Good Governance Code – 2021

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1. Context

PARUMA S.A.S is a Colombian company, established on May 9, 2018, with its headquarters in Medellin. Its main activity is to evaluate user experiences in interacting with its clients’ digital products.

In order to ensure integrity and transparency in its administration, this document is prepared, which encompasses the general guidelines that apply to everyone involved with PARUMA S.A.S during its economic activities.


Before deciding if a behavior is appropriate within the company, you should check:

  • If it goes against the law.
  • If it contradicts this Code or PARUMA S.A.S’s best practices.
  • If it is inconsistent with the company’s values.

If the answer is affirmative to any of these questions, the behavior is inappropriate. Nevertheless, it is recommended to ask if you have any doubts.

2. Reference Framework

The corporate reference framework is published on the corporate website at and includes:

3. Good Governance

The Code of Good Governance sets the behavior guidelines for daily operations within the company on a national and international level.

It also commits to respecting ethical principles regarding the State, Clients, Collaborators, Suppliers, the Crowdters Community, Society in general, and Shareholders.

Regarding the State

Our behavior is to comply with and support duly established institutions and authorities, collaborating with them in the application of the rules.

With Clients

We expect professionalism and a service-oriented attitude from all collaborators to ensure client satisfaction in every project.

The company conducts a satisfaction survey after each project to capture not only satisfaction but also improvement suggestions.


Collaborator selection is conducted transparently to find candidates aligned with the company’s values and capable of fulfilling their roles professionally. Collaborators must refrain from offering or promoting things they know they cannot deliver to clients or any other involved parties.

Regarding Suppliers

Supplier selection is based on market competition and improving PARUMA’s efficiency and profitability while respecting commercial loyalty and good faith principles.

Crowdters Community

Involvement in the Crowdters community and project participation is voluntary, ensuring equal opportunities for all. Rewards for project participation are the same for everyone to prevent inequality.

Society in General

PARUMA actively engages in guild, sectoral, and national matters, aiming to enhance the quality of life and contribute to common good works or events.

With Shareholders

Benefits distribution aligns with the company’s conditions, treating shareholders fairly and respecting their legitimate rights. Shareholders are informed transparently and comprehensively about the company’s status.

These are just a few sections of the text. If you’d like more sections translated or have specific questions, please let me know!

4. Safety and Health at Work

All workstations where PARUMA S.A.S. employees are located comply with current regulations on occupational safety and health. That’s why we provide safe spaces for work, as health and safety are highly relevant topics for the company.

All company employees must adhere to all policies, practices, and procedures related to this matter. If an employee identifies unsafe situations within the company, they should report it to the relevant department to minimize potential risks to the health and integrity of our employees.

In PARUMA S.A.S., we do not accept inhumane, degrading, or dignity-compromising working conditions. Consequently, child labor and forced labor/slavery are not tolerated in PARUMA S.A.S.

5. Equality and Fair Treatment

Respect is another value instilled in each of our company’s employees, as it is vital in our relationships with clients.

Our commitment to the company goes beyond merely identifying with its values; it involves achieving the goals set by the company as if they were our own.

To fully embody these values, employees must uphold RESPECT AT WORK.


Directors and employees of the company must treat others with respect, preserving their dignity and maintaining a workplace free from all forms of discrimination and any behavior that implies abuse or harassment, be it moral, sexual, or discriminatory.

Moral harassment can include:

  • Verbal offenses
  • Humiliating treatment
  • Threats

Employees must avoid making offensive jokes, using derogatory nicknames, or any other offensive references related to:

  • Race
  • Color
  • Age
  • Gender
  • Religion
  • Marital status
  • Place of origin
  • Disability
  • Orientación sexual
What is sexual harassment?

Sexual harassment is defined as unwanted sexual behavior towards another person. This includes requesting sexual favors, exposing inappropriate material, and other related behaviors.

Free Participation in Internal Processes

At PARUMA S.A.S., we strive for fair and equal treatment for all employees and individuals who wish to be a part of our company.

This is why when hiring new personnel or promoting an employee, decisions are based on objective criteria such as education, experience, skills, and values aligned with the company. These decisions are not influenced by factors like race, religion, sexual orientation, or skin color.

The dismissal of any employee will be based on the misconduct committed, with the right to due process and legal defense prevailing.

6. Privacy and Confidentiality

At PARUMA S.A.S., we fully comply with Law 1581 of 2012, which regulates the protection of personal data.

Under this law, PARUMA S.A.S. protects the privacy of data provided by employees, suppliers, clients, and other individuals with labor or commercial relationships with the company. For detailed policy information, please refer to

Situational Example: I’m an employee of PARUMA S.A.S. and I receive a call from a third party requesting the address and phone number of a colleague. Can I provide this information?

No, you cannot provide the requested information or confirm data that the caller may already have. This information is personal data belonging to each employee. The company only retains such information in compliance with the law.

Confidential Information of the Company

All employees have an obligation to protect the information they come to know about the company in the course of their work. Disclosing this information can put the company at a disadvantage, causing financial losses or harm to its reputation. The disclosure of confidential information or property of PARUMA S.A.S. can only occur with prior authorization from the company.

Confidential information can be safeguarded in the following ways:

  • Refrain from discussing business matters in public.
  • Avoid sharing access passwords to systems.
  • Store documents in locked files.
  • Destroy documents before disposing of them.

This duty must be maintained even after the employment relationship has ended.

Confidential Client Information

All employees have an obligation to protect client information they come to know in the course of their work. The disclosure of this confidential client information can directly or indirectly affect the reputation and profitability of our clients. It can only occur with prior authorization from the clients themselves.

