Governance

Our Compliance Program guides us in our interactions with each other and with customers, suppliers, competitors, creditors, the media, communities and the general public. The Program scope covers laws and regulations, contracts and agreements, antitrust, prevention of losses and fraud, and anti-corruption. Our Compliance Program is managed by the Compliance & Governance function, which reports to the Audit Committee and the Board of Directors, both of which have independent members that can evaluate matters impartially and recommend continuous improvements.

Our Anti-corruption Policy establishes guidelines on the conduct expected of employees, management and third parties in dealing with national and international government organizations on behalf of CBA. The Policy covers topics such as gifts, hiring third parties, and facilitation payments.

Our Code of Conduct outlines guiding principles on business conduct and the conduct expected of employees and business partners. It provides a source of guidance on ensuring that our formal and informal business interests are reconciled with the legitimate interests of stakeholders, as part of our commitment to creating value for both our Company and broader society. The Code also describes the channels available for communicating or reporting any misconduct in confidence.

CBA takes a zero-tolerance approach to unethical, illegal or otherwise dubious behavior. We have an Ethics Hotline to report any suspected violations of our Code of Conduct, Anti-corruption Policy or good practices. Employees and external stakeholders can report concerns and request information by telephone or online. Reports are kept confidential, anonymous and addressed impartially. All reports are handled and investigated by an independent, specialized firm in accordance with CBA’s internal policies and applicable laws and regulations.