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FR-TC-003 Revised: CC See 01

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REFERENCE TO THE HELPLINE Approved: GG 10/05/2021

Detailed Requirements of the Tests to be Submitted

Evidence Presented Evidence requirements State

1) S&H Ingenieros' The program covers the principles of the compliance
compliance program, code:
as well as policies in - Integrity
relation to each
- Conflicts of interest
principle (if separate).
- Confidentiality and Data Protection

- Anti-bribery

- Fair business conduct

- Fair labor

- Health and Safety

The program and policies are in line with the details

provided in the 'Application of Compliance Principles'
in the Compliance Code guidelines.

The program includes:

Accordin
-Reference to the helpline. g to

-Provisions for the protection of confidentiality for

reporting violations.

-A provision where employees may report known or

suspected violations to the Compliance Officer, the
employee's superior, a member of senior management
or an internal auditor.

-Requirement for employees to report any solicitation

or offer of an improper payment or advantage that
comes to their attention.

-It is always clear that employees will not suffer

demotion, penalty or any other adverse consequence
arising from strict implementation of the Program, even
if it may result in a loss of business.
2) The Terms of The Terms of Reference specify that the Committee is Accordin
g to
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REFERENCE TO THE HELPLINE Approved: GG 10/05/2021

Reference for the responsible for overseeing the Compliance Program.

Compliance Committee The Terms of Reference specify the frequency of
(or equivalent), Compliance Committee meetings. The Compliance
including the Committee meets regularly (at least once a year).
specification that the
Compliance Committee
(or equivalent) is
responsible for
overseeing the
Compliance Program.
3) List of members of the There are at least 3 members on the Compliance
Compliance Committee Committee.
(including position). Committee members include:

-Compliance Officer
Accordin
g to
-CEO

-Legal Representative (S&H Ingenieros does not have

a legal function).

-Human Resources Representative.

4) Compliance Program The material includes sections on:
Training Course - Integrity
Material
- Conflicts of interest

- Confidentiality and Data Protection

Accordin
g to
- Anti-bribery

- Fair business conduct

- Fair labor

- Health and Safety

5) Material to help you The material explains: Accordin
g to
learn about the -The employee may obtain guidance on any questions

Employee Helpline (or or issues of concern related to the implementation or

equivalent, e.g., interpretation of the Compliance Program.

designated e-mail). -At the employee's request, any such questions should
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REFERENCE TO THE HELPLINE Approved: GG 10/05/2021

be treated confidentially and the employee's anonymity

should be protected to the extent reasonably possible.
6) Material that The material explains that:

encourages employees -The employee is fully protected against any form of

to report details of retaliation unless he/she has acted maliciously or in

bad faith. Accordin
violations or suspected
g to
violations and to whom -The employee is required to report any solicitation or
they can report them. offer of an improper payment or advantage that comes
to his or her attention.
7) Silkscreen from S&H
Ingenieros website
where:

- The principles of
compliance are
N/A N/A
explained.

- An interested party may

make inquiries,
complaints or
comments.
8) Documented procedure The procedures include requirements for: Accordin
g to
for handling (a) maintaining records of all reported violations and
investigations and subsequent actions taken;
sanctions.
(b) the alleged perpetrator of such violation has the
right to be heard;

(c) the management of S&H Engineers or the

Compliance Committee to decide on the appropriate
corrective and disciplinary measures to be
implemented if a violation has been established.
These measures may include reprimand, demotion,
suspension or dismissal; and

(d) the Compliance Officer shall receive progress

reports from his or her nominated delegates and/or
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REFERENCE TO THE HELPLINE Approved: GG 10/05/2021

management at the locations concerned and shall

prepare periodic summary reports to the Compliance
Committee on investigations, established violations
and the implementation of corrective actions and
disciplinary measures.
9) Policies related to The policy covers the need for the company to
confidential business implement appropriate security measures to ensure
information (information that access is restricted to authorized personnel only Accordin
g to
security policy, and that documents/data are stored in designated
confidentiality policy). secure areas and disposed of in a secure manner.

10) Procedures for The procedures must:

health and safety -define what a health and safety incident is.
incident reports and
-explain how the employee can report health and
investigations.
safety incidents. Accordin
g to
-encourage employees to report health and safety
incidents.

-explain how health and safety incidents will be

investigated and corrective actions will be determined.
11) Due diligence For intermediaries, joint venture partners and
procedures for initiating franchisees, S&H Engineers is required to have a
or renewing written procedure in terms of the due diligence steps
relationships with they require to perform and what approval is required N/A
intermediaries, joint to initiate or renew the intermediary, joint venture
venture partners and partner or franchisee.
franchisees.
12) Procedure for The contract / terms of business include: N/A
contracting with -A requirement that the business partner comply with
intermediaries, joint the compliance program.
venture partners and
-A provision that allows S&H Ingenieros to verify the
franchisees and related
Business Partner's compliance with the Compliance
contract/terms and
Program.
conditions templates
For the Intermediary, Joint Venture Partner and
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REFERENCE TO THE HELPLINE Approved: GG 10/05/2021

with an intermediary, Franchisee, S&H Engineers has written procedures in

joint venture partner or terms of the contracts / terms of business that are
new/renewed established to cover the recognition of compliance with
franchisee. the Member's compliance program by the
Intermediary, Joint Venture Partner or Franchisee.

Where S&H Ingenieros does not have a standard

template, S&H Ingenieros will present examples of
contracts included above.
13) Template of the The compliance statement includes the attributes in
annual management Annex A, including the locations and/or activities
Accordin
statement based on the covered by the statement, as well as the statement of g to
template in Annex A. implementation of the Compliance Program.

14) Scope of the The scope of the internal audit plan covers the S&H
Internal Audit plan that Ingenieros organization.
includes the review of Accordin
the implementation of g to

the Code of
Compliance.
15) Annual summary Annually (in line with the end of the financial year), Accordin
g to
reports prepared by the S&H Ingenieros prepares an annual summary report
Compliance Officer detailing:
covering statistics or 1) Violations:
confirmations to show
-Number of infractions / alleged infractions reported.
compliance with the
-Number of verified violations.
procedures and policies
-Confirmation that corrective actions have been
and policies of
identified and actions taken/undertaken for each
Members, as specified
violation/non-compliance found.
in Annex B.
(The above statistics are necessary to cover
violations / suspected violations reported through the
helpline and also during internal audits).

2) For new or renewed intermediaries, joint venture

partners and franchisees:
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REFERENCE TO THE HELPLINE Approved: GG 10/05/2021

-Number of new or renewed intermediaries, joint

venture partners and franchisees in the year.

-Confirmation that each has gone through the

member's due diligence procedures, as required.

-Confirmation that a contract / appropriate commercial

terms have been established with each.

3) Confirmation that expenditures are in line with the

Member's Compliance Program and related policies
for:

-Political contributions

-Charitable contributions and sponsorships.

-Expenses related to gifts, hospitality and expenses.

-Remuneration of intermediaries.

4) Health and safety:

-Number of health and safety incidents reported

-Confirmation that corrective actions have been

determined and actions taken/undertaken for each
incident.
16) Annual report on
the results of the N/A N/A
agreed procedures.