Ethics, compliance,

and anti-corruption

Developing a corporate culture of ethics is an essential part of our Compliance Model. Integrity and transparency are essential parts of who we are and what we do in the corporate environment and beyond. We realize our objectives in a way that is responsible and creates value for everyone.

All our operations conform to the highest standards of conduct. As a result, during 2020 we had:

• No cases of corruption or bribery

• No reports of breaches of the conduct and ethics code

• No cases related to unfair competition and anti-trust practices, and no penalties regarding actions against free competition.



The Ethics and Compliance System applies to every area and process at Canacol, and its scope encompasses shareholders, directors, administrators, employees, and all third parties involved. The system establishes commitments in business ethics, anti-money laundering and anti-financing of terrorism (AML/ATF). It establishes standards for conduct and controls that expressly prevent and prohibit acts of corruption or transnational bribery that could affect our local or international operations.

• Corporate Governance Code

• Governance Guidelines for the Board of Directors

• General Framework of the Ethics and Compliance System

• Code of Ethics & Business Conduct

• Anti-Corruption Policy

• Whistleblower Policy

• Human Rights Manual

• Workplace Harassment Prevention Policy

• Insider Trading Policy

• Sustainability Policy (HSEQ)

• Comprehensive Social Responsibility Policy

• Disclosure & Confidentiality Policy

• Corporate Governance and Nominating Committee Terms of Reference

• Compensation Committee Terms of Reference

• Audit Committee Terms of Reference

• Reserves Committee Terms of Reference

• ESG Committee Terms of Reference

Reporting mechanisms




for employees, contractors, and other stakeholders to report any

violation of the Business Ethics Manual, corruption, or unusual or suspicious actions:, or

We honed our culture of


Communication and training by job categories, 2020

Our ESG goals


• Annually disclose breaches against the code of conduct and actions taken

By 2021:

• Build the ESG Committee of the Board of Directors to monitor the performance of the company’s sustainability strategy

• Establish an independent reporting hotline that is available 24/7

By 2022:

• Evaluate employee and Board of Directors performance linked to the ESG strategy

• ESG training for 100% of the Board of Directors