Ethics and compliance program

Part of the commitments established in the policy is following and respecting regulations applicable to companies that form part of the GEB, the “Zero Tolerance” policy to fraud, money laundering and terrorism financing and corruption. This is in addition to taking the components of the Control System aligned with the “COSO” model as key principles and applying the

en_Programa de Cumplimiento 2024_VF.pdf

Cert No. 020 del Acta CAR No. 92 de 2024.pdf

The construction of the Ethics and Compliance Program was based on international standards and regulatory requirements; seeking to prevent the materialization of the risks of Bribery, Fraud, Corruption, Money Laundering, Financing of Terrorism, Proliferation of Weapons of Mass Destruction, inadequate treatment of personal data and inadequate management of conflicts of interest through the following components:

Since 2017, our company has adopted policies and guidelines for the prevention of Fraud and Corruption, currently it has the Business Ethics, Anti-Corruption and Anti-Bribery Policy, as well as manuals and procedures that establish the framework of action to identify, detect, report, monitor, manage and mitigate Corruption Risks in all its forms, including Bribery.

TGI's Code of Ethics and Conduct defines the standards of behavior that the organization expects from all its employees. This document should be considered as the roadmap for the development of all TGI activities, operations and processes, based on the ethical principles of transparency, respect, equity, legality and responsibility.

The Code of Ethics and Conduct of Suppliers and Contractors is a regulatory and consultation document, mandatory for all TGI Suppliers and Contractors. It is the responsibility of Suppliers and Contractors to adopt, honor and disseminate this Code of Ethics and Conduct for Suppliers and Contractors with their employees and subcontractors, effectively verifying their communication and compliance.

In 2023, 21 reports were received through the ethics line, classified as follows:

All reports were managed in a timely manner, in accordance with theAdministration manuals of the Ethical Channel.

Once the respective verifications and investigations of the 18 reports were carried out, the following results were obtained:

When faced with a potential conflict of interest, the most important thing is to inform yourself as soon as you become aware of it and before making any decision, in order to manage it.

In effect 2023, the relationship in TGI of TGI administrators and collaborators with the different interest groups was framed in the Legality, Ethics and Integrity and therefore no conflicts of interest situations materialized.

The system establishes the framework of reference, the procedural rules and general aspects for the development of the methodologies used for the Prevention and Control of Money Laundering, the Financing of Terrorism and the Financing of the Proliferation of Weapons of Mass Destruction (“SIPLA”). ) (“risks defined with the acronym ML/FT/FPADM”) within TGI, with the purpose of mitigating the possibility that companies become an instrument for carrying out said illicit activities.

Another important element is the verification of interest groups in control lists, for which the official template must be filled out and sent via email: 

oficial.cumplimiento@tgi.com.co 

In 2023, no events related to Money Laundering, Terrorist Financing and/or Terrorism Financing materialized in TGI Financing of the Proliferation of Weapons of Mass Destruction, complying with policies, manuals and guidelines adopted corporate

The Company has a Control Architecture Policy that establishes the control structure necessary to maintain and strengthen the Internal Control System, through a reference model that defines general guidelines, roles and responsibilities necessary for the operation of the ICS of Transportadora de Gas Internacional S.A. ESP as a subsidiary of Grupo de Energía de Bogotá S.A. E.S.P. The conceptual framework of the Internal Control System is the COSO model (2013), issued by the Committee Of Sponsoring Organizations.

TGI complies with Law 1474 of 2011, through which it seeks to strengthen the mechanisms for prevention, investigation and punishment of acts of corruption and the effectiveness of public management control. Annually, the GEB prepares, executes and publishes the Anti-Corruption and Citizen Service plan in compliance with this law. 

Check the Plan here

TGI applies the provisions of Law 1712 of 2014 that regulates the right of access to public information and the procedures for the exercise and guarantee of the right and the exceptions to the publicity of information.

Learn about the Transparency and Access to Public Information Law here

TGI, in compliance with Law 1581 of 2012, protects the constitutional right that all people have to know, update and rectify the information that has been collected about them in databases or files.

Learn more about Personal Data Protection here

Coordination of the timely and adequate attention to the requirements that come from the surveillance and control entities.

Learn more about the control entities here