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Benky Payments SAS Regulations

Transparency and Business Ethics

Benky Payments SAS. reaffirms its commitment to transparency, integrity, and corporate ethics by implementing practices that promote legality and prevent misconduct at all levels of the organization.

As part of this commitment, the company has adopted and implemented a Business Transparency and Ethics Program (PTEE), which includes policies and procedures aimed at preventing corruption, bribery, and other conduct contrary to business ethics.

This program aims to:

  • Promote an organizational culture based on ethical principles and compliance.
  • Prevent, detect, and penalize acts of corruption, bribery, or any misconduct within and outside the organization.
  • Establish secure and confidential channels for the reporting of irregularities, guaranteeing the protection of the whistleblower.
  • Strengthen transparency in relationships with clients, suppliers, government entities, and other third parties.

The implementation of the PTEE is aligned with the guidelines established by the Superintendence of Companies and other regulatory bodies, and complements the SAGRILAFT Policy, thereby reinforcing the comprehensive approach to legal and reputational risk management at Benky Payments SAS.

Ethics Line

Benky Payments SAS makes the BENKY Ethics Line available to its employees, contractors, suppliers, shareholders, stakeholders, and the general public. This is a confidential and secure communication channel designed to promote compliance with ethical standards, prevent irregular situations, and foster a culture of integrity and transparency.

What is the purpose of the Ethics Line?

The BENKY Ethics Line aims to enable the reporting of incidents that may pose ethical, legal, or reputational risks to the organization, such as:

  • Fraud or attempted fraud.
  • Situations related to money laundering and terrorist financing (ML/TF).
  • Misconduct, acts of corruption, and bribery.
  • Misuse or misappropriation of company assets.
  • Violation of policies, internal procedures, or codes of conduct.
  • Unreliable or manipulated financial information.
  • Unauthorized disclosure of confidential or privileged information.
  • Other behaviors contrary to business ethics and internal regulations.

What is the Ethics Line NOT for?

The Ethics Line is not intended for:

  • Shareholder or investor inquiries about corporate decisions or financial strategies.
  • Submission of commercial or service-related complaints, requests, or claims.

For these purposes, BENKY has specific customer and investor service channels.

Confidentiality and Whistleblower Protection

Benky Payments SAS guarantees the confidentiality of all information received through the Ethics Line, as well as the protection of the identity of those who use it in good faith to report irregularities. The company prohibits any form of retaliation against those who submit reports under these principles.

Internal Reporting Channel:

Fraud - Bribery - Corruption - Money Laundering - FT

Lineaetica@Benky.co  

Ethics Line: (+57) 310-210-7887

TO MAKE YOUR REPORT, CLICK HERE “The Google Form opens,” which must be directed to the compliance mailbox and Ethics Line: Lineaetica@Benky.co.

External Reporting Channels:

National Citizen Service: 01-8000-114319. Superintendence of Companies Reporting Channel for Transnational Bribery, available at the following link:

https://www.supersociedades.gov.co/web/asuntos-economicos-societarios/canal-de-denuncias-por-soborno-transnacional

http://www.secretariatransparencia.gov.co/observatorio-anticorrupcion/portal-anticorrupcion

Benky Payments SAS Regulations

Money Laundering and Terrorist Financing (ML/TF/FPADM)

Benky Payments SAS, in compliance with its commitment to good corporate governance, adopts the policies and guidelines issued by the Superintendence of Companies. These are based on best practices aimed at preventing Money Laundering and Terrorist Financing (ML/TF/FPADM) risks, in strict accordance with current national and international standards.

The company has a SAGRILAFT Policy (Comprehensive Money Laundering and Terrorist Financing Risk Management and Self-Control System), which establishes the guidelines and procedures that its related parties must follow to prevent and mitigate risks associated with money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction (ML/TF/FPADM).

These policies are mandatory for all employees, contractors, suppliers, and third parties associated with the company.

