Exportadora Unifrutti Traders y Filiales – Chile Division

Check List
Bribery and Corruption
Risk Assessment

Exportadora Unifrutti Traders SpA.

(Chile Division)

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CONTACT
DETAILS

Cristian Vera
Local Compliance, Risk and Sustainability Officers (LCRSO)
[email protected]

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Checklist for Bribery and Corruption Risk Assessment

With the introduction of various global regulations aimed at preventing corrupt practices, the
assessment of bribery and corruption risk has become particularly important.

Organisations must now take fraud and corruption issues very seriously. The starting point is,
of course, the assessment of the risk of bribery and corruption.

The task seems daunting. However, by making use of the Bribery and Corruption Risk Assessment
Checklist, things can move a little faster.

Bribery and Corruption Risk Assessment - Checklist.

Today's Bribery and Corruption Risk Assessment Checklist is designed to identify effective
compliance with an anti-fraud, anti-bribery and corruption programme. However, it should not be used
as a substitute for an open, honest and ethical culture.

Thus, we propose an agile methodology in which to list the good practices that should be
followed, the check on whether or not they are complied with, and the improvement action
required. For example, following a table such as:

N° Good practices Compliance (Yes/No) Action requested

1 Procedures Yes
2 Commitment of Management Yes
3 Risk assessment Yes
4 Due Diligence Yes
5 Communication and training Yes
6 Monitoring and review Yes

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1 Procedures

The procedures adopted by an organisation to counter the risk of bribery and corruption should be
proportionate to its level of risk. Procedures should include measures already in place to
strengthen governance and accountability and address fraud risks.

In assessing the risk of bribery and corruption, include in your checklist:

Good practices – Procedures Action requested

 The organisation has a formal policy that emphasises zero tolerance We have Internal and
of bribery and corruption. Corporate Policies where the
primary objective is zero
tolerance to this type of events.
 The organisation has a comprehensive set of policies that address We have Internal and
potential bribery and corruption risks, e.g. conflicts of interest, gifts Corporate Policies that address
and anti-fraud policies. potential bribery and corruption
risks.
 The organisation has anti-bribery and corruption procedures in place We have anti-bribery and
commensurate with the risks identified and the size and corruption procedures in place
complexity of the organisation. according to the risks identified
and risk appetite according to
the reality of our division.
 The organisation has clear and effective procedures in place for those The procedures for reporting
wishing to raise concerns about actual or potential bribery or any matters of concern are
corruption. clearly set out in the
Whistleblowing Policy and
Code of Conduct.
 The organisation has procedures in place to create and reinforce The Risk and HR functions are
awareness, in particular with those exposed to a higher risk of bribery responsible for training
and corruption. employees on the provisions of
the Policies and instilling in
them a culture of accountability
and speaking up.
 The organisation has strong controls in place such as separation of We have an adequate
duties and delegated levels of authority. segregation of duties as well as
application controls which are
evaluated by the internal and
external audit area.
 The organisation has strong financial controls in place such as We have Corporate Accounting
transparent accounting records and the requirement for full supporting Policies, we also have a
documentation for all transactions. manual of accounting
accounts, and the balance
sheets of all our subsidiaries
are reviewed on a monthly
basis.
 The organisation seeks to minimise or avoid the use of cash All transactions involving
payments. payments are carried out via
bank transfers with the
appropriate levels of
authorisation and approvals.
 The organisation has strong internal and external audit functions We do not have a formalised
and an effective audit committee. audit committee, but every
Monday the different
management teams meet to
evaluate internal control,
sustainability and other issues.

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 The organisation has effective procedures in place to deal with any We have procedures in place
detected bribery or corruption, e.g. a fraud or bribery response plan. that define guidelines for
dealing with any bribery or
corruption that may be
detected.

As mentioned at the beginning, after reviewing compliance with good practices in policies and
procedures, where it is found that they are not being applied, actions for improvement should be
identified, planned and initiated. Similarly, in the following sections.

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2 Commitment of Management

Those at the top of an organisation are in the best position to ensure that it conducts its business
fairly and honestly. Clear and visible commitment from top management is an essential element of
an ethical culture.

