Policies
Legal Notice
Visitors to the web portal of CONEXRED S.A.S., the commercial company that owns the PUNTORED brand, should read the terms and conditions described below. By accessing this portal and any web page of CONEXRED S.A.S. you agree to comply with them. If you do not agree with the following terms and conditions do not access these portals.
The information contained in this website, including text, graphics, links or other elements, does not provide any warranty as to the accuracy, adequacy or completeness of the information expressed. CONEXRED S.A.S. is not responsible for any errors or omissions in this information. CONEXRED S.A.S. makes no warranty, whether implied, express or statutory, including, but not limited to, warranties of non-infringement of third party rights, title of ownership, that the product is in merchantable condition or that the goods are fit for the specific purpose for which they were purchased. Nor is it responsible for their being free of computer viruses.
Privacy Policy
CONEXRED S.A.S. protects the data of the owners in order to prevent its adulteration, loss, use and unauthorized access. Therefore, CONEXRED S.A.S diligently implements human, administrative and technical protection measures that are reasonably within its reach, among which are the contractual obligations of privacy and confidentiality of employees, contractors and suppliers of CONEXRED S.A.S. Therefore, the information provided through the Web Portal, will have the data protection mechanisms that CONEXRED S.A.S has implemented for the management of information and user data, according to the guidelines provided by Law 1581 of 2012.
Disclosing personal information is a unilateral, free, voluntary and spontaneous action on the part of the users of the web portal and it is not a fundamental requirement to navigate in it. If the user decides to disclose personal information, he/she does so by accepting CONEXRED S.A.S. internal manual of personal data processing, which he/she declares to have read in CONEXRED S.A.S. web portal.
Propiedad Intelectual
CONEXRED S.A.S is the owner of the trademarks and logos incorporated in the Web Portal, or holds the license for the use of all graphic elements. It is also the owner of the information presented in the Web Portal. The user accepts that the content of the Web Portal, texts, graphics, links, buttons, logos and images, as well as all service marks, logos and names of products and services (hereinafter referred to collectively as "Intellectual Property"), are the exclusive property of CONEXRED S.A.S. Consequently, the User has the obligation NOT to display, use, copy or modify the Intellectual Property in any way. The user is only authorized to view and save a copy of the Web Portal for his/her personal, non-commercial use. You further agree that: (I) You will not use any automated data mining device, robot, spider, or other similar data gathering or extraction method to access or use the Service; (II) You will not copy or alter any copyright or trademark notices or legends displayed on the Web Site; (III) You will not violate the copyrights, patents, trademarks, trade secrets or any other intellectual property rights or rights of publicity or privacy of CONEXRED S.A.S. or any third party. The access to any information (confidential or not), trademarks or logos, does not grant the user of the Web Portal, either expressly or implicitly, authorization, permission or license of use or any other industrial or intellectual property right over them.
The use of trademarks and/or other elements of property of CONEXRED S.A.S. or of CONEXRED S.A.S. customers whose trademarks are published in the Web Portal is not allowed. In case of any violation of this prohibition, CONEXRED S.A.S. will initiate the corresponding legal actions.
Limit of liability
CONEXRED S.A.S. shall not be liable for any damages, including but not limited to, any punitive, indirect, incidental or consequential damages, including lost profits or lost revenues. Also against damages caused by errors, omissions, interruptions, defects or delays that occur in the Web Portal. The user must have in their equipment with antivirus and security mechanisms necessary to prevent the alteration or impersonation of their credentials, so CONEXRED S.A.S is not responsible for transactions that are generated impersonating their identity and are made with or without their authorization.
CONEXRED S.A.S will promote the updating of the information on its Web Portal but does not guarantee the accuracy of this so the information published on the Web Portal may refer to products, programs or services that are not available so you should consult with a sales representative of CONEXRED S.A.S, to obtain accurate information. Regarding the products and services are governed solely and exclusively by contracts or agreements that are signed or on which their terms and conditions are accepted and nothing in this portal should be understood as a modification of such agreements.
Know the personal data treatment policies Our personal data protection policy applies to all databases and / or files containing personal data that are subject to processing by Conexred S.A.S.
Privacy Notice
CONEXRED S.A.S., domiciled in the city of Bogota at Calle 100 No. 19 - 61 Piso 9, will act as the Data Controller of your personal data, which will be treated according to the policies and procedures designed to protect the confidentiality of the information and make proper use of them. The data provided by you are stored in CONEXRED S.A.S. servers, where they are being guarded through the use of information security tools, reasonably accepted in the industry, such as firewalls, access control procedures, among others. All of the above in order to prevent unauthorized access by third parties to stored personal data.
