coming from any person who works or not in the organization, towards another collaborator, client, supplier, visitor, or anyone who is in the facilities of the organization or who does business with it.
  11. Avoid reporting suspicious situations of clients, employees or contractors that are being covered up by any collaborator of the organization.
  12. Partners, lawyers, executives or collaborators provide their personal services in private to suppliers, customers or competitors, except situations previously consulted and approved by the Board of Directors.

For more examples and details regarding this policy, please email [email protected]

Procedure for Reporting Complaints:

  1. To report your complaints you can choose the following modalities:
  2. Directly to RSM, who will follow the internal procedures and will protect the anonymity of the collaborators, contractors, clients, and others who in good faith have filed any complaint or accusation. RSM will ensure they are not sanctioned, suspended, threatened, or discriminated when complains or accusations are presented in good faith and in accordance with this policy.
  3. To a supervisor, and in such cases, the supervisor should immediately report the matter to RSM.
  4. Directly or anonymously through the email ‘[email protected]’. Only RSM will be enabled to access this address to receive the complaints that have been made.
  5. Through the intranet in the section entitled to complains or accusations or webpages such as morimor.com, fundamorgan.org and others in the in the field enabled (ex: “Denuncias” or “Whistleblower” section).

This policy applies to employees, suppliers/contactors, and clients related to Morgan & Morgan, Morgan & Morgan Legal and other related companies.

 

 

Formulario de Denuncia