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Effective Date: April 3, 2025

Ethical Line: Together we build integrity

At Cleo, integrity and transparency are the pillars of our culture and a shared responsibility. We have enabled this Ethics Line, an open channel for anyone to report acts of corruption.

If you are aware of any conduct that violates our policies or an act of corruption, we invite you to report it through this confidential channel. It is available to workers, suppliers, customers, or anyone who wishes to contribute to a fairer and more ethical environment.

Each complaint will be treated with the utmost seriousness and managed under the principles of issuance, confidentiality, responsibility and effectiveness. We will thoroughly investigate each report, ensuring the protection of those who report in good faith and act honestly.

Your action makes a difference.

Information about your security and privacy

Before making your report, we want you to know that your safety is our priority. We have designed this channel to ensure maximum confidentiality and protection.

We invite you to read our Complaints Channel Guide, where you will find detailed information about the procedure and, most importantly, the measures we take to protect your identity and avoid any type of retaliation.

Your collaboration is crucial, and we want to make sure you feel safe taking this step.

All information related to complaints and investigations will be treated with the strictest confidentiality. Access to this information will be restricted to those directly involved in the process.

Reception

The compliance team will be responsible for receiving the complaint and carrying out an initial assessment of the veracity, relevance and seriousness of the complaint within a maximum period of 7 business days from its receipt.

Remember that this channel is only for reporting any activity that could involve any violation or transgression of any law, regulation or the principles established in the company's internal regulations.

Investigation

For an effective investigation, it is recommended that the complaint contain the following information:

  • Clear and concise details of the events, indicating what happened, when, where and how, trying to be as precise as possible regarding the time when the incident occurred or became known.

  • The identification of the people or areas involved.

  • Evidence such as documents, emails, messages, photographs, names of witnesses, or other relevant information to support the complaint.

Follow-up

You will be given a document number by which you can follow the status of your complaint, regardless of whether it is anonymous

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