You may contact us at: Office Address: Calle 100 No. 19 - 61 Piso 9. City: Bogotá D.C., Colombia. Telephone: 313 5559768 in the rest of the country Email: servicioal.cliente@puntored.co
Personal data will be collected, stored, used or deleted in a database in charge of CONEXRED S.A.S, in order to develop its corporate purpose. You have the right to know, update, rectify and delete the personal data of which you are the owner, through the procedures established in Law 1581/2012 (Law on Protection of Personal Data) and if at any time you are asked questions about sensitive data, you may determine whether or not to answer such questions, as the disclosure of this information is voluntary. Likewise, you may revoke the authorization for storage and use of your personal data in the events provided by law, provided there is no relationship with CONEXRED S.A.S.
To exercise this right, you may do so through the following channels:
By contacting our customer service lines in the rest of the country at 313 5559768.
By means of a communication addressed to the e-mail: servicioal.cliente@puntored.co CONEXRED S.A.S makes available to you the Information Processing Policy which establishes the principles under which the request, processing, custody and use of your personal data will be carried out, which may be consulted at https://www.puntored.co/ and in case of any substantial modification thereof, this will be made known by giving notice through the company's website, email and / or administrative portal. The authorization provided extends the access to the information to whoever represents the rights of CONEXRED S.A.S., to whom it hires for the exercise of the same or to whom it assigns its rights, its obligations or its contractual position in any title, in relation to the information of the affiliated service point, as well as to the execution of the contract(s) that have been signed. Likewise, to third parties with whom CONEXRED S.A.S. establishes commercial alliances, or contracts for the provision of services from which the products or services that may be provided from the affiliated service point are modified, complemented or expanded.
On December 27, 2021, the National Tax and Customs Directorate - DIAN issued Resolution 1641, which regulates the reporting of information to such entity related to beneficial owners, as described in Articles 631-5 and 631-6 of the Tax Statute.
Taking into account the above, Conexred SAS. must comply with the reporting of the information corresponding to the participation account contracts it manages, therefore we kindly request you to provide us with the data associated with the natural persons who own or control and/or exercise effective control over the contract of which you are a party in the commercial agreements you have with Puntored.
Here you will find the form to be filled out, which must be duly signed by June 27, 2023.
SYSTEM FOR SELF-MONITORING AND COMPREHENSIVE RISK MANAGEMENT OF MONEY LAUNDERING, FINANCING OF TERRORISM AND FINANCING FOR THE PROLIFERATION OF WEAPONS OF MASS DESTRUCTION (LA/FT/FPADM) AND SUSPICIOUS TRANSACTION REPORTING TO THE UIAF
In accordance with the provisions of the Basic Legal Circular of the Superintendence of Companies in Chapter X – “Regime of Self-Control and Integral Risk Management LA/FT/FPADM and Suspicious Transaction Reporting to the UIAF”, as amended by External Circulars 100-000016 of 2020, 100-000004 of 2021 and 100-000015 of 2021. For Conexred S.A.S. (hereinafter “Conexred”), it is imperative the implementation of the Self-Control and Integral Risk Management System for Money Laundering and Financing of Terrorism. – SAGRILAFT, not only in compliance with the Colombian legal regulations, but also as an added value for our stakeholders and in compliance with the code of conduct and risk policies that allow us to act with integrity in the development of our corporate purpose.
1. Objective
Conexred establishes policies, methodologies and procedures for the self-control and management of ML/FT/FPADM risk, in order to minimize the risk that the Company is used as a means to give the appearance of legality to resources from illicit activities and transactions that seek to support terrorism, the financing of the proliferation of weapons of mass destruction and its source crimes.
2. Scope
This policy is addressed to all allies, clients, collaborators, partners, members of the Board of Directors, suppliers and other third parties linked to the Company.
Additionally, this policy is complemented by the SAGRILAFT Manual, documents approved by the Board of Directors.
3. Guidelines
These policies establish the general framework and basic principles for the self-control and management of ML/FT/FPADM risk, which allow identifying, assessing, treating and monitoring the risks to which the company is exposed, as a result of its nature and operation.
Likewise, to ensure effective and efficient risk management, this policy must adhere to the ethical principles and values outlined in the Code of Ethics and SAGRILAFT Manual, for which the company has established the following aspects:
● Conexred carries out a training program based on SAGRILAFT regulations and development.
● Commercial negotiations shall not take precedence over compliance with the policies and guidelines defined for the management of money laundering and terrorist financing risk in this manual.
● Mechanisms will be adopted to conserve documentary information on members, movements of incoming and outgoing funds, reports to the UIAF, reports prepared by the Compliance Officer, the auditors and other information generated in the execution of SAGRILAFT.
● Report to the Financial Information and Analysis Unit (UIAF) the operations that have been determined as suspicious of Money Laundering and Financing of Terrorism and cash transactions.
