Control Enviroment

Elements of the Control Enviroment - PEI

The management and operation of the PEI are framed within a control environment which is composed of different elements distributed among the corporate bodies and companies involved in the management and governance of the PEI, according to the processes and activities under their responsibility. The systems and controls implemented by each of those involved are aimed at identifying, monitoring and managing the risks to which the vehicle may be exposed, in order to implement the necessary controls and mitigants.

Investors General Assembly The Investors

Investors General Assembly The Investors’ General Assembly will be integrated by the Investors with the quorum and under the conditions set forth in the Trust’s Equity Securities Issuance and Placement Program Prospectus. Find the rules and regulations for the operation of the assembly and other information of interest here.

Advisory Committee

The Trust will have an Advisory Committee made up by nine (9) members, which will make the decisions on the Permitted Investments, the Issuance Program, the purchase and sale of Real Estate Assets, and the Trust’s Financial Indebtedness, following the guidelines of the Trust’s Equity Securities Issuance and Placement Program Prospectus. Learn more about its composition and regulations here.

Statutory Auditing

PEI will have its own statutory auditing, exclusive and independent from that of the Management Agent. PEI’s statutory auditor may be the same or other than that of the Management Agent, as determined by the Advisory Committee. All of the Statutory Auditing findings and reports shall be disclosed in the reports submitted to the Investors General Meeting and the notes to the end-of-period financial statements.

Trust Company or Management Agent

Is Fiduciaria Corficolombiana S.A., which shall fulfill the Management Agent’s duties and, in accordance with Article 5.6.3.1.1 of Decree 2555, shall collect the proceeds from the Issuance Program, make with investments under this Prospectus charged to the Trust’s resources, and act before the Investors and third parties as the Trust’s spokesperson.
Additionally, the Management Agent has internal policies on corporate governance practices and business ethics, which apply to the governing bodies and personnel of the Management Agent in charge of managing the PEI, which can be found here.

Investors Legal Representative

It is the financial services company Fiduciaria Colombiana de Comercio Exterior S.A. – Fiducoldex, or the entity legally authorized to do so, as selected by the Investors General Assembly to replace it.
To learn more about the Investors’ Legal Representative click here or consult their website www.fiducoldex.com.co

Real Estate Manager

Internal Audit: The Real Estate Manager has an internal audit area that periodically audits the company’s processes, including those deployed for the administration of the PEI, to ensure that they comply with the procedures and policies established for each process. The audit includes the supervision of processes involving third parties such as specialized operators and clients of PEI properties. The audit includes the supervision of processes involving third parties such as specialized operators and clients of PEI properties.

Statutory Auditor of the Administrator: Professional or independent firm in charge of issuing an objective opinion on the quality and veracity of Pei AM’s financial information.

Specialized Committees: Specialized Committees: For risk management and decision making, including those related to the services provided by the Real Estate Administrator to the PEI, the Real Estate Administrator has a group of specialized committees by subject that are responsible for monitoring and proposing strategies for the management of issues such as sustainability, business ethics, counterparty risks, crisis management, among others. Learn more about these committees here.

SAGRILAFT: In order to prevent the risk of money laundering, financing of terrorism and financing of the proliferation of weapons of mass destruction, the Real Estate Administrator establishes procedures and controls that govern its relationship with third parties, which are described in the SAGRILAFT Policy and Manual that can be found here In compliance with best practices and legal requirements, the Administrator has a compliance officer in charge of supervising the fulfillment with the controls established therein. It also conducts annual training and awareness-raising activities for its employees on the subject.

PTEE: The Transparency and Business Ethics Program establishes the standards of behavior expected from the Real Estate Administrator’s employees with regard to the different stakeholders in order to promote impartial, transparent and trustworthy relationships, ensuring the ethics, integrity and quality of the services it provides as a real estate administrator. The PTEE is composed of different policies and manuals that establish the protocols and actions aimed at preventing and managing reputational risks, Money laundering and financing of terrorism, corruption and potential conflicts of interest, which can be found here.

Committees

Audit Committee:

Functions: Responsible for supervising the management and effectiveness of the internal control system, monitoring the independence and objectivity of the internal auditor, defining and following up on the internal audit plan and; evaluating the findings detected in the audit results and the implemented action plans.
Composition: Executive Director of the Real Estate Manager and the Internal Auditor.
Regulation: The audit committee has its own regulation, which can be consulted here.

Sustainability Committee:

Functions: Define, update and follow up on the compliance and development of the corporate sustainability model (and the policies that conforms it) under which the Real Estate Manager manages the vehicle.
Composition: President, Legal and Corporate Affairs Manager and Innovation, Strategy and Communications Manager.
Regulation: The Sustainability committee has its own regulation, which can be consulted here.

Ethics Committee:

Functions: It is the corporate body in charge of supervising the compliance with the Code of Conduct; supervising and managing the complaints made to the Ethics Mailbox; resolving Conflict of Interest situations in which the employees of the Real Estate Manager are involved and initiating investigations and defining the action plan for potential violations to the Transparency and Business Ethics Program.
Composition: Executive Director, President, Legal and Corporate Affairs Manager, Human Talent Manager. The compliance officer attends will have the right to speak but not to vote, when the topics to be discussed are related to his functions.
Regulation: The Ethics committee has its own regulation, which can be consulted here.

Procurement Committee:

Functions: To assure compliance with the Procurement Policy that promotes objectivity and transparency in the Real Estate Manager contracting process, as well as the evaluation and approvement of suppliers when the contracting modality presents any exception or incompatibility with the provisions of the Contracting and Procurement Policy.
Composition: Vice President of Finance and Investor Relations; Legal and Corporate Affairs Manager, Director of Contracting and Procurement and manager of the area requesting the contract.
The Procurement Committee has a policy, which can be consulted here.