Compliance, Ethics and Governance

The company has a governance, ethics and compliance structure that appropriately manages its regulatory risks, which is based on compliance programs in areas such as crime prevention, ethics, free competition, the environment, personal data protection and consumer rights protection.

All our compliance programs contain standards that describe the behavior expected of our employees, as well as the consequences of non-compliance. They describe how we publish the behavior expected of our employees, which must begin with senior executives and then be cascaded throughout the entire organization. They describe how these standards are applied in practice, and they describe the checks that verify correct execution.

We use this structure to continually manage our compliance risks and every quarter we report the management indicators that measure the effectiveness of our programs.

  

Ethics Program

Falabella is firmly committed to ethically and conscientiously managing its business and recognizes that it must promote a culture of integrity and compliance that guides the behavior of all its employees. Accordingly, Falabella S.A. has an Ethics Program, which contains the associated internal regulations, including the Integrity Code and the Handling Conflicts of Interest Policy and the Gifts and Invitations Policy, which reflect the values ​​of our company and give us tools to act correctly.

A very important part of our Ethics Program is the Integrity Channel available to employees and other stakeholders, such as suppliers, customers, and anyone who needs to make a query or complaint of an ethical nature; raise doubts or concerns related to infractions, or law´s breaches or internal regulations. The communication channels are varied, such as, email, telephone, through the link located on the website and in the intranet of each company; and, in person by going directly to the offices of the corresponding Ethics Management area.

Our Integrity Channel is the same for all Falabella businesses and is confidential, anonymous and without reprisals, that is, confidentiality is required of all those involved in an investigation or consultation; reprisals against those who use it in good faith are not tolerated; and anonymous inquiries and complaints are allowed.

In the event of a complaint, the person can choose to communicate through any of the communication channels described. Once completed, and according to our General Investigation Policy and Procedure, an investigation is carried out from the Ethics Management area to investigators trained for such purposes, who subsequently deliver a report so that, together with each business, the necessary measures are taken. These can translate into disciplinary actions up to the dismissal of the collaborator.

Likewise, our channel is communicated periodically through posters, emails, digital and face-to-face campaigns. In pursuit of our continuous improvement, we are constantly receiving feedback from employees regarding this tool, through surveys, meetings with employees, unions, etc.

It is important to note that the use of channel that the company makes available to employees and third parties does not imply the waiver of their right to file a complaint with the corresponding authorities, nor the requirement to maintain confidentiality regarding the reported facts.

During 2022, 30 incidents of discrimination were registered in all Falabella companies; 5 were proven and closed and the corresponding sanctions were applied in accordance with internal management processes. Likewise, 104 complaints of sexual harassment were registered directly with Falabella companies, while none were filed with the Labour Department or equivalent body. Regarding workplace harassment, 125 complaints were filed directly with Falabella companies, while another 8 complaints for the same concept were filed with the Labour Department or equivalent body. The complaints received were investigated in accordance with our internal procedures, with a smaller percentage of them being proven.

The Integrity Channel’s means of contact can be found here.

Our Integrity Code can be found here.

 

+ Crime Prevention and Anti-Corruption Program

The size, structure, diversity and multiplicity of Falabella’s markets require that appropriate behavior standards are defined, to prevent behavior that could result in bribery. Accordingly, Falabella approved a Crime Prevention Model (CPM) and a corporate Anti-Bribery Policy that categorically prohibits the commission of any illegal act within the organization, particularly bribery between private individuals and domestic or foreign public officials.

A campaign called "I play fair" was implemented to address this important issue, which establishes the minimum standards that apply to all company employees when interacting with any public official. This campaign is reinforced throughout the year using bulletins and training courses for every position exposed to this risk within the Falabella group.

Falabella is firmly committed to respecting and complying with all the relevant laws and regulations. The Integrity Code describes this commitment to promote a culture of compliance and integrity that guides the behavior of all its employees, regardless of the country or place where they work.

Therefore, Falabella proactively prohibits the commission of any crime, especially those related to money laundering, financing terrorism, bribery of public officials or private parties, inappropriate business dealings, and any that may involve criminal or administrative liability for any of Falabella's companies.

