Ethics & Compliance Program

At TGN

Our ethics and compliance risk-based program has been designed to prevent, detect, and appropriately respond to any potential violations of (the) law, of our Code of Ethics, or of any other company policies and procedures. In TGN we believe that this commitment to compliance across the entire organization is fundamental to running a successful and sustainable business.

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We keep the highest ethical and professional conduct standards in our activities.

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We are convinced that acting with integrity and transparency guarantees successful relations with our stakeholders.

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The robust ethical culture at TGN depends on the commitment of employees at every level and on strong leadership by senior leaders and management.

Our Ethics & Compliance Program consists of the following key elements:

  • An Ethics & Compliance Office providing compliance advice and customized training, conducting investigations, and improving governance across all regions and countries where TGN does business.
  • A Code of Ethics that provides a foundation on compliant actions and behavior.
  • Internal policies and procedures, guided by the principles in our Code of Ethics, such as:
    • Anti-Corruption policy.
    • Due diligence procedures for intermediaries and consultants, and an enhanced risk-based process for vetting business partners and suppliers.
    • Policy that regulates TGN´s participation in public tenders.
    • Conflict of Interest policy.
    • Gift & Entertainment policy.
    • Policy for expenses (meals, transportation, lodging, etc.) in our interaction with government officials.
    • Donations, sponsorships and memberships policy.
  • Comprehensive employee communication and training program with on-going in-person and computer-based training sessions.
  • Annual compliance risk assessments, which results are used to allocate resources and identify opportunities for continuous improvement of the ethics & compliance program.
  • Open Reporting Environment where employees and third parties are encouraged to report any ethics or compliance matter without fear of retaliation. Reporting can be anonymous, and reporting channels are available 24/7 and are free of charge.
  • Swift investigation of any potential compliance violation that is raised through any means of reporting. Investigations at TGN follow standard procedures to ensure that all reviews are performed properly and fairly, and that the company identifies all actions necessary to prevent future compliance violations.

Our Program Building Blocks

Prevent

Detect

Respond

Our Structure

Since 2018, we have a Compliance Office, autonomous with sufficient resources and direct report to the Audit Committee and the Board of Directors.

Compliance Office
Led by a Compliance Officer appointed by the Company’s Board of Directors.
Compliance Officer
Reports to the Board of Directors through the Audit Committee and, hierarchically, to the CEO.
Board of Directors
Has the power to approve all Policies and Procedures related to the Ethics & Compliance Program.
Director
Encourages that all employees and executives support internal controls and promotes their ethical commitment in the fight against corruption, understanding that these are decisive/determining/key factors.
"Through this program, we reaffirm our commitment to compliance and integrity in all of our actions –every day, everywhere and without exception."