ANNUAL AND SUSTAINABILITY REPORT 2015

True to our beliefs

Our Philosophy

G4-56, G4-57, G4-58

Throughout our 25 years of history, we have continued to be true to our original values and principles. We have been led by our Philosophy, a way of life that guides everything we do, and recognizes every person as unique, respecting his dignity, rights and obligations.

Our Philosophy is our differentiator;
it is our way of thinking
and acting

Code of Ethics and Conduct

G4-DMA ANTI-CORRUPTION (GENERIC AND SPECIFIC)
G4-56, G4-57, G4-58, G4-SO4

It is the instrument that communicates our Philosophy guiding our actions and daily work. It is the means through which we share our essence with all our stakeholders. It applies to our employees, consultants and commissioners, as well as to our clients and suppliers.

We convey ethical behavior through rules of conduct and behavior that foster healthy relations and protect the interests of our internal and external stakeholders giving us a high degree of credibility. The rules of conduct address themes such as interest conflict, handling of information, privileged information, corruption, harassment and work environment, among others.

In addition, every year we carry out our Philosophy survey in order to measure how our values are experienced in daily work.

In 2015, we conducted
15,300 surveys,
between our employees, getting an annual global satisfaction result of 88% of them experiencing our Philosophy

To protect our Philosophy and maintain our values, we have established in all our companies, a confidential means for denouncing non-compliances of the Code of Ethics and Conduct; these are attended by our Honor Commission.

For more information about our Code of Ethics and Conduct and the means of denunciation, visit our website

Regulatory compliance

G4-DMA COMPLIANCE G4-14

The main work we carry out to identify and mitigate risks regarding regulatory compliance throughout Gentera and its companies, is to provide suitable legal counseling and ensuring correct and timely compliance with the requirements of the authorities. This is duly established in our institutional procedures. The bodies that regulate the operations of our Group in the three countries where we operate in are the following:

Mexico Peru Guatemala
  • Comisión Nacional Bancaria y de Valores (CNBV)
  • Superintendencia de Banca, Seguros y AFP (SBS)
  • As a limited liability company we are governed by the regulatory bodies of industry and commerce in Guatemala
  • Comisión Nacional de Seguros y Fianzas (CNSF)
  • Superintendencia del Mercado de Valores (SMV)
  • Banco de México (BANXICO)
  • Banco Central de Reserva del Perú (BCRP)
  • Comisión Nacional para la Protección y Defensa de los Usuarios de Servicios Financieros (CONDUSEF)
  • Secretaría de Hacienda y Crédito Público (SHCP)
  • Servicio de Administración Tributaria (SAT)
  • Instituto para la Protección al Ahorro Bancario (IPAB)

Because Gentera and its companies have a robust process to guarantee compliance with the legal provisions issued by the above institutions, we avoid any economic impact to the group or to its reputation, managing to achieve a good standing before regulators like CNBV and CONDUSEF.

Compartamos Banco fosters an organizational culture of self-control in which the role played by each one of its employees in following up and applying the control instruments is essential and inspires the trust of our clients. This is mainly due to the fact that all institutional operations are standardized and comply with current regulations.




In 2015, the CNBV recognized Compartamos Banco as a financial institution with a robust internal control system, constituted by policies and procedures that guarantee the ethical conduct of its employees

Internal Control Procedure
Input Process Deliverables
  • Applicable regulation (includes new regulation and changes to the existing one)
  • Changes to products and/or processes
  • Observations by the authorities and internal and external audits
  • Improvements suggested by monitoring of controls
  • Business strategy
  • Analysis of each one of the input aspects
  • Identification of risks and associated controls
  • Evaluation of the efficiency of existing controls
  • Generation of internal regulatory documents
  • Monitoring of relevant process-regulating controls
  • Compliance matrices
  • Control matrices
  • Monitor control matrices

With this process we streamline our operations, obtain reliable and opportune financial information, comply with applicable current laws and regulations, and safeguard the resources of our institution. To achieve these objectives and consolidate our processes, we have established a priority goal:

G4-DMA AUDIT (SECTOR SPECIFIC) G4-14, G4-47, FS9

To secure our operations are aligned with applicable regulations and our mission, we have an audit process by which we verify –conforming to activities, frequency, and scope described in the Annual Internal Audit Plan– that through standard and efficient application of the policies and procedures of our internal control, proper risk management is carried out and identification of improvement opportunities is achieved in order to renew or business model.

G4-DMA ANTI-CORRUPTION (GENERIC AND SPECIFIC) G4-SO4

Moreover, in accordance to the International Standards for the Professional Practice of Internal Audit (issued by the Institute of Internal Auditors –1210.A2–, our auditors have sufficient knowledge to evaluate the risk of fraud and the manner in which it is managed by the organization, so we have established a Fraud Follow Up, which follows up on this type of incidents.

Sector participation

G4-DMA PUBLIC POLICY (GENERIC AND SPECIFIC), ANTI-COMPETITIVE BEHAVIOR (GENERIC AND SPECIFIC), ACTIVE OWNERSHIP

Regarding public policy, our group actively participates in sector chambers, networks and organisms in order to position our activities, inform about the way in which we manage economic, social and human value, and to share good practices with the financial sector.

Being an election year, 2015 posed several challenges due to new themes arising in the political agenda, which limited our interaction with legislative bodies and required constant monitoring of circumstances in order to identify matters that would restrict our business model and to avoid reputation risks related to the control of financial services.

2015 was a year
of consolidation of
activities related to
financial reform passed
by the Mexican congress
in 2014, creating
opportunities for
the further aspirations
of the Group

G4-14

The process of managing and decreasing risks in free competition and public policy is based on close monitoring of compliance with the requirements of the authorities and adequate communication of the resulting impacts, achieving the improvement in the opinion of the Group among the stakeholders, positioning in sector chambers, and profitability of the business.

This management mode turns out to be a successful entrepreneurial project in terms of transparency and ethics due to permanent follow-up by the public in the media, biennial opinion studies and the achievement of plans and strategies defined by the External Relations and Social Responsibility Committee in order to follow up on the established objectives and goals.

2016 GOALS

  • Maintaining the grade in opinion studies
  • Continuity of specialized attention of every audience
G4-16

The associations in which we actively participated as a Group are:

Mexico Peru
  • Asociación de Bancos de México (ABM)
  • Asociación Mexicana de Dirección de Recursos Humanos, A.C. (AMEDIRH)
  • Confederación Patronal de la República Mexicana, S.P. (COPARMEX)
  • Consejo de la Comunicación, A.C.
  • MicroFinance Network
  • ProDesarrollo Finanzas y Microempresa, A.C.
  • Red ACCION
  • Unión de Instituciones Financieras Mexicanas (UNIFINMEX)
  • Unión Social de Empresarios de México, A.C. (USEM)
  • Foro Económico Mundial (World Economic Forum)
  • Microinsurance Network
  • Consejo Coordinador Empresarial (CCE)
  • Asociación de Instituciones de Microfinanzas del Perú (ASOMIF)
  • Asociación de Bancos del Perú (ASBANC)

On the other hand, we are currently evaluating associations in Guatemala in order to determine which of them we will associate with in 2016.

G4-DMA PRODUCT PORTFOLIO, ACTIVE OWNERSHIP (SECTOR SPECIFIC)

Compartamos Banco is part of the Asociación de Bancos de México (ABM), and, in accordance with its established policies, it participates with voting rights in some of its committees which address specific themes related to sustainability, social responsibility and financial education.