Integrity & Compliance

GRUPO CLM values transparency, ethics and integrity in its

business relationships and in its organizational culture

Integrity & Compliance

GRUPO CLM values transparency, ethics and integrity in business relations and in its organizational culture. These values are the basis of GRUPO CLM’s Code of Ethics and Conduct, as well as all the internal rules and policies that make up our Compliance Program.

Ethics and Integrity are part of the routine at GRUPO CLM, which encourages and stimulates its employees, channels, resellers and suppliers to act within a suitable standard of behavior, respecting current legislation, fighting corruption and unfair competition.

In keeping with these values, in 2021 GRUPO CLM updated its Compliance Program, based on the Anti-Corruption Law (Law 12.846/2013) and other applicable legislation, with the aim of further raising the ethical, moral and legal standards that guide all its activities, strengthening internal controls and the ability to manage risks.

CLM complies with various anti-corruption laws around the world, including Brazilian (Law 12.846/13), American (FCPA – Foreign Corrupt Practices Act), European (, UK (UK Bribery Act), Colombian (Law 1474/2011), Chilean (Law 20.393/2009) and Peruvian (Law 30424/2018). We stress the importance of organizations not only combating illicit practices, but also acting preventively, whether through the implementation of compliance policies or internal controls.

We have appropriate procedures in place to prevent such acts from occurring. These include:

1. Procedures for preventing corruption in proportion to the risks to which the company is exposed.

2. Senior management commitment to preventing these practices by people linked to the organization, and fostering an organizational culture that cultivates these values.

3. Assessment of internal and external risks in order to promote their mitigation.

4. Carrying out audits, including on third parties (service providers on behalf of the company).

5. Widespread dissemination of corruption prevention policies and training.

6. Monitoring and reviewing the processes adopted to prevent illegal acts.

Our commitment to ethics and integrity is a priority, and we are constantly improving our anti-corruption mechanisms to ensure compliance with the laws in force in all the jurisdictions in which we operate.

CLM also operates in compliance with the LGPD (General Data Protection Act) in Brazil and the GDPR (General Data Protection Regulation) in the European Union. Our company is committed to ensuring the protection and proper use of personal data, following the guidelines established by these legislations.

CERTIGOV Certification

Improving its integrity program, 𝐂𝐋𝐌, after winning the Um Empresa Ética certificate, has now been awarded the 𝐂𝐄𝐑𝐓𝐈𝐆𝐎𝐕 certificate.

CertiGov is a seal that certifies a company’s ethical processes and is designed for organizations that participate in public tenders, providing increased security and reduced risks in transactions. CLM obtained the CertiGov seal because it operates in the public sector and has anti-bribery and anti-corruption policies.

CertiGov is an important achievement not only for CLM, but also for all its suppliers, channels, clients, the government and the business ecosystem. With this seal we promote maximum security for our chain of operations and anticipate the growing demand for compliance practices from suppliers!

Reporting Channel

If you identify or suspect any misconduct or violation of CLM’s policies, you have the option of SENDING AN EMAIL TO or accessing (anonymously or not) the link: : Reporting Channel

Please note that any information will be received by a specialized professional, who will forward the analysis for investigation. There is no need to identify the whistleblower and you can follow the progress of the complaint using the protocol number you receive after submitting the complaint.

How are complaints received at CLM handled?