Key Components of the SAGRILAFT Policy

The SAGRILAFT Policy of Benky Payments SAS is structured around the following fundamental components, which enable effective management of the risks of Money Laundering, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction (ML/TF/FPADM):

  • Risk identification and assessment: A comprehensive analysis is conducted to identify, classify, and evaluate the ML/TF/FPADM risks to which the company is exposed, taking into account factors such as customer types, products, channels, and jurisdictions.
  • Prevention and control measures: Internal controls are implemented to mitigate identified risks, such as KYC policies, due diligence and enhanced due diligence (EDD) processes, transaction monitoring, and verification of counterparts and ultimate beneficiaries.
  • Reporting and monitoring system: A continuous monitoring system is established, using tools and processes that enable the detection of unusual or suspicious transactions and their corresponding reporting to the competent authorities, in accordance with current regulations.
  • Senior management commitment: The senior management of Benky Payments SAS demonstrates an active commitment to preventing ML/TF/FPADM, providing the necessary resources and promoting a culture of compliance at all levels of the organization.
  • Training and awareness: Training and awareness programs are developed for employees, contractors, and third parties to ensure the knowledge, understanding, and application of the SAGRILAFT Policy and its associated procedures.
  • Responsible for risk management and self-control: The company has a Compliance Officer, who is in charge of managing the risk system. This official is responsible for leading its implementation, supervision, updating, and reporting to senior management and regulatory bodies if required.

Penalties for Non-Compliance

BENKY PAYMENTS SAS has established within its SAGRILAFT Policy a sanction regime applicable to employees, contractors, suppliers, and third parties who fail to comply with the provisions, guidelines, and procedures set forth in said policy.

Non-compliance with the SAGRILAFT Policy may result in sanctions of a:

  • Administrative: Warnings, reprimands, or suspension of related activities.
  • Labor: Disciplinary sanctions in accordance with the provisions of the internal work regulations, which may include justified dismissal.
  • Corporate: Termination of contracts with suppliers or partners, and even legal actions if complicity or participation in illicit activities is evident.

These sanctions aim to ensure the effectiveness of the system and reinforce the institutional commitment to preventing ML/TF/FPADM.

Benky Payments SAS Regulations

Data Protection

At BENKY PAYMENTS SAS, we protect what you value most: your personal information.

At Benky Payments SAS, we are committed to the protection, security, and confidentiality of the personal data of our users, employees, contractors, suppliers, and other stakeholders. For this reason, we have implemented mechanisms, policies, and procedures aligned with Colombian legislation, guaranteeing the proper handling of personal information.

The management of personal data at Benky Payments SAS is governed by:

The management of personal data at Benky Payments SAS is governed by:

Law 1581 of 2012: Regulates the processing of personal data contained in public and private databases. It is mandatory for all entities, including financial institutions.

Law 1266 of 2008 (Habeas Data Law): Regulates the management of personal data of a financial, commercial, credit, services nature, and data originating from third countries.

Political Constitution of Colombia: Recognizes the fundamental right to habeas data, guaranteeing the confidentiality of personal information and its exclusive use for the purposes authorized by the data subject.

Rights of Data Subjects

Individuals whose data is processed by Benky Payments SAS have the right to:

  • Know, update, and rectify their personal data.
  • Obtain a copy of the authorization granted for the processing of their data.
  • Be informed about how their data is used.
  • Submit inquiries and complaints in accordance with established legal procedures.
  • Request the deletion or revocation of consent when legal provisions are not complied with.
  • Access their personal information free of charge.

Protection Measures Implemented

To guarantee the security and confidentiality of personal data, Benky Payments SAS has adopted the following measures:

  • Purpose: All collection and processing of personal data must have a legitimate, clear purpose authorized by the data subject.
  • Restricted circulation: Personal information will not be disclosed publicly, except in cases authorized by law or by the data subject.
  • Information security: Technical, administrative, and organizational measures are implemented to prevent unauthorized alteration, loss, access, or consultation of data.
  • Confidentiality: Access to personal information is limited exclusively to duly authorized persons.
  • Encryption and protection technologies: Technological tools, such as encryption, are used to protect the integrity and confidentiality of information.

Commitment to Security and Trust

In summary, Benky Payments SAS aims to provide peace of mind and trust through a robust personal data protection system that complies with current legislation and is based on principles such as:

  • Confidentiality: Only authorized personnel can access the data.
  • Integrity: Data is kept complete, accurate, and up-to-date.
  • Availability: Data is accessible when needed, under the conditions permitted by law.