Compliance Programs

Cables de Energía y de Telecomunicaciones S.A.S.

Centelsa is committed to strengthening a culture of corporate ethics and legal compliance in its business and processes. To achieve this, it is essential to inform its counterparts (clients, suppliers, third parties, employees, and partners) about the general aspects of the Self-Control System and Comprehensive Risk Management of Money Laundering, Financing of Terrorism, and Financing of the Proliferation of Weapons of Mass Destruction - SAGRILAFT, as well as the Corporate Transparency and Ethics Program (PTEE), in compliance with Colombian legal regulations and our Code of Ethics and Corporate Conduct.

Under these programs, Centelsa has manuals, policies, procedures, and controls designed to prevent and mitigate risks associated with Money Laundering, Financing of Terrorism, and Financing of the Proliferation of Weapons of Mass Destruction (ML/TF/WMD) and their predicate offenses, as well as the prevention of crimes associated with transnational corruption and bribery (C/ST).

To ensure the sustainability of these systems, it is necessary to identify and periodically review risk profiles, ensure compliance with action plans (opportunities for improvement and treatment plans), provide training, use a common language, identify opportunities for system improvement, and promptly report events.

Any report can be sent to the Compliance Officer through the established channels for this purpose, or using those established by the regulatory authorities. For more information about our SAGRILAFT and PTEE compliance programs, you can request information through the following contact channels:

COMPLIANCE PROGRAMS

Self-Control System and Comprehensive Risk Management for ML/FT/FPWMD – SAGRILAFT	Corporate Transparency and Ethics Program - PTEE (to prevent and manage risks of transnational corruption and bribery).

Compliance Officer	Manuals, Policies, and Procedures	Due Diligence	Disclosure and Training
The company has a Principal Compliance Officer and an Alternate Compliance Officer, responsible for ensuring the proper compliance with the SAGRILAFT - PTEE compliance programs.	Implemented documents that provide general guidelines and behavioral guides in daily activities. Compliance with these is expected to prevent and mitigate risks to which one may be exposed in the exercise of their corporate purpose and economic activity.	Set of procedures for making a sufficiently informed decision. In the context of these programs, due diligence refers to those procedures that allow for a proper understanding of counterparts (associates, employees, clients, contractors, distributors, suppliers, and other related parties).	Strategies to inform both internal and external counterparts about the existence and operation of compliance programs.