Closa has implemented a Crime Prevention Model in accordance with article 31 bis of the Criminal Code.
The Compliance Officer is responsible for overseeing Closa’s policies and procedures for identifying and managing conflicts of interest and ensuring that they are properly managed.
They have the following responsibilities but not limited to:
- Support and conduct compliance monitoring, compliance controls and compliance audits.
- Supporting management in integrity risk management processes
- Documenting all ethical incidents and actions taken to resolve them
- Ensure that employees know where they can seek help and advice if they are in doubt about correct business behaviour
- Encourage employees to engage with stakeholders in the event of a compliance issue
Incidents and complaints channel
Closa has proceeded to the creation of a complaints channel (firstname.lastname@example.org) as a high-level control measure, with the aim that any person (administrators, employees, professionals, and managers) or related (collaborators or suppliers) can communicate any indication or suspicion of the commission of conduct that may involve:
- Non-compliance with applicable regulations, protocols, procedures, and internal controls.
- Commission of acts that do not comply with ethical principles and good business practices.
- Commission of acts that could be criminal.
Complaints are received by the Compliance Officer and an external advisor and procedures are regulated to avoid conflict of interest, so that the person reported cannot form part of the persons involved in processing the complaint.
Closa has develop and implemented wide ranging specific controls to prevent the commission of crimes.