● The information on attempted or suspicious transactions related to Money Laundering and Financing of Terrorism shall be treated with strict confidentiality, and therefore the name or identity of the persons whose conduct has led to the generation of the report may not be disclosed.
● Perform due diligence on any natural or legal person that formalizes a contractual or legal relationship (allies, customers, collaborators, suppliers, shareholders, contractors and other counterparties).
● Any transaction to which the Company is a party must have internal and/or external documentation that clearly explains the nature of the transactions, the date and the approvals given in accordance with the policies and procedures established for each area and process of the Company.
● The Company shall refrain from entering into relationships with allies, customers, collaborators, partners, members of the Board of Directors, suppliers and other related parties that are on any of the binding and restrictive lists.
● Employees must immediately report any unusual or suspicious operation that they identify in the course of their daily activities to the Compliance Officer. Employees and/or third parties who have any relationship with the Company assume the commitment and responsibility to promptly respond to the requests made by the Compliance Officer.
● Any situation or inquiry regarding a potential conflict of interest must be reported to the immediate superior, who must pass it on to the authority in charge of resolving this conflict.
4. Communications
Our communication channels are:
● E-mail: contactocumplimiento@puntored.co
● Ethical Line: https://puntored.co/linea-de-etica/
5. Privacy Notice
The information related to the implementation and execution of SAGRILAFT is confidential and is managed by those responsible for its execution within the company. This information may only be disclosed to the competent judicial or administrative authorities with the prior approval of the Compliance Officer.
TRANSPARENCY AND BUSINESS ETHICS PROGRAMS THROUGH SELF-MONITORING ACTIVITIES AND MANAGEMENT OF CORRUPTION RISKS AND TRANSNATIONAL BRIBERY RISKS.
In accordance with the provisions of Chapter XIII – “Instructions and administrative recommendations aimed at implementing Transparency and Business Ethics Programs through activities of self-control and management of corruption risks and risks of transnational bribery”, as amended by External Circular 100-000011 of 2021, for Conexred S.A. S (hereinafter “Conexred”), it is imperative the implementation of the Transparency and Business Ethics Program (PTEE), not only in compliance with the Colombian legal regulations, but also as an added value for our stakeholders and in compliance with the code of conduct and risk policies that allow us to act with integrity in the development of our corporate purpose.
1. Objective
The main objective of the PTEE policy is to formulate and communicate the policies, values and principles established by Conexred’s senior management, subsidiaries or subordinates, to ensure that all its employees perform their duties in an ethical, transparent and honest manner applicable to the relationships between them, suppliers, distributors, business partners, customers and authorities.
2. Scope
This policy is addressed to all allies, customers, collaborators, partners, members of the Board of Directors, suppliers and other third parties linked to the Company, with the purpose of being used in the timely performance of their functions, which must be governed and inspired by the highest ethical standards, facilitating the self-control and execution of processes, allowing the preventive identification of the different C/ST risk situations to which the entity may be exposed.
3. Guidelines
Conexred, its administrators, collaborators and senior management are committed to act ethically and transparently before its stakeholders, and to conduct business in a responsible manner, acting under the principle of zero tolerance to corrupt practices on the part of any of the Company’s counterparts, therefore, the company has established the following aspects:
● Conexred rejects and refrains from engaging in acts of Corruption, including transnational bribery. It implements necessary mechanisms to combat and fight corruption and other criminal acts related to transnational bribery.
● Imparts an institutional culture of anti-corruption and Business Ethics. Establishes rules of conduct in order to prevent the occurrence of any act of Corruption derived from the giving and receiving of gifts, money or gifts.
● Evaluates and manages in a timely manner all complaints received and adopts a policy of non-retaliation against those reporting alleged acts of corruption.
● Conexred has an Ethics Hotline, through which we receive reports of non-compliance with the provisions of this policy and other documents that integrate it.
● The company together with the Compliance Officer manages in a timely manner all reports of acts related to Corruption, regardless of the amount or personnel involved.
● The PTEE compiles all the rules regarding prevention and mitigation of the Risks of Corruption and Transnational Bribery, as well as the ethical principles and values that Conexred has, in order to conduct its business in an ethical and transparent manner.
● It is forbidden to authorize, deliver, offer, promise, any object of value directly or indirectly to our counterparties or third parties involved with Conexred.
4. Communications
Our communication channels are:
● E-mail address contactocumplimiento@puntored.co
● Línea Ética https://puntored.co/linea-de-etica/
5. Privacy Notice
The information related to the implementation and execution of the PTEE is confidential and is managed by those responsible for its execution within the company. This information may only be disclosed to the competent judicial or administrative authorities with the prior approval of the Compliance Officer.
