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Anti-bribery Policy

 

This ANTi-BRIBERY POLICY reflects that our organization has and permanently exhibits a high commitment to the development of our activities with the highest level of ethics, integrity and compliance with current legislation.

At MARCO CAPITAL INC. we are firmly committed to combating bribery in any of its forms, by establishing fairly, honesty and transparently principles, policies and procedures that guide the behavior of all our employees and business partners.

At MARCO CAPITAL INC. WE EXPRESSLY PROHIBIT BRIBERY in any of its forms, whether directly or indirectly, in relation to a public official or body or a private person or organization, as well as any type of behavior or action that may involve a violation of current bribery laws and regulations in the countries that we are stablished.

 

The Board of Directors of MARCO CAPITAL INC. are fully committed and has approved the necessary resources and mechanisms have been provided for the proper implementation of an ANTI-BRIBERY MANAGEMENT SYSTEM aligned with the requirements of the international standard ISO 37001:2016 and the current legislation that applies to us in terms of bribery in the development of our activities, in order to prevent, control and manage any bribery risks to which our organization may be exposed.

 

This ANTI-BRIBERY POLICY applies to all members of MARCO CAPITAL INC., regardless of their location, in the development of their activities of:

  • Factoring
  • Asset-based Lending
  • Supply chain financing
  • USA legal formations and Banking services, for domestic and international

"INTEGRITY AT THE CORE OF ALL OUR ACTIONS"

At MARCO CAPITAL INC we regularly identify and evaluate the bribery risks to which our activities are exposed, documenting the results in our RISK MATRIX. We establish control plans for our risks, analyzed and evaluated above low, with the clear objective of preventing and reducing their probability of occurrence, as well as establish monitoring and control mechanisms.

As a result of the internal and external mechanisms for evaluating the effectiveness of our ANTI-BRIBERY MANAGEMENT SYSTEM, as well as based on the information collected, analyzed and evaluated, we have established control and supervision measures, committing ourselves to continuously improve the effectiveness of our ANTI-BRIBERY MANACEMENT SYSTEM, with the aim of creating a truly living system able to adapt to changing market circumstances and to the improvements, opportunities and failures detected.

 

For the maximum guarantee of independence, we have appointed a specific position within our organizational chart, called Anti-Bribery Officer, endowed with capacity, autonomy, independence and authority, so that, reporting directly to the General Manager, it ensures the correct design, implementation, monitoring and improvement of our ANTI-BRIBERY MANAGEMENT SYSTEM. The designated Anti-Bribery Officer is available to all members of our organization to advise, guide and support them in matters of ethical action and compliance.

We have a CODE OF CONDUCT in place and approved by the Board of Directors. Our CODE OF CONDUCT, as well as the disciplinary consequences for non-compliance, are applicable to all members of MARCO CAPITAL INC., without prejudice to the legal consequences that may fall on it for those acts, facts or behaviors that involve a violation of legality. In this sense, we have a disciplinary system in place to sanction conduct contrary to the provisions of this POLICY, our CODE OF CONDUCT, as well as the other requirements of our ANSI-BRIBERY MANAGEMENT SYSTEM.

Any member of our organization, employee, partner, shareholder, director, representative and/or person acting in an authorized manner in the name or an behalf of MARCO CAPITAL INC., has the obligation to report any action, conduct, information or evidence that is susceptible or suspected of violating this policy or the requirements of the ANTI-BRIBERY MANAGEMENT SYSTEM of our organization and that may involve criminal conduct by action or omission.

At MARCO CAPITAL INC. we have set means of communication so that anyone can report any type of suspicious fact or behavior or can raise any type of doubt or query in this regard:

At MARCO CAPITAL INC. we positively value and strongly encourage the communication of any indication or suspicion of violation of legality by any member, person or organization linked to our organization, so we appreciate the greatest possible detail in the presentation of the facts denounced/communicated.

Our organization has put secure internal mechanisms and processes in place to ensure the confidentiality of the complaints and communications received, as well as to protect from any type of threat or coercion the people who participate in our objective of fighting bribery through communication and reporting.

 

 

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