How to make the complaint or inquiry successful?

Stay in touch: having the ability to contact whoever complains or inquires is a key factor in the success of an investigation or in responding to a query. That is why it is important that you follow up on your complaint or query so that you will be able to know the progress of the process, respond to our concerns or expand the information. You can leave us a means of contact without having to reveal your identity.

Tell us all the details: the more information, the higher the chances of confirmation.
Keep these recommendations in mind:

• Use channels such as the telephone line, Whatsapp or the EthicsGlobal chat, where you can interact with agents who will help you file your complaint
• Give the full name and position of those involved, name the person or persons who have knowledge of the facts.
• Describe the place and date where the events occurred.
• If possible, get elements that can serve as evidence.
• Write in detail how the events happened.

How can I follow up on a complaint or query that I have submitted?

sends the information to the corresponding Ethics Committee or Ethics Officer within a maximum of 24 hours after the complaint or query has been made. After receipt, the company has a maximum term of 30 business days, extendable for an equal period, to resolve the case.

How long will it take to resolve a complaint or query already made?

EthicsGlobal sends the information to the corresponding Ethics Committee or Ethics Officer within a maximum of 24 hours after the complaint or query has been made. After receipt, the company has a maximum term of 30 business days, extendable for an equal period, to resolve the case.

How does it work?

The receipt of complaints and inquiries is managed by EthicsGlobal, an external company totally independent from SURA AM, which is also a specialist in the matter; In this way, it seeks to guarantee the transparency and seriousness of ethical management and respect for the rights of informants.

We have various channels for receiving complaints or inquiries to the Ethics Line, all of which are managed by EthicsGlobal:

1. Through this portal you can fill out a form in which all the information necessary to carry out the investigation will be requested.

2. By phone, to the following lines:

   
   

   Argentina	0800-345-5478
   Brasil	800-8923-392
   Chile	0800-914-501
   Colombia	01-800-5189191
   El Salvador	2136-6543
   México	800-04-38422

   Panamá	836-5888
   Perú	0800-78424
   Dominican Republic	200-9643
   Uruguay	000-416-205-6395

   
   
   

   In which you will be attended by an expert in attention to complaints and ethical queries from the EthicsGlobal company.

3. You can also file your complaint or query by writing to the email sura@sistemaetico.com or through the Chat that you will find on this page.

4. Through the EthicsGlobal App

   Download the app on Google Play or App Store

   

   Log in to the app, write the code or scan the QR code and answer the questions.

   
   

   

Whichever means you choose, complaints or inquiries will be treated confidentially and anonymity is guaranteed for those informants who require it.

A. Reception

Complaints may be submitted through the various channels made available by the Company and will be centralized by the Compliance Department, which will be responsible for gathering the information and, when possible, seeking the greatest level of detail regarding the facts, depending on the channel used to submit the complaint.

The complainant may file the report anonymously; however, if they choose to reveal their identity, the Company will guarantee strict confidentiality and will implement measures to prevent retaliation.

Each complaint will be assigned a unique and sequential case number based on the order of reception.

B. Classification and Referral

Complaints received through any of the enabled channels will be classified according to the subject matter or the position of the person being reported.

Once the complaint is received, the Compliance Department will be responsible for referring it to the Responsible Area within three (3) business days of receipt.

C. Responsible Area for Management

Based on the classification of the complaint, the Responsible Area will be in charge of processing and handling the assigned cases.

D. Report Submission to the Ethics Committee

The Responsible Area will have fifteen (15) business days, starting from the day after the complaint is notified by the Compliance Department, to analyze and prepare a report for the Ethics Committee. The report must include their assessment regarding the possible violation of the Code of Conduct and a recommendation on whether an investigation should be initiated.

The time established for preparing the report may be extended up to two equal periods with prior authorization from the Ethics Committee. Additionally, if the Responsible Area requires additional information related to the complaint and the complainant has provided a means of contact, the information may be requested. A maximum period of 15 business days will be set for this. If the complainant does not provide the information or does not explain the inability to do so within this time, the case will be closed.

Once the report is submitted, the Ethics Committee will decide whether the reported conduct constitutes a violation of the Code of Conduct. If so, it will assess whether it has sufficient elements to make a decision or if further investigation is needed. In such a case, the Committee may engage an external expert in the relevant subject.

If the Committee determines that there is insufficient evidence of conduct violating the Code of Conduct, the case will be closed.

In both scenarios, the decision will be documented in the meeting minutes and communicated to the complainant, provided they supplied contact information.

Baseless rumor spreading, false complaints, or deliberately misleading information will be subject to review. If bad faith is confirmed, disciplinary measures may be applied according to the Company’s Internal Work Regulations.

E. Investigation

The investigation process will be carried out by the Responsible Area. Based on the facts and reported conduct, the Company may hire an independent third party to conduct the investigation or support the process.

In any case, the investigation must be completed within ten (10) business days, which may be extended for equal periods with prior approval from the Ethics Committee.

Complaints related to internal or external fraud will be investigated by the Internal Audit Department.

F. Implementation of the Investigation Work Plan

The Responsible Area or the third-party investigator must document each action taken, detailing the activities carried out and the evidence needed to determine whether the conduct occurred and who is responsible.

G. Report to the Ethics Committee

As a result of the investigation, a report will be submitted to the Ethics Committee with the findings and conclusions.

If it is proven that an employee has engaged in conduct violating the Code of Conduct, the Ethics Committee will decide on the applicable sanction, following the guidelines established in the Internal Work Regulations, and will notify the Human Resources Department to proceed accordingly.

If the reported conduct cannot be proven, the case will be closed.

H. Criminal Complaints

If, during the management of a complaint, it is determined that the reported conduct may constitute a crime under Colombian law, the Company will file a report with the competent authority and will carry out all actions as directed by that authority.

When a complaint must be referred to the Board Committees, as per the previously described rules, the Secretary of the Board of Directors and the Company President will be responsible for managing the case, following these timelines:

• Notification to the Committee: Ten (10) business days from the day the complaint became known.
• Investigation: A maximum of thirty (30) business days from when the Committee decides to initiate an investigation. This period may be extended with prior authorization from the relevant Committee. The Committee may request the hiring of a third party to carry out the investigation.

Additionally, the Company must ensure that the investigation process always complies with the procedures established in the Internal Work Regulations and respects the rights of involved employees and Directors.

Inquiries received through the Company’s official communication channels that relate to the application of the Code of Conduct or the internal policies derived from it will be handled by the Compliance Department. It will take the necessary steps to resolve them within a maximum of ten (10) business days, which may be extended only once for an equal period.

The Compliance Department will periodically present a report to the Ethics Committee on the inquiries received.