How do we do it?

  • Anti-corruption awareness: dinformation is provided during the year on the duties and obligations of all employees with regard to anti-corruption. The company posts Infographics in the media for all employees, and people working in positions exposed to this risk are invited to training sessions that explain the checks to prevent corruption. Random evaluations verify the scope of these communication and training measures. Anti-corruption initiatives include the “Yo Juego Limpio” (I Play Fair) campaign to prevent bribes being offered to public officials and corruption among private individuals. The “Un millón de gracias, pero no” (A million thanks, but no thanks) campaign describes everything related to receiving and giving gifts.
  • Training for people working in positions exposed to this risk: training is provided at least once a year to everyone working in positions exposed to the greatest risks according to their duties. They are trained in anti-corruption issues covering the crime, its scope, its history and the company’s measures to prevent it. They are instructed how to behave if they become the passive subjects of this crime and they are also reminded that there is an Integrity Channel and a mailbox to request advice from the lawyers at the Compliance department.
  • Compliance risk analysis: Falabella has developed a Compliance Risk Management Procedure for compliance risk assessment and analysis, which aims to:
  • Board Oversight: A report on Falabella's compliance programs is submitted to the Board of Directors on a semi-annual basis and emphasizes the Crime Prevention and Antitrust Programs. This report describes the Crime Prevention Program’s prevention, detection, response and monitoring measures, and it focuses on:
  • Procedures to address CPM with brokers: Falabella extends its own internal policies to its third-party brokers to prevent them becoming corrupted. We communicate our standards and provide training on anti-corruption issues to brokers. The same Risk Management Procedure is used to survey and manage these risks, and they are added to the crime prevention matrix for each business. Most importantly, compliance and anti-corruption clauses are added to all of Falabella's third-party contracts.

Our Crime Prevention Model can be found here.

Our Certificate of 20.393 law can be found here.

+ Human Rights

Falabella is committed to behaving in a socially responsible manner towards its customers, employees, suppliers, local communities, the environment, and society in general. We understand that our business can impact the quality of life of our stakeholders. Therefore, we have mechanisms that adequately identify and evaluate risks, in order to prevent these impacts and correct them where necessary.

  • Business and Human Rights Policy: Falabella has a Business and Human Rights Policy, which reflects its commitment to respect and promote the fundamental rights of individuals. Falabella encourages its suppliers to behave in accordance with the standards, guidelines and principles in this Policy.

    It defines the principles and specific measures that guide Falabella's behavior to ensure that it actively and sustainably complies with Human Rights standards with respect to the impact of its business, in accordance with its corporate values, its internal regulations, and the United Nations Guiding Principles on Business and Human Rights.

    Our Policy has established three resources and monitoring mechanisms:
  • Protect children's rights: Falabella respects and promotes the principles enshrined in the Universal Declaration of Human Rights and the United Nations Convention on the Rights of the Child, and it complies with all laws and regulations governing child labor and apprenticeship programs. It also adheres to the United Nations Global Compact, and its initiatives are aligned with the Sustainable Development Goals.
    Falabella emphatically rejects human trafficking and the use of child labor. It contractually encourages its suppliers to comply with the law, international treaties, declarations and conventions that promote and protect human rights, and contribute to eradicating child labor.
  • Adherence to fundamental rights: Falabella respects the fundamental rights described in the United Nations Guiding Principles on Business and Human Rights, the International Bill of Human Rights, and the International Labor Organization's Declaration on Fundamental Principles and Rights at Work. This requires it to prevent its own business from causing or contributing to negative consequences for people.

 Learn more about our work regarding Human Rights here.

+ Antitrust Program

Falabella has an Antitrust Compliance Program that describes various regulations and measures aimed at mitigating the risk of anti-competitive behavior.

Communication and training activities are focused on people working in positions exposed to the antitrust risks that may arise at Falabella, and explain the checks designed to prevent exposure to them.

Falabella publishes its Antitrust Compliance Program and related materials using various internal communication channels.

We ensure that our employees are kept informed of significant news on antitrust matters.

Our Antitrust Policy can be found here.

