Integrity Program

C O M P L I A N C E

Integrity Program

The Quequén Port Authority Integrity Program expresses our commitment to ethical, transparent, and responsible management, in line with the values that guide our daily operations. This initiative is embodied in concrete tools, such as the Code of Ethics and Workplace Coexistence, which establishes principles, standards, and guidelines for behavior that should govern relations within our port authority and with the community.

The complaints channel is anonymous and strictly confidential, provided by an independent third party, for reporting potential irregularities. It is very important that the information you provide is complete and accurate.

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The Statute defines the mission, objectives and principles that guide our Compliance function at the Puerto Quequén Management Consortium. It also formalises the institutional commitment to establishing, promoting and continuously improving a solid culture of ethical integrity.

The Code promotes a culture of integrity that prioritises respect, fairness, inclusion, accountability and good faith at all levels of the organisation. It also seeks to prevent conflicts of interest, foster safe and healthy working environments, and ensure clear procedures for dealing with situations of violence or discrimination.

The Conflict of Interest Declaration form must be completed by individuals who identify a current or potential situation that could pose a risk to impartiality between their personal interests and their work responsibilities.

The Dual Employment and/or Professional Practice Declaration form is intended for those who have a second job or practise their profession independently, with the aim of detecting possible incompatibilities, ensuring time commitment and preventing situations that affect the performance of duties.

Conflict of interest

Double employment

Comprehensive Model

Prevention

Identification and anticipation of current and potential risks.

Determining the regulatory framework and developing a Code of Ethics and Workplace Compliance.

Establishing an Ethics Hotline for administrative reporting by KPMG.

Promoting the institutional culture of compliance through the Annual Training and Internal Communication Plan.

Verification

Training and supervision for continuous improvement.
Monitoring the work environment and disseminating key messages.
Internal monitoring of indicators.

This refers to the actions the company takes to address detected non-compliance situations, both preventively and correctly.

It establishes mechanisms to investigate and resolve violations, apply sanctions, implement corrective measures, and promote a culture of compliance.

Report

This stage is crucial to ensure that the company complies with applicable laws and regulations, as well as its internal policies.

It involves detecting, assessing, and reporting potential noncompliance to the competent authorities so that the necessary measures can be taken.

Answers

FAQ

Is our Ethics and Compliance Channel managed by Puerto Quequén employees?

No. The Ethics and Compliance Channel is managed by KPMG, an independent and internationally recognized firm. KPMG operates the Ethics Line externally to ensure the confidentiality, independence, and professionalism of the process. This channel is available to employees, suppliers, clients, and any third party, 24/7, and in several languages.

Why do I have to report what I know?

Integrity, responsibility, and transparency are fundamental pillars for the Puerto Quequén Consortium. Reporting any violation of the Code of Ethics and Workplace Collaboration strengthens our ethical culture, protects people, preserves our institutional reputation, and helps prevent future risks. No one can solve a problem if it isn’t known.

What happens after I contact the Ethics and Compliance Channel?

After submitting a report through any of the six channels available (phone, website, email, WhatsApp, postal mail, or in-person interview), KPMG will assign a unique code and password. You can track the status of the report on the website. The report will be evaluated, categorized, and processed according to internal protocols, safeguarding the confidentiality of the complainant.

Is the security and confidentiality of communications submitted through the Ethics and Compliance Channel guaranteed?

Yes. The identity of the whistleblower will be protected in accordance with the current protocol, unless the whistleblower expressly authorizes disclosure. KPMG does not record calls, IP addresses, or other personal data without informed consent. All information will be treated confidentially, securely, and in accordance with current regulations.

Can I use the Ethics and Compliance Channel to report emergencies or customer complaints?

No. This channel is not intended for emergencies or customer service-related inquiries. In case of emergency, contact the relevant public services. For customer inquiries or complaints, please use the institution’s designated service channels.

What is the purpose of the conflict of interest procedure?

The objective is to prevent personal, family, or economic interests from interfering with professional decision-making. The protocol establishes clear criteria for identifying, declaring, and managing these conflicts based on the transparency and impartiality expected of all staff.

Do we have regulations for managing gifts and entertainment?

Yes. The protocol establishes criteria for accepting or offering gifts or courtesies, ensuring that they do not compromise independence or pose undue influence. Every situation must be reported and evaluated in accordance with the Code of Ethics and Workplace Compliance.

The areas of action of our Compliance

Ethics and prevention of corruption

A strong ethical culture, promoting honesty, transparency, and accountability, is essential to preventing corruption at all levels.

Conflicts of interest

Identifying specific and objective situations in which a risk to impartiality in decision-making is presumed contributes to the proper exercise of the functions and responsibilities of employees and managers consistent with the Port Authority's mission.

Free competition and fair business practices

Two fundamental pillars of a healthy market economy. They imply that companies can offer goods and services without artificial restrictions, interacting ethically and honestly with each other and with consumers.

Gender violence

In an effort to ensure a workplace of trust, security, and respect for people's rights, the Puerto Quequén Management Consortium protocol adopts action measures to address situations of discrimination and/or gender-based violence against women and members of the LGBTI+ community.

Prevention of money laundering and terrorist financing

The implementation of control policies and procedures to detect, avoid, prevent, and report suspicious transactions in which illicit funds enter the financial system and/or legal resources are used to finance terrorist activities.

Compliance with environmental, safety and operational standards

Compliance with laws, regulations, and standards related to environmental protection, the protection of worker health and well-being, and operational efficiency.

Integrity in contracting

Promoting efficiency, trust, and sound resource management, we adhere to the ethical values of transparency, honesty, impartiality, and accountability in all aspects of the contracting process, from planning to contract execution.

Protection of personal data

This is the guarantee or ability to control one's own information against automated or non-automated processing, on any medium that allows its use, storage, organization, and access.

Transparency and accountability

Complementary concepts. They create a virtuous circle of citizen participation and good governance. They reinforce each other. They promote public trust and prevent corruption through open and accessible information.