

Corporate Governance
Dolmen S.A. E.S.P. adopts the definition and understands Corporate Governance as the system through which the company is directed, managed, and controlled by balancing ownership and management, to ensure its sustainability and growth, the rights of its investors, transparency and ethics in its actions, and access to information for its stakeholders.

Transparency and Accountability
Corporate Governance makes the management and results of Dolmen S.A. E.S.P. visible to its various stakeholders, aiming to build trust as a fundamental element to ensure continuity and sustainability.
Balance Between Governing Bodies
Corporate Governance provides the framework that defines decision-making rights and responsibilities, with criteria that promote value creation, business excellence, and balanced access to information.
Commitment to Implementing Governance Practices
The governing bodies of Dolmen S.A. E.S.P. drive the implementation of best Corporate Governance practices. The company’s executives and employees are committed to adopting these practices.
Shared Responsibility
Corporate Governance promotes respect and shared responsibility within each governing body, aligning expectations and interests to maximize the value of the company and its stakeholders.
Recognition of the Impact of Corporate Governance
The way Dolmen S.A. E.S.P. is directed and controlled is of interest to society at large. In this regard, the company acknowledges the impact its practices have on Corporate Governance.
Corporate Governance
Integration with Other Systems, Processes, and Themes Complementary to Corporate Governance
Dolmen S.A. E.S.P., in its commitment to strengthening Corporate Governance, promotes integration with key organizational themes such as the internal control structure, ethical management and transparency, sustainability, and other complementary matters, including the leadership behaviors of the EFR (Family-Responsible Company) model, which encompass quality of employment, family support, flexibility, holistic talent development, equal opportunities, and conscious leadership.
Internal Control Structure at Dolmen S.A. E.S.P.
Dolmen S.A. E.S.P. has policies, processes, procedures, activities, and information that ensure unity of purpose and direction, complying with the internal and external legal framework that regulates it, with the common goal of achieving the established objectives.
Corporate Social Responsibility (CSR) at Dolmen S.A. E.S.P.
Corporate Social Responsibility (CSR) is led with a comprehensive vision, from the definition of strategic elements to monitoring progress in management, to facilitate a socially responsible way of doing business based on the CSR-Sustainability Policy.
For Dolmen S.A. E.S.P., CSR is a business approach that seeks to generate value not only for the organization but also for its stakeholders and society. It involves balancing economic, social, and environmental interactions and is closely linked to business activities, aiming for greater impact and the permanence of practices to achieve broader scale and influence.
Ethical Management at Dolmen S.A. E.S.P.
Dolmen S.A. E.S.P. implements the Transparency and Business Ethics Program (PTEE), which includes the principles of business ethics, corporate values, and the expected behaviors and conduct of all members of the organization.
The Transparency and Business Ethics Program comprehensively compiles all internal regulations, policies, guidelines, and rules of the implemented management systems for the prevention and mitigation of corruption risks and/or transnational bribery risks, as well as the ethical principles and corporate values defined to conduct business lines in an ethical, transparent, and honest manner.
Transparency and Information Management
Dolmen S.A. E.S.P. will disclose information about its financial and non-financial situation in accordance with current legal provisions, to the Shareholders’ Assembly.
The disclosure of information is guided by the principle of transparency, understood as the quality that makes information truthful, clear, timely, relevant, accessible, and useful for the discernment of its recipients.
Transparency and Business Ethics Policy
Dolmen S.A. E.S.P., and each of its employees, is committed to “conducting investments and developing business in a responsible, transparent manner, in accordance with the legal and ethical standards issued in each country where we operate, to safeguard the organization’s reputation, integrity, values, and financial well-being.”
Our Commitment
The partners, executives, and each employee commit to:
Understanding anti-bribery, corruption, money laundering, and terrorism financing laws (Law 1778).
Implementing best practices at Dolmen S.A. E.S.P. to combat and foster a culture against money laundering, terrorism financing, and the proliferation of weapons of mass destruction.
Adhering to the principles of the Transparency and Business Ethics Program through the Ethical Principles, Behaviors, and Expected Conduct at Dolmen S.A. E.S.P.
Staying updated and informed about the Management and Compliance of the Business Ethics Program.
Business Ethics Principles
Honesty
All employees of Dolmen S.A. E.S.P. must act with honesty both within and outside the organization.
Responsibility
Recognize the consequences of our actions and their impacts on others and the institution.
Optimism
Employees must face situations with perseverance, trusting in their abilities and possibilities.
Uprightness
All employees must act with integrity and adherence to corporate goals, being consistent with their own principles and actions.
Service Attitude
Address the needs of clients and coworkers with kindness, warmth, and promptness, without any form of discrimination, aiming to meet their needs.
Proactivity
Take initiative in developing creative and effective actions to generate improvements, assuming responsibility and commitment to achieving goals.
Respect
Employees must acknowledge the individual and inalienable differences of coworkers, clients, suppliers, and stakeholders, providing courteous treatment that fosters harmonious coexistence.
Information
All employees must provide clients, suppliers, and coworkers with timely, complete, and truthful information as requested, without disclosing confidential organizational information.
Team Spirit
Employees of our organization must act as a cohesive and organized entity, building bonds strengthened by respect and cooperation in the workplace.
Integrity
Employee behavior must not lend itself to misunderstandings or misinterpretations.
Impartiality
All decisions must be made without discrimination or favoritism, based on demonstrable arguments supported by facts or evidence.
Teamwork
Employees must collaborate with their colleagues in fulfilling their duties to ensure harmony and efficiency in business development.
Open a link to download related documents:
Programa PTEE
Manual Sagrilaft
Ethics Line
As part of monitoring compliance with the Transparency and Business Ethics Program, Dolmen S.A. E.S.P. has implemented an Ethics Line through which stakeholders can report non-compliance with the program, particularly regarding fraud, corruption, bribery, money laundering, and terrorism financing.
Purpose
To provide a communication mechanism through which our stakeholders can make inquiries or report violations of our Code of Ethics and Conduct.
Management
The email is managed by our Compliance Officer. Once cases are received, recorded, and classified, they are handled in accordance with the entity’s Code of Ethics and Conduct.
Information Handling
Information received through the Ethics Line is classified as confidential and managed as such. Personal data is processed appropriately and for authorized purposes. The identity of individuals is protected.
Communication, Reporting, or Follow-Up Inquiries Related to Transparency, Ethics, and Compliance