Policies

C.I. Banasan S.A.S. is an International Export Type Banana Marketing Company, which meets the requirements of its customers through the development of a culture of service and continuous improvement, committed to the compliance with legal requirements and others applicable to its activity and the implementation of controls aimed at preventing the materialization of the risks associated with its management, thereby achieving the protection of the integrity of its processes, people and goods. To achieve this it relies on a highly competent and reliable team of people committed to the quality of their work.

C.I. BANASAN S.A.S. is committed to the protection and promotion of the safety and health of its employees, seeking their physical and mental integrity through the identification, evaluation and control of risks, the continuous improvement of the processes and the protection of the environment. It is the responsibility of all the levels of management to promote a culture of self-care, safety and health at work, complying with the applicable legal requirements and allocating the human, physical and financial resources necessary for this management. Likewise, all workers, contractors, subcontractors, temporary workers and visitors are committed to the integral care of their health and to the fulfillment of the existing rules, regulations and instructions defined in the matter of safety and occupational health.

C.I. Banasan S.A.S. is an International Export Type Banana Marketing Company, committed to the implementation of strategies, activities and programs focused on risk control and prevention of traffic accidents, aimed at protecting the physical, mental and social integrity of the employees, the community and the environment. It also ensures compliance with the existing rules, traffic regulations and others applicable to the organization and to continuously improve the standards defined in the strategic road safety plan.

PRIVACY NOTICE

In compliance with the provisions of Law 1581 of 2012 and the provisions of Decree 1377 of 2013, in order to inform all persons whose personal data are in our databases, and taking into account the impossibility of requesting authorization individually, C.I. BANASAN SA.S. reports that it makes use of the alternative mechanism established in the regulations and states that the personal data included in its databases have been collected for the development of various procedures directly related to its corporate purpose.

The use and handling of these data is carried out under strict standards of responsibility, including respect for due process and the protection of information.

Responsible for the treatment

Company Name: C.I. Banasan S.A.S.
NIT: 900.031.088-5
Domicile: Santa Marta D.T.C.H.
Address: Km 5 via Gaira. Troncal del Caribe
Tel: (5) 4351830 ext 611
Email: servicioalcliente@banasan.com.co

Treatment and purpose
 

• For BANASAN to comply with each and every one of the obligations and to exercise the rights arising from the activities of its main and related corporate purpose, which may be provided directly or with the support of third parties with whom my personal information will be shared, such as Data Credit, Credit Bureaus or third parties that require my personal data for purposes related to the contracted purpose.
   
• For marketing activities and/or promotion of other services related to BANASAN's corporate purpose or those of third parties with whom BANASAN has established commercial relationships.
   
• So that for purposes of the corporate purpose of the Authorized Entities, statistical, commercial and risk control purposes, they may consult and/or report to financial and credit information databases, such as CIFIN and DATACRÉDITO; it is empowered to report the birth, development, modification, extinction and fulfillment of obligations contracted or to be contracted, the existence of unpaid debts or the improper use of the contracted services.
   
• To share my personal data with national and/or foreign authorities when the request is based on legal or procedural reasons, for my own convenience or to collaborate with foreign governments that require the information, based on legitimate causes such as legal or tax issues.
   
• I authorize my personal data to be made available on the Internet or other means of mass disclosure or communication to me and to authorized third parties and only when access is technically controllable.

Holder's rights
 

• To know, update and rectify their personal data against C.I. Banasan S.A.S. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose treatment is expressly prohibited or has not been authorized.
   
• Request proof of the authorization granted to C.I. Banasan S.A.S., except when expressly exempted as a requirement for the processing of data in accordance with the law such as: a) Information required by a public or administrative entity in the exercise of its legal functions or by court order. b) Data of a public nature. c) Cases of medical or health emergency. d) Processing of information authorized by law for historical, statistical or scientific purposes. e) Data related to the Civil Registry of Persons.
   
• Be informed by C.I. Banasan S.A.S., upon request, regarding the use it has made of your personal data.
   
• File complaints before the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other rules that modify, add or complement it, once the consultation process or requirement before C.I. Banasan S.A.S. has been exhausted.
   
• To revoke the authorization and/or request the deletion of the data when the treatment does not respect the principles, rights and constitutional and legal guarantees. The revocation and/or deletion will proceed when the Competent Authority has determined that in the Treatment C.I. Banasan S.A.S., has incurred in conduct contrary to Law 1581 of 2012 and the Constitution. The revocation will proceed as long as there is no legal or contractual obligation to keep the personal data.

Mechanisms to learn about data protection policy

We invite you to know the Personal Data Protection Policy of THE COMPANY, which includes the procedures for the holders of Personal Data to exercise their rights to know, update, rectify and delete the information and revoke the authorization, and is available for consultation on the website www.banasan.com.co.

DE-PGE-11 Personal data protection manual

Procedures for the exercise of the rights of holders of personal data

If you wish to make consultations, correction, update or deletion, or notice a breach by this, submit a request to C.I. Banasan S.A.S. through the Customer Service area, in the following terms:

Inquiries

The query is made by email, telephone or in person to the Customer Service area of C.I. Banasan S.A.S. (Data indicated in the field of the Data Controller". The consultation is answered in a maximum term of ten (10) working days from the date of receipt of the same.

Request for correction, updating or deletion of personal data - claims

This is done through the format "FE-PGE-04 Requirements for the treatment of personal data", which is filled out, signed and sent to the Customer Service area, either physically or by e-mail.

• If it is a request from the holder, only a copy of his/her identity document is required.
   
• If it is a request from a successor in title, a copy of the civil registry and the corresponding copy of the holder's death record must be attached, in order to be able to infer the interest and the relationship with the holder.
   