Good practices – Commitment of Management Action requested

 La The organisation is formally committed to integrity and business The Unifrutti Group ("UG") is
ethics. committed to ethical behaviour
and conducts its business
fairly, with integrity and
transparency in all its
geographic locations and
business operations.
 The organisation has a Code of Conduct or similar document that The Group and divisions have
includes a clear statement against bribery and corruption. Codes of Conduct which is a
formal statement of principles
setting out the values and
ethical standards by which UG
is guided.

UG has a "zero tolerance"

approach to acts of bribery and
corruption and any violation of
its bribery and corruption policy
will result in appropriate
disciplinary action.
 The chairman, board and senior management have clearly assigned The Board of Directors (BoD)
responsibility and authority for implementing anti-bribery and and management promote
corruption arrangements. integrity, ethical behaviour,
honesty and accountability in
accordance with the Group's
values. In addition,
management promotes
transparency and
accountability.
 The board or equivalent body considers concerns about fraud and Fraud and irregularities issues
whistleblowing at its meetings. are consistently addressed in
regular meetings at Group and
Divisional level. Management
is committed to ethical
behaviour, sets the tone from
the top and applies a "zero
tolerance" approach to bribery
and corruption.

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3 Risk Assessment
A risk assessment is key to establishing the bribery and corruption risk faced by an organisation. It
will also inform the proportionality of controls introduced to mitigate the risks identified.

Good practice - Risk assessment Action requested

 The Directive or equivalent body oversees the risk assessment Risk assessment is monitored
process. and evaluated from the top
management of both UG and
the Divisions, using the
principle of Tone at the Top for
a clear Group commitment to a
strong compliance culture.
 The risk assessment process includes consideration of the risk of Our risk assessment process
bribery and corruption. considers bribery and
corruption concepts within its
assessments and matrices as
assessment processes for our
control environment.
 The risk assessment is documented and regularly reviewed. The risk assessment is carried
out on an annual basis and
documented in risk matrices
and assessment reports, which
are sent to the general
management.
 The process for identifying bribery and corruption risk ensures that all For the bribery and corruption
key risks are identified. For example, by consulting with staff in all assessment process, we carry
areas of the business, in particular the higher risk areas. out a matrix assessment by
sensitive areas by performing
flow charts and process
walkthroughs to detect
potential risk drivers or triggers.
 Positions at particular risk of bribery and corruption have been They have been identified
identified. according to a matrix
assessment including potential
positions that could be exposed
to bribery and corruption risks.
 Bribery and corruption risk assessment has been used to inform In establishing procedures and
relevant policies and procedures. controls for the management of
bribery and corruption risk, UG
in each geographic location
considered internal and
external sources of potential
risks, local cultures, market
behaviours, regulations, etc., in
order to adopt relevant
proactive measures and
controls to properly assess
bribery and corruption.
 Bribery and corruption risks have been assessed and prioritised so They are assessed on an
that mitigating controls can be appropriately focused. ongoing basis where timely
detection is prioritised,
mitigating controls are
determined considering that
they are within the range of the
risk appetite assumed by our
division.

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4 Due Diligence

The application of due diligence in relation to the risk of bribery and corruption posed by associated
persons should be proportionate and risk-based. Due diligence can be applied to both external
partners and internal staff members.

Good practice – Due Diligence Action requested

Due Diligence – Third parties

 Risk-based due diligence is conducted on contractors, suppliers and Unifrutti shall carry out an
other partners prior to appointment and periodically thereafter. identification and analysis of all
its Business Partners, Major
Clients, Suppliers and third
parties with which it has
business relations in terms of
corruption, fraud, international
trade sanctions or similar risks
(Due Diligence).
 Contractors, suppliers and other partners are aware of the We have a Supplier Behaviour
organisation's ethical stance on bribery and corruption and are Guide" aims to disseminate the
expected to act accordingly. basic ethical principles to which
the company adheres and
which it therefore requires its
suppliers to comply with in
carrying out their activities. The
Guide aims to disseminate in a
simple way the good practices
that allow to approach the
fulfilment of each of the ethical
principles and also to exemplify
some bad practices that should
not be carried out.

