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Ethics and compliance program

Since June 2017, the Company has adopted the Policy on Internal Control and Prevention of Fraud and Corruption , which establishes the commitments of the companies that make up Grupo Energía Bogotá for the adoption and maintenance of an Internal Control System for the orderly and efficient achievement of the objectives, management and results of the Group's companies through the implementation of standards and procedures for the fulfillment of this task.


Part of the commitments established in the policy is following and respecting regulations applicable to companies that form part of the GEB, the “Zero Tolerance” policy to fraud, money laundering and terrorism financing and corruption. This is in addition to taking the components of the Control System aligned with the “COSO” model as key principles and applying the

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Compliance Department

As a result of this separation of duties, the Corporate Compliance Department was created, which is part of the Legal and Compliance VP and reports directly to the Audit and Risk Committee of the Board of Directors of GEB.


The objective of the Compliance Department is to formulate, implement and control the policies on transparency and compliance within the Group through the establishment of monitoring and control mechanisms and to promote a corporate culture of probity in its activities and relations with all stakeholders

The construction of the Ethics and Compliance Program was based on international standards and regulatory requirements, seeking to prevent the materialization of the risks of money laundering and terrorism financing, fraud and corruption, through the following components:


It is the document through which the GEB establishes and develops the principles of behavior and the rules of action that govern its administrators and collaborators and those of its subsidiaries, based on its corporate values: transparency, respect, integrity, and equity. Through the Code, the GEB declares its commitment to a 'zero tolerance' policy against fraud, money laundering, terrorism financing, and corruption.

It is the instrument through which GEB ensures the right of all shareholders, administrators, collaborators, contractors of the Group, and other stakeholders, to report situations that may potentially be classified as alleged fraud and/or corruption events, or unethical conduct within GEB..


Additionally, this Channel allows for the formulation of inquiries aimed at resolving ethical dilemmas, among which conflicts of interest can be found. These are situations in which the integrity and judgment of a collaborator or administrator may be influenced by the possibility of choosing between the interest of the company, that of a third party, or their own.


In the face of a potential conflict of interest, the most important thing is to report it as soon as it is known and before making any decision, in order to manage it effectively.

It is the Comprehensive System for the Prevention of Money Laundering and Terrorism Financing implemented by the GEB. It is composed of several elements, including red flags, which are behaviors or characteristics of certain transactions or individuals that could lead to the detection of a suspicious money laundering or terrorism financing operation.


These signals must be reported immediately. Another important element is the verification of stakeholders in control lists, for which the official template must be completed and sent via email to:

Statutory Auditor Certification SIPLA II Semester.pdf

GEB implements what is established in Law 1712 of 2014, which regulates the right to access public information and the procedures for the exercise and guarantee of this right, as well as exceptions to the disclosure of information.

GEB complies with Law 1474 of 2011, through which the strengthening of mechanisms for the prevention, investigation, and sanctioning of acts of corruption and the effectiveness of public management control are sought. Annually, the GEB elaborates, executes, and publishes the Anti-Corruption and Citizen Attention Plan in compliance with this law.


In compliance with Law 1581 of 2012, GEB protects the constitutional right that all individuals have to know, update, and rectify the information collected about them in databases or files.

GEB adheres to the provisions stipulated in Law 1778 of 2016, which dictates the rules regarding the liability of legal entities for acts of transnational corruption abroad..

Coordination of timely and adequate response to requests from supervisory and regulatory bodies.

The entire compliance program of the GEB is supported by strong corporate governance, a culture of integrity, policies, procedures, and methodologies, ongoing communication and training, monitoring, and information systems.


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