Report - COP Prototype

2022 Communication on Progress

Transportes Caravana S.A.S

Published date

June 8, 2022

No. of questions

Supplemental files

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	5
Male (%)	4
Female (%)	1
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	3
Above 50 years old (%)	2
From minority or vulnerable groups (%)	0
Executive (%)	5
Independent (%)	0

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Se reciben ocasionalmente auditorias de clientes para evaluar cumplimiento en derechos humanos y laborales, GEI

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
04 de marzo de 2022
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Identificación de riesgos en la operación en derechos humanos y acciones de prevención. Política de Derechos Humanos, Código de conducta, divulgación y comunicación de los derechos humanos, participación de webinar con Pacto Global, sistema de reporte de acoso laboral, conformación de Comité de Convivencia para evitar acosos laborales, reporte en la herramienta SDG Corporate Tracker de acciones enfocadas al sector Social- Derechos Humanos.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
4 de marzo de 2022
Child labour
4 de marzo de 2022
Non-discrimination in respect of employment and occupation
Occupational safety and health
4 de marzo de 2022
Working conditions (wages, working hours)
4 de marzo de 2022

Optional comment

Están en las políticas de : Política Gestión Integral y Política de Derechos Humanos, ambas del 4 de marzo de 2022

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	100

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	0

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	25
Non-executive board	50

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	0

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Comité de SST, Comité de Seguridad Vial, Comité de Convivencia, Pagos parafiscales de acuerdo a la ley; Alianzas de servicios para los empleados en seguros , servicios médicos en casa, gastos funerarios, Programa de seguimiento con los contratistas, Programa de capacitación y desarrollo personal , Programa de vigilancia y prevención del COVID, Programa de vigilancia y prevención Osteomuscular, Programa de vigilancia y prevención visual, Programa de vigilancia y prevención de sobrepeso, protocolos de bioseguridad covid, simulacros de prevención en covid, simulacro en choques, simulacros en evacuación, simulacros en derrame de sustancias peligrosas en carretera, brigadas de salud, medidas de prevención de acoso laboral, divulgaciones de prevención sobre trabajo infantil, Reporte componente ECONOMICO ODS año 2020 en la plataforma SDG Corporate Tracker

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
4 marzo de 2022
Water
4 marzo de 2022
Oceans
Forests / Biodiversity / Land Use
4 marzo de 2022
Air Pollution
4 marzo de 2022
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
4 marzo de 2022
Energy & Resource Use
4 marzo de 2022

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

863.44

Scope 2 Emissions

Full

None

Emissions (tCO2e)

2.63

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

0.11

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Somos una empresa de servicio con terceros y no tenemos control directo sobre los vehículos de transporte que se contratan

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total
No extraemos agua
Groundwater:
No usamos agua subterranea
Surface water:
No usamos aguas superficiales
Rainwater:
No usamos agua de lluvia
Wastewater:
No generamos aguas residuales en nuestro servicio
Percentage of water withdrawn in regions with high or extremely high water stress (%)
no usamos agua extraída en regiones con estrés hídrico alto o extremadamente alto

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total
Groundwater:
Surface water:
Rainwater:
Wastewater:
Percentage of water consumed in regions with high or extremely high water stress (%)

Optional comment

No se tiene grifos, ni baños, ni cocina en la oficina, se recurre a los baños del edificio.

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

Unknown

Not applicable (Please provide additional information)

No tenemos consumo de agua en nuestro servicio en regiones con alta o extremadamente alta estrés hídrico.

Sector-specific: Air pollution

17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

	Emissions (tCO2e)	Unknown	Not applicable (Please provide additional information)
NOx
no generamos ni medimos esta emisión
SOx
no generamos ni medimos esta emisión
Volatile Organic Compounds (VOC)
no generamos ni medimos esta emisión
Hazardous air pollutants (HAP)
no generamos ni medimos esta emisión
Particulate matter (PM10)
no generamos ni medimos esta emisión
Persistent organic pollutants (POP)
no generamos ni medimos esta emisión
Other (please specify in text box)

Sector-specific: Waste

18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

Waste Generated (t)

0.02642

Unknown

Not applicable (Please provide additional information)

19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

Hazardous Waste Ratio (%)

Unknown

Not applicable (Please provide additional information)

20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

Single-use plastics (tonnes)

Unknown

Not applicable (Please provide additional information)

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Politica medio ambiente, id aspectos e impactos ambientales con controles y divulgación de los mismos, participación mesas de trabajo medio ambiental con Pacto Global, perteneciente a la Red de Gestión de residuos de Pacto Global, uso de programas posconsumo para disponer residuos peligrosos, programa de mantenimiento preventivo y uso de programas posconsumo para los residuos del mismo, revisión de certificados de emisión de gases de los vehículos vigentes, simulacros de atención de derrames de sustancias peligrosas en carretera, medición de consumo de agua, luz y generación de residuos en oficinas, sensibilización de uso adecuado de recursos no renovables, divulgación de los días ambientales: tierra, árbol, agua, medio ambiente, campaña de disposición de residuos peligrosos y reciclables con Pacto Global, cálculo de huella de carbono, Reporte ODS en la herramienta SDG Corporate Tracker de acciones en la Ficha de Medio Ambiente.

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

marzo 4 de 2022

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

en la Política de Gestión Integral revisada el 4 de marzo de 2022

Prevention

3. Who receives training on anti-corruption and integrity?

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
No se han presentado incidentes de corrupción
Confirmed during the current year, and related to this year	0
No se han presentado incidentes de corrupción

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

se tiene implementado el Programa SIPLAFT " Sistema de Prevención y Control del lavado de activos, la financiación del terrorismo y financiamiento de la proliferación de armas de destrucción masiva", el cual deben implementar todas las empresas habilitadas por el Ministerio de Transporte para la prestación del servicio público de transporte terrestre y es revisado por la Superintendencia de Transporte durante el año por medio de unos reportes.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

se tiene implementado código de ética, la Política de Gestión Integral tiene referenciada el tratamiento de corrupción, se tienen divulgados los valores de la empresa, contamos con el Sistema integral de prevención y control del riesgo de lavado de activos y de financiación del terrorismo (SIPLAFT), se tiene una línea ética para reportar casos de corrupción, se tiene establecido un Programa Anticorrupción, se tienen identificados y valorados los riesgos en corrupción en la empresa y los controles que se establecieron, participación en actividades y webinar de Alliance For Integrity, se tiene certificado un Sistema de Gestión en control y seguridad física en el que uno de los ítems son controles anticorrupción (Certificación BASC diciembre 2022), campañas anticorrupción con personal directo y contratistas, capacitaciones de temas anticorrupción internas, Participación en la construcción del 3er reporte Nacional de avance en la implementación de ODS presentados por el gobierno nacional ante la ONU, Participación encuesta Nacionalidad de Integridad Empresarial Noviembre de 2021, Participación encuesta Estado de Cumplimiento Digital con Alliance For Integrity Noviembre de 2021, divulgación día internacional contra la corrupción, Reporte en la herramienta SDG Corporate Tracker de acciones en la Ficha Social donde se reporta el tema de anticorrupción.