 There are procedures in place for the application of sanctions to third There are written procedures
party partners when incidents of bribery or corruption occur. mentioned in Corporate
Policies (Anti-fraud and Anti-
bribery Policy) and in the case
of our division there is the anti-
corruption law N°21.121, which
improves the legal framework
of bribery and bribery, whose
objective is to strengthen the
typification of certain conducts
and raise the penalties for the
main official crimes:
embezzlement, tax fraud,
incompatible negotiation,
bribery and bribery.
Due Diligence – Employees
 The organisation's procurement process includes procedures to There are external and internal
ensure that it is fair, transparent and free from bribery and corruption. Corporate Policies in our
organisation which define the
guidelines to mitigate

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concentration and high

dependency risk.
 The organisation conducts due diligence when recruiting Our Division recruits key
management and employees, particularly for positions with a higher employees according to
risk of bribery and corruption or positions of trust. protocols defined by the human
resources area reflecting the
Unifrutti Group's commitment
to these policies.
 Managerial employees must subscribe to a Code of Conduct when The code of conduct will be
they join the organisation. updated to include the
principles of the corporate
policies and is therefore part of
the on-boarding procedures for
new employees. All policies are
communicated to new
shareholders, new members of
the Board of Directors or
members of new committees
that may be appointed from
time to time.
 Employees and members of senior management receive training on Group and divisional chief
bribery and awareness of corruption and the fight to prevent it. executive officers (CEOs) are
responsible for ensuring that all
group employees,
management and key
stakeholders are aware of the
principles of these policies and
that they are properly
understood.

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5 Communication and Training

Communication promotes awareness and understanding of the organisation's policies and

procedures in relation to bribery and corruption and deters acts of bribery or corruption by internal
or external persons or associated agents. Training can range from risk awareness with new
employees to specialised training for those in key positions.

Good practice – Communication and Training Action requested

Internal communication
 The organisation has a clear anti-bribery and corruption policy and Management shall ensure that
procedures that are communicated in an accessible manner to all policy principles are adequately
employees. communicated to all Group
employees and key internal
and external stakeholders.
 The organisation provides a safe, confidential and accessible means Confidential information
by which employees can raise concerns or seek advice in relation to channels are established
bribery and corruption risk, without fear of reprisal. through:
 E-mail
 Certified mail
 Orally

The whistleblower should

submit his or her report through
any of the above-mentioned
communication channels. If the
report is oral (at the request of
the whistleblower), a record of
the conversation must be
drawn up and signed by both
the whistleblower and the
investigation team, or the
conversation may be recorded.

The whistleblower is protected

against actual or threatened
retaliation, threats or attempts
of retaliation, dismissal,
negative impact on promotion
or salary, unfair or unjustified
performance evaluation,
change of workplace without
consent, harassment,
discrimination or as stated in
the EU directive or national
legislation. Local management
has the ultimate responsibility
to ensure that adequate
controls and procedures are in
place to achieve this and to
show no tolerance for
retaliation and similar
behaviour.
External communication
 The organisation's anti-bribery and corruption stance is clearly stated This is communicated to all our
and communicated to all external partners (e.g. through a policy external partners through
statement and/or code of conduct on the organisation's website). through the document
"Supplier Behaviour Guide",

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where we invite them to commit

themselves to the maximum
with the ethical values of the
company, which are at the
same time requirements
demanded by our customers,
increasingly aware of the
growing need for respect for
human rights, the environment
and society in general.

