1. Introduction
Our company, Vínculo Digital SpA, is deeply committed to fostering an organizational culture based on ethics, probity, and transparency. For this reason, we have structured and implemented this Integrity & Compliance Program.
The priority goal of this program is to prevent, detect, and respond in a timely manner to irregular conducts such as acts of corruption, fraud, conflicts of interest, or unethical practices in our commercial operations, particularly in our capacity as suppliers to the State of Chile. This program covers multiple implementation phases mandatory for all our collaborators, directors, and strategic partners.
2. Code of Ethics & Conduct
We actively promote a work environment grounded in corporate responsibility. Below are the practices and guidelines that are mandatory for all collaborators of Vínculo Digital SpA, specifically designed to prevent bribery, extortion, nepotism, collusion, embezzlement, and other unethical business practices:
Hiring of Collaborators
Multiple interviews and exhaustive evaluations must be conducted for the selection of new professionals, verifying technical knowledge, capability, work experience, and education. The participation of any collaborator who has family, personal, or financial relationships with applicants in the recruitment process is strictly prohibited.
Selection of Providers
External contracting requires multiple independent quotes and legal documentation verifying the provider's regulatory compliance. Selection will be based on objective criteria such as price, quality, technical capacity, and delivery times. A post-service evaluation will also be performed for our historical records. Interference by collaborators with personal interests in the bidding parties is strictly prohibited.
Gifts & Hospitality
It is strictly forbidden for any member of the company to offer, promise, or receive any type of gift, favor, invitation, or benefit aimed at influencing commercial or administrative decisions. The exchange of commercial courtesy gestures is limited to an accumulated annual maximum of 2 UF per collaborator, and must be reported in writing to management for registration.
Bidding Terms & Probity
It is mandatory to thoroughly review the terms of public and private bids before formulating any application, ensuring that our participation complies with all regulations regarding administrative probity, transparency, and free competition required by state entities and commercial clients.
Accounting & Financial Transparency
Our accounting is managed under the highest ethical and auditing standards, ensuring compliance with tax and fiscal laws in the territories where we operate. We maintain complete, traceable, and accurate records of every commercial transaction, which are reported with transparency to shareholders, auditors, and the corresponding regulators.
Sanctions for Non-compliance
Any detected violation of the rules established in this program, or proven participation in acts of corruption, fraud, or collusion, will be classified as a serious breach of the employment or services contract. This will empower immediate termination from the company without prejudice to the initiation of appropriate civil and criminal actions before judicial authorities.
3. Complaints & Reports Protocol
In order to guarantee the effectiveness of compliance guidelines, Vínculo Digital SpA provides a formal, confidential, and secure channel to report suspected unethical conduct or breaches of the Code of Conduct.
Confidential Reporting Channel
Any collaborator, provider, customer, or interested party can report acts contrary to probity in a confidential and protected manner by writing to our exclusive email address:
* All reports received through this channel are handled directly by the Integrity Committee under strict confidentiality protocols, guaranteeing a total ban on retaliation against good-faith whistleblowers.
Immediate Investigation & Action
Upon receiving a report through our channel, the company will immediately initiate a formal internal investigation. To safeguard the objectivity and transparency of the process, any reported individual will be excluded from the investigation, ensuring non-interference and the complete protection of information.
Resolution & Corrective Measures
Once the case analysis is completed, a detailed report with findings and recommendations will be submitted directly to the board of directors. If ethical violations or irregularities are confirmed, appropriate sanctions will be applied immediately, including administrative measures, immediate termination of contractual relationships, and, if applicable, a formal report to the courts and State regulators.