Preventing Bribery, Corruption, and Conducting Internal Audits

As part of Doral’s internal enforcement program, a “Bribery and Corruption Prevention Procedure” was also adopted. The procedure is a tool for implementing the Anti-Bribery and Anti-Corruption Policy formulated and approved by company management and the board of directors, which is publicly available on the Company website.

As outlined in its policy and procedure, the Company is committed, to conducting its business operations with fairness, integrity, reliability, and responsibility. It also places great emphasis on complying with all relevant laws in its operational locations with a focus on preventing bribery and corruption. The purpose of the policy and procedure is to ensure that the Company, its board members, managers, employees, suppliers, and other service providers strictly adhere to these guidelines, as well as other legal requirements. The policy and procedure are widely distributed among all company employees, who are required to approve them. Furthermore, as part of its agreements with external parties such as service providers, contractors, and consultants acting on its behalf, the Company incorporates commitment clauses aimed at preventing bribery and corruption.

The Anti-Bribery and Anti-Corruption Policy and Prevention Procedure incorporate a robust reporting system for employees who may become aware of or suspect any potentially bribery-related payments in the course of their work with the Company. In such instances, employees are obliged to promptly report the matter to their respective supervisor, with a copy of the report delivered to the Corporate Secretary. In cases where there are concerns about the involvement of the supervisor, the report should be directed solely to the Corporate Secretary. Then, a thorough investigation into the reported incident will be conducted by the appropriate parties to ensure proper handling of the matter.

Through implementation of its procedure, the Company demonstrates its commitment to safeguarding the well-being of the employees through all means necessary, including by maintaining their anonymity. Additionally, the Company guarantees that no employee will be retaliated against for filing a complaint.

In 2023, there were no instances of bribery or corruption.

Doral, as a public company, operates in accordance with legal requirements. Upon the recommendation of the Audit Committee, the board of directors approved the appointment of an internal auditor for the Company. The internal auditor provides internal audit services as an external supplier and operates according to a multi-year plan and the internal audit work plan for 2023, which was prepared in coordination with the Company’s management, presented to the Audit Committee and the board of directors, and approved by the board. The multi-year plan is based on conducting audits related to central processes in the Company, considering the level of exposure, the likelihood of failure, and the potential damage. The work plan is specific to Doral and does not apply to the entire group, and it does not allow the internal auditor the discretion to deviate from it. Therefore, any change to the plan is subject to the approval of the Audit Committee.

In 2023, the Audit Committee held a discussion with the internal auditor and the external auditor without the presence of company officeholders, in line with the authority’s position to allow open dialogue regarding various challenges that arise during the audit work. The Company advocates for transparent dialogue and full cooperation between the management and the audit bodies.

The internal audit work plan for 2023 was prepared by the internal auditor in coordination with the Company’s management, presented to the Audit Committee and the board of directors, and approved by the board. Any change to the plan is subject to the approval of the Audit Committee.

For additional information about the internal auditor consult Doral’s 2023 Annual Report.