The present "Supplier

Behaviour Guide" aims to
disseminate the elementary
ethical principles to which the
company adheres and which it
therefore requires its suppliers
to comply with in carrying out
their activities. The Guide aims
to disseminate in a simple way
the good practices that allow to
approach the compliance with
each of the ethical principles
and, also, to exemplify some
bad practices that should not
be carried out.
 Every opportunity is taken in external communications to emphasise It is constantly working to
the organisation's commitment to fairness, openness and reinforce its commitment to the
honesty as a deterrent to inappropriate behaviour. values of ethical behaviour that
it must conduct business fairly,
with integrity and ethical
behaviour to conduct business
fairly, with integrity and
transparency in all its
geographic locations and
business operations,
emphasising a commitment to
speak out without fear of
retaliation.
Training
 Bribery and corruption awareness training is provided to all staff. Training and awareness of
This training includes how to raise concerns about risks or how to seek Corporate Policies is provided
advice. at all levels of our organisation,
emphasising guidelines for
ethical behaviour and how we
conduct business fairly and
with integrity in all of our
geographic locations. In this
context, our employees and
managers are expected to
conduct their activities with the
highest level of integrity and
are encouraged to bring to
UG's attention any suspicions
about issues involving
compromise, violation of ethical
standards, misconduct, non-
compliance, etc.
 Those employees at higher risk of bribery and corruption (e.g. those For procurement policies
working in procurement functions) receive more detailed and where they are most exposed
tailored anti-bribery and corruption training. to potential risks of bribery and
corruption, there is a lot of

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training and periodic reviews of

procurement records and
related backups..
 Training is provided to staff who may receive reports of concerns Training or clarification is
so that they have the confidence to deal appropriately with the provided when there are
concerns raised. doubts about the application of
policies or other types of
concerns that may arise,
always under the concept of
speaking without fear.

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6 Follow –up and Review

An organisation's bribery and corruption risks may change over time, for example if it takes on new
functions.

A regular assessment of bribery and corruption risk is necessary to ensure that the compliance
programme remains fit for purpose.

Good practice - Monitoring and review Action requested

 Internal financial control systems are subject to regular reviews and All systems including financial
audits to ensure that they remain effective in combating the risk of control are subject to internal
bribery and corruption. and external audits on a period-
by-period basis to ensure that
controls are effective or that
more effective controls need to
be redefined if necessary.
 There is a regular review of high-risk transactions, e.g. large-scale All high-risk transactions are
acquisitions or major planning decisions, to ensure compliance with reviewed on an ongoing basis
procedures and controls. to ensure that our employees
and corporate governance are
in full compliance with
procedures, policies,
instructions and others for an
adequate planning and control
environment.
 There is a regular review of the number of fraud and High-risk transactions that
whistleblowing cases within the organisation, to determine whether require a more in-depth look
cases highlight any new bribery and corruption risks and analysis are raised when
warranted, and when reports of
irregularities are detected
through formal communication
channels, they are analysed
and reviewed with the source
documentation to see the
degree of materiality and
impact, if positive.
 A periodic review of the register of interests is conducted to We carried out a division-wide
determine whether any new conflicts of interest may have arisen that survey of potential conflicts of
could leave an employee more susceptible to the risk of bribery and interest that may arise in
corruption. accordance with corporate
policy, and we have a record of
potential COI as indicated in
Appendix C of the current
Policy..
 Employees, particularly those in high-risk functions, should regularly Procedures were established
confirm that they comply with anti-bribery and corruption agreements. that can be used by employees
and other stakeholders to
report directly or through the
hotline any suspicion of such
risks.

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 The results of the review activities are incorporated into reviews This is done on an annual basis
of systems controls and the strengthening of controls where by teams of external auditors
necessary. (PwC) where we are mentioned
in internal control letter the
weaknesses detected in
systems audits, when there is a
need to correct our division is
always ready to the best control
environment to ensure
traceability and transparency in
all processes.

7 Summary

As part of the ongoing commitment to best practices in corporate governance and risk management,
fraud prevention policies are established in order to promote the development of coordinated actions
to prevent and detect potential fraud, both internal and external, deter misconduct and encourage the
commitment of all employees and stakeholders to ethical and transparent conduct.

Taking into account the current regulatory context, which is clearly in a phase of growth and whose
most accentuated characteristic is dynamism, it is of vital importance to have a complete and effective
compliance model that allows organisations to identify and manage the main regulatory risks to which
they are exposed due to their activity, geographic location, etc.

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Realised by:
Cristian Vera M.
Exportadora Unifrutti Traders SpA. (Chile)

Reviewed by:
XXXXXXXXXXXX
Exportadora Unifrutti Traders SpA. (Chile)

Versión N°1
June 2022

Winter 2022
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