Compliance Management

The Compliance Department of Colombia Telecomunicaciones S.A. E.S.P. BIC, which reports to the Global Compliance Department, the Board of Directors and the Hispam General Secretariat, has the purpose of managing preventive and reactive environments related to compliance with (a) the positive legal system and (b) the Telefónica’s internal regulations, in general and with a specific focus on those areas that are most sensitive depending on the circumstances.

Thus, the Compliance function extends to the management of issues that may arise regarding certain matters identified as sensitive from a compliance point of view.

The main matter supervised by the Compliance Department and on which most of its policies, procedures and controls focus is integrity, a transversal concept that captures the fight against corruption and bribery.

Telefónica’s commitment to our stakeholders is zero tolerance for fraud and corruption, as we understand that they have a negative impact on business and society.

Additionally, the Compliance Department is responsible for executing the Compliance program in Colombia in terms of international sanctions programs coordinated by the Global Compliance Department.

The elements that make up Telefónica’s Global Compliance Model are: Prevention, Detection and Response to potential breaches.

Prevention

Organization and government

Identification of non-compliance risks

Politics and procedures

Due diligence checks

Training and awareness

Consultations

Detection

Follow-up on complaints received and managed by the Inspection Management (Internal Audit Management)

Reaction / Response

Discipline and Recognition

Review and mitigation