• If the applicant is not the titleholder, and has the quality of representative or attorney-in-fact or other, he/she must submit an authenticated document proving his/her condition and a photocopy of the document of the titleholder or assignee granting power of attorney or mandate.

FE-PGE-08 Requirements for the processing of personal data

The maximum term to comply with the requirement is fifteen (15) business days from the day following the date of receipt.

LA/FT/FPADM Policy

As a sign of our commitment to self-control and management of the integral risk of money laundering, financing of terrorism and financing of the proliferation of weapons of mass destruction, we have defined the following rules and policies, which are aimed at rigorously complying with the ethical, commercial and legal obligations and duties in force:

• Knowledge of and compliance with the policy: The ML/FT Risk Management System-PADM is deployed to all processes of the organization and is known by all C.I. BANASAN S.A.S. employees.
   
• Compliance with manuals and procedures: All employees and managers of the organization must know and fully apply the SAGRILAFT/SIPLAFT- FPADM Manual in order to contribute to the prevention of ML/FT/ FPADM and its underlying crimes. Likewise, they must immediately report to the Compliance Officer, the facts or circumstances that they consider to be in violation of an adequate ML/FT/ATF/ATF-MFTPD Risk Management.
   
• Compliance with standards: All employees directly or indirectly involved in the company's operations are obliged to ensure compliance with legal regulations aimed at preventing and controlling money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction.
   
• Preventive attitude: The employees of C.I. BANASAN S.A.S. must apply in all their actions their knowledge, experience and good judgment, especially in the prevention and detection of money laundering, financing of terrorism, proliferation of weapons of mass destruction and channeling of resources from such activities.
   
• Knowledge of Counterparties: C.I. BANASAN S.A.S. establishes the following guidelines:

1. Any relationship with third parties must be duly supported with documents that endorse the commercial transaction, being the maximum amount allowed to receive in cash at the facilities $5,000,000.
    
2. No operations or contracts will be established with counterparties that refuse to provide the required information or submit false or difficult to verify information. Nor with counterparties that appear in the restrictive and control lists established by the company, such as OFAC, UN and Interpol.
    
3. It is the policy of BANASAN S.A.S. to establish mechanisms to know the identity of customers, suppliers and other counterparties of the company, to determine the type of activity they develop and the origin of their resources, as well as to follow up on their operations, frequency and amounts, to have elements of judgment to analyze transactions that become unusual and determine the existence of suspicious transactions.
    
4. The Compliance Officer must apply the due diligence and enhanced due diligence procedures, in accordance with the regulations in force.
    

• Market knowledge: C.I. BANASAN S.A.S. must have a thorough knowledge of the particular characteristics of the economic activities of its counterparties, as well as of the operations they carry out in the different markets. The knowledge of the market should allow the company to clearly establish the usual characteristics of the economic agents that participate in it and the transactions they carry out.

Unusual operations of the counterparties shall be considered as those that may be outside the market in which the company operates.
 

• Knowledge of Politically Exposed Persons (PEPs): The Shareholders' Meeting is the body that authorizes the establishment of business relationships with Politically or Publicly Exposed Persons (PEPs).

The Compliance Officer must carry out a more demanding follow-up of third parties, natural and/or legal persons who, due to their profile or the functions they perform, may expose the entity to a greater degree to the ML/TF/DDAF risk, including persons who, by reason of their position, handle public resources, exercise some degree of public power or enjoy political recognition (PEPs). The foregoing, according to the definitions of PEPs established in the regulations in force.
 

• Training and outreach: In order to promote a culture of prevention, it is established that this policy as well as the manuals and procedures focused on the prevention and control of ML/FT-PADM risk must be communicated and disclosed to all employees and different stakeholders of the organization, as appropriate, through different means, leaving a record with the respective support.
  
   
• Conflict of interest: It is mandatory that the guidelines established in the DE-PGE-30 Code of Ethics and Conduct of C.I. BANASAN S.A.S. are followed.  

Transparency and Business Ethics Program - PTEE

In accordance with the commitment and responsibility that C.I. Banasan S.A.S. has as a legal entity with society in general and its customers, as well as to prevent crime within the organization, the Transparency and Business Ethics Program is adopted, in order to implement transparent and ethical conduct in all activities and processes of the organization:
 

• C.I. Banasan S.A.S. is committed to the management and control of the risks of Corruption and Transnational Bribery.
   
• C.I. Banasan S.A.S.'s position is zero tolerance for fraud, bribery and corruption.
   
• C.I. Banasan S.A.S. rejects all criminal conduct that may be committed by its members and collaborators, and therefore, implements these policies to prevent the aforementioned illicit activities from being committed.
   
• C.I. Banasan S.A.S. promotes and establishes within the entire organization, an institutional anti-fraud, anti-bribery and anti-corruption culture.
   
• The use of Company funds, assets or personnel for any illegal, improper or unethical purpose is strictly prohibited.
   
• C.I. Banasan S.A.S. prohibits demanding, soliciting, agreeing to receive, or accepting a bribe, kickback, influence payment, or any undue or illegal inducement, benefit or advantage.
   
• Remuneration and payment of commissions to employees, associates and contractors is prohibited.
   
• Out of loyalty to the Company, every person must communicate in a timely manner to his or her immediate superiors any fact or irregularity committed by another employee or a third party that affects or may harm the interests of C.I. Banasan S.A.S., its customers, shareholders and directors. If the employee prefers to keep his or her identification confidential in order to report such an event, he or she may do so in accordance with the provisions of paragraph 10 of this program.
   
• No direct or indirect political contribution may be made on behalf of or with funds of C.I. Banasan S.A.S., unless authorized by the Executive President, provided that it does not exceed 200 SMLMV, in which case it shall be approved by the General Shareholders' Meeting.