Code of Conduct
INTRODUCTION
FLUVIP (hereinafter, “FLUVIP” or the “Company”) is a leading Influencer Marketing company that is part of a business group with a presence in Latin America and the Hispanic market of the United States. The group was founded in Colombia in 2013 and, thanks to its technology, has grown exponentially throughout the region. Today it has its own offices in Miami, Mexico, Colombia, Peru, Spain, and Argentina.
Integrity and honesty have always been the pillars on which our Company was built. Both pillars are part of our corporate culture and unite us across all our divisions, departments, and regions around the world.
FLUVIP’s success depends on the Company’s reputation at both the local and global levels. Each of our employees must strive to conduct our business with integrity and honesty. Our future success depends on the trust placed in us by the environment in which we operate.
We are aware that the vast majority of our employees, shareholders, and influencers conduct themselves ethically and in compliance with laws and regulations. This Code of Conduct is simply a reaffirmation of our daily work and of our commitment to our principles and values. This Code of Conduct establishes clear ethical standards so that our employees, shareholders, and influencers have the necessary guidance in carrying out daily activities and making decisions.
This Code of Conduct is mandatory for all FLUVIP employees, shareholders, and influencers.
Each individual is responsible for reading and understanding this Code of Conduct, as well as all laws and regulations related to the Company’s activities. Failure to comply may result in sanctions, including termination of employment and/or contractual relationships.
This Code of Conduct is not intended to replace laws, regulations, or governmental and/or regulatory authority guidelines. In the event of any conflict between this Code of Conduct and local laws or obligations, local laws and regulations shall prevail.
INTEGRITY
Compliance with Laws and Government Regulations
All employees, shareholders, and influencers are required to fully comply with all applicable laws and any government regulations related to FLUVIP’s activities.
In cases where Company policies differ from the law or local custom, the more restrictive policy shall apply.
If any employee, shareholder, or influencer becomes aware of or suspects a violation by an employee or by the Company of any law or government regulation, they must immediately report it to their supervisor or to FLUVIP’s designated contact person.
Corruption and Bribery
Employees, shareholders, and influencers must comply with the applicable legal provisions for the prevention and fight against corruption.
Under no circumstances may employees, shareholders, or influencers engage in any action involving the payment, offer, or promise, directly or indirectly, to any public official (whether municipal, state, or federal) that is not based on a legitimate and legal obligation.
Gifts to public officials will only be permitted if they are a common and ethical business practice, provided that they are not made with the purpose of inducing that official to use their influence before the government and/or any body, company, political party, or public authority in order to influence a future decision or obtain business advantages.
If any employee, shareholder, or influencer becomes aware of any information that may indicate the existence of any action, payment, offer, or promise, directly or indirectly, to any public official for the purposes described above, they must immediately report it to their supervisor or to FLUVIP’s designated contact person.
FRAUD
Fraud may be defined as any intentional act or practice designed to obtain an unlawful economic benefit by means of deception or by taking advantage of another, or to cause financial harm to a person even if no profit is obtained for oneself or a third party.
FLUVIP aims to detect, prevent, and investigate fraud; therefore, internal controls designed to detect, prevent, and respond to cases of fraud shall be implemented.
Employees, shareholders, influencers, and especially senior management of FLUVIP, must remain alert to possible fraudulent activities within the Company, particularly in those activities related to their specific responsibilities.
If any employee, shareholder, or influencer becomes aware of any information that may indicate the existence of fraud, they must immediately report it to their supervisor or to FLUVIP’s designated contact person.
WORKPLACE
FLUVIP is committed to its occupational health and safety policies and to promoting the physical and psychological well-being of its employees.
PHYSICAL WELL-BEING
The workplace provided by FLUVIP must be safe and hygienic. Employees must be aware of safety and health rules and apply them at all times, cooperating to maintain an environment free from contamination. Safety risks and incidents must be reported and addressed immediately.
FLUVIP prohibits employees and third parties not associated with the Company from entering Company facilities while carrying illegal drugs, weapons, or other devices and tools that could endanger the health and safety of employees.
Employees are prohibited from working under the influence of illegal drugs, alcohol, or other substances that have not been medically prescribed. Alcohol consumption will only be permitted at events where its nature involves such consumption, and only at acceptable levels.
PSYCHOLOGICAL WELL-BEING
All relationships among employees, shareholders, and influencers must be based on mutual respect, which is a fundamental pillar of workplace relationships. Therefore, a work environment of trust, respect, and free from harassment (verbal, physical, psychological, etc.) must be promoted.
Likewise, the work environment must be diverse and inclusive, and free from any form of discrimination. In this regard, the Company condemns and discourages actions and/or behaviors that ridicule, intimidate, threaten, degrade, and/or harm any person and/or the work environment.
If any employee becomes aware of any discriminatory, degrading, harassing, or intimidating act, they must immediately report it to their supervisor.
INFORMATION
Confidentiality
All information, whether business-related or related to clients or employees, must be treated as confidential unless its disclosure is authorized by FLUVIP or is required by law, decree, resolution, regulation, or an order issued by a competent court or governmental or administrative authority.
FLUVIP implements and maintains appropriate measures to prevent the disclosure and/or unauthorized use of the Company’s confidential information and/or that of its clients, suppliers, and employees.
Employees have been instructed to take special precautions when transmitting information via email, fax, Internet, or other means, and they are prohibited from duplicating or copying transmitted material unless strictly necessary.
Personal Data
FLUVIP protects the personal data of its clients, suppliers, and employees and uses such data solely for legitimate and authorized business purposes. Employees, and especially FLUVIP’s senior management, must clearly understand when and how to collect, use, or share personal data, and in all cases must adopt appropriate security measures to protect such data.
Conflict of Interest
It is FLUVIP’s policy to avoid conflicts of interest that may arise between its employees and/or executives and the Company. Decisions made by employees or executives regarding FLUVIP’s business transactions must not be influenced by their personal or private interests.
Resources and Assets
Company employees are responsible for the proper use and care of the resources that FLUVIP makes available for their work. Safeguarding IT resources is essential, as the Company relies on technology to carry out its daily operations.
The use of Company resources and assets for personal purposes is prohibited, including but not limited to office equipment, desktop and laptop computers, software, landline and mobile telephony, Internet access and email, postal mail, and printing, copying, and photocopying equipment.
For these reasons, removing any Company asset or resource for personal use without the express authorization of a supervisor is prohibited.
ACCOUNTING AND AUDITS
Accounting
FLUVIP prepares its financial statements and maintains its accounting records in accordance with generally accepted accounting principles and the regulations of the country in which it operates.
Company employees whose specific duties include access to or handling of accounting information must ensure the truthfulness, accuracy, and authenticity of the information contained in the accounting records, as these records are fundamental to decision-making.
If any employee, shareholder, or influencer becomes aware of any information that may indicate violations of any law or policy in relation to the Company’s accounting records or operations, they must immediately report it to their supervisor or to FLUVIP’s designated contact person.
Audit
In some cases, FLUVIP may be subject to internal or external accounting audits; therefore, employees are required to fully cooperate with all requests for information.
Employees are prohibited from attempting to influence, deceive, interfere with, manipulate, or provide inaccurate information in response to an audit or for the purpose of altering its results.