“Information of Interest - Settlement with the Chilean antitrust authority (FNE) regarding interlocking case”

+ Environmental Program

An Environmental Program was approved in 2020 that demonstrates Falabella's commitment to caring for the environment and sustainably operating its business.

The purpose of this Program is i) to guide the behavior of employees and suppliers in relation to the environment, ii) to establish mechanisms to comply with the legal requirements and Falabella’s environmental commitments, and iii) to manage Falabella’s risks in relation to the environment.

This Program encompasses several internal regulations related to environmental issues, such as the Environmental and Climate Change Policy, the Inspections by Environmental Authorities Protocol, the Environmental Permit Submission and Administration Instructions, the Reporting Information to Authorities Protocol, and the Compliance with Extended Producer Responsibility Protocol.

Our Environmental and Climate Change Policy can be found here.

 

+ Personal Data Protection Program

We know that a good shopping experience for our customers includes protecting their privacy. Accordingly, the Personal Data Protection Compliance Program was approved in 2021, which compliments the technological advances that Falabella implemented during the year.

This Program expresses Falabella's commitment to respect the fundamental rights of individuals. Therefore, it focuses on guidelines and measures that protect personal data and prevent behavior that could violate the associated laws.

This Program is led by the Personal Data Protection Compliance Officer, whose main function is to ensure that the Program is correctly executed.

Our Personal Data Protection Policy can be found here.

 

+ 'My Customer' Program

We want to provide Falabella’s customers with the best shopping experience, so we have implemented our My Customer Compliance Program. It focuses on guidelines and measures that protect customers' rights and prevent behavior that might contravene the law that protects consumers' rights.

This Program includes training and information on the i) Preparation of Advertising and Promotional Material Policy and Procedure, ii) Guarantee Requirements Procedure, iii) Inspections by Authorities Procedure, iv) Customer Security Procedure, v) Processing and Responding to Customer Complaints Procedure, and vi) Customer Rights Protection Policy.

Every year, we present the My Customer Update Report to all our employees, which describes the significant indicators, any new regulations and bills, judicial and administrative procedures, and any related news.

The My Customer Program is led by the Compliance Officer, whose main function is to ensure that the Program is correctly executed.

Our Customer Rights Protection Policy can be found here.

 

+ Supplier Engagement

All Falabella’s business partners are assessed and created in our systems by following the guidelines and checks described in the Supplier Validation and Creation Policy and the Background Data Review Procedure. These two regulations govern the process for accepting any supplier that initiates a relationship with Falabella. They require that suppliers sign a compliance declaration, a conflicts of interest declaration and a links with politically exposed persons declaration. All new suppliers are reviewed by compliance software where they are compared to public lists of prohibited people. Finally, they are reviewed for any negative press comments, and a report is submitted on any findings.

 

Participation in organizations and associations

Falabella participates in many national and international associations and organizations, in order to develop strategic alliances that have common interests and objectives and reinforce sustainability. We do not make contributions to political campaigns, in accordance with our internal regulations and policies.

Contributions in Ch$ millions            2018         2019           2020      
    Lobbying organizations -
    Industry associations1.0771.085 1.200 
   Political campaigns
 Total1.077 1.085 1.200 

The largest contributions to trade associations include the Banks and Financial Institutions Association (Chile, Ch$126 million), the Facatativá Chamber of Commerce (Colombia, Ch$113 million) and the Chilean Chamber of Shopping Centers (Chile, Ch$95 million).

Resource Center

  • Integrity Code
  • Crime Prevention Model
  • Crime Prevention and Anti Bribery Policy
  • Personal Data Protection Policy
  • Corporate Privacy Notice
  • Antitrust Policy
  • Donee Control Protocol
  • Environmental and Climate Change Policy
  • Diversity and Inclusion Policy
  • Sodimac Community Engagement Policy
  • Sodimac Sustainability Policy
  • Tottus Sustainability Policy
  • Customer Rights Protection Policy 
  • FATCA Policy for Non-reporting Companies
  • Human Rights Policy
  • Gender Equity Policy
  • General Investigation Policy
  • General Investigation Procedure
  • Tax Policy