7. Focus on Results

PARUMA S.A.S.’s main goal is to contribute to the country’s development. To achieve this, it is necessary to obtain excellent results that allow for constant growth and good profitability in the business. This, in the long term, will enable the company to generate employment, fulfill commitments, and make reinvestments that promote responsible sustainability.

To achieve excellent results, you can contribute in the following ways:

Care and proper use of company assets and resources

All employees must care for and protect the company’s assets as well as the resources assigned to them to perform their duties correctly. It’s important to use these resources for business purposes, avoiding their inappropriate or illegal use.

Among the assets that are company property and that employees must care for and protect, the following are highlighted:

  • Facilities
  • Computers
  • Internet access
  • Email
  • Landlines or mobile phones
  • Work materials and other supplies
  • Intellectual property, such as the name and brand

It is prohibited for employees to provide or transmit company information, business information, or personal information of employees to third parties without proper authorization from the department head. Additionally, employees are prohibited from using work tools for purposes other than their assigned duties, including transferring information related to pornography, terrorism, chain messages, political or partisan propaganda, games, and other topics over the internet.

Situational Example: Can I use the computer to look up something unrelated to my work?

Yes, as long as it does not significantly affect your work productivity and is done during your free time or breaks.

8. Political, Community, and Associative Activities

Employees may, in their free time, participate in political, community, or associative activities. However, it is prohibited to use resources allocated for work to promote or advertise any of these activities within or outside the company. This prohibition also extends to participating in politics using resources for donations or contributions to candidates or political parties without the approval of the company.

9. Integrity Toward the Public

Being an ethical company means conducting business honestly, doing what is right, and respecting the law. PARUMA S.A.S.’s integrity is reflected in:

Relationship with Third Parties

PARUMA S.A.S. believes that having an honest relationship with competitors and other third parties is essential for its existence and success. We must treat all parties with whom we interact with the same integrity and honesty that we expect in return.

Competing fairly with competitors goes beyond avoiding anti-competitive practices. Our employees must respect the work of our competitors, not making, for example, deceptive claims about their products and services.

Trading with Inside Information

Inside information is any non-public information about the business and investments of PARUMA S.A.S., whether it is carried out through the company or the funds it manages, that, if disclosed, could influence an investor’s decision to buy or sell shares of PARUMA S.A.S. or its investors.


We respect applicable legislation and regulations in all the markets where we operate. Therefore, our employees need to be aware of certain obligations related to trading in company shares.


Employees of the company are strictly prohibited from trading in shares when they have inside information that has not been publicly disclosed. They should also refrain from passing on this information to third parties who might use this knowledge for stock trading (known as “tipping”).

For detailed information about our anti-bribery and anti-corruption policy, please refer to this link:


Information that must be provided by PARUMA S.A.S. to the various controlling, inspection, and oversight authorities will be delivered in a timely manner and in a clear, precise manner, always being truthful.

For this reason, all employees who are responsible for preparing this information must ensure that it is truthful and in compliance with the legislation and internal controls applicable within the company.

10. Conflicts of Interest

All employees must avoid conflicts of interest, which can arise when they are involved, directly or indirectly, in situations that could influence or appear to influence their professional decisions.

Examples of situations in which a conflict of interest may arise include:

  • Working for another company, which affects performance at PARUMA S.A.S., or using resources provided by the company in another job.
  • Having a personal financial investment with a client, competitor, or another related company and using one’s position at PARUMA S.A.S. to favor them.
  • Recommending clients or suppliers with some degree of relationship to company employees.

Situational Example: In addition to the work I do for PARUMA S.A.S., I am a school or university teacher. Could there be a conflict of interest?

No, as long as you do not disclose confidential information from PARUMA S.A.S. in your classes. However, this activity should not affect your performance at the company, meaning that class preparation should be done at a different time from your work at PARUMA S.A.S. You also cannot use the company’s resources for teaching activities without prior authorization.

11. Gifts, Favours, and Donations

Within our company, it is prohibited to use resources or assets to provide benefits or make illegal or inappropriate payments (such as donations) to customers, government representatives, or other third parties.

This prohibition is in place to prevent bribery, the improper collection of money, or any other type of benefit in exchange for an undue advantage. It’s important for all employees to be aware that any illegal or improper payments, as described above, can not only damage the company’s reputation but also result in civil and criminal liability for both PARUMA S.A.S. and the individuals involved.

Gifts are allowed when they are meant to strengthen relationships with customers and suppliers, as long as they don’t create a sense of obligation in the recipient. This means that gifts should not be given with the expectation of receiving something in return.

When is a gift appropriate?

A gift is appropriate when its value is moderate, typically bears the corporate brand, is distributed without preferences and on special occasions. These may include consumable products such as gift baskets, chocolates, candies, or beverages, as long as they meet the criteria mentioned above.

For more details about our anti-bribery and anti-corruption policy, please refer to this link:

12. Economic, Social, and Environmental Sustainability

PARUMA S.A.S. is committed to being a responsible company and promotes economic, social, and environmental sustainability through corresponding actions.

The company will work towards promoting the adoption and compliance with practices and behaviors that respect human rights and combat corruption, in line with international treaties. This includes supporting the achievement of development goals that are aligned with the company’s nature, with special emphasis on:

  • SDG5: Gender Equality: The company aims to provide all employees, including the community, with equal opportunities for personal growth and participation in business-related activities. This can be achieved through open job promotion announcements or voluntary participation in community projects.
  • SDG10: Reduced Inequalities: The company aims to democratize the possibility of receiving rewards for executed projects, which helps reduce inequalities that people in the community might face due to a lack of opportunities.
  • SDG12: Responsible Consumption and Production: PARUMA promotes sustainable consumption by partnering with environmentally-friendly companies. For instance, it collaborates with Fokus Green, a supplier of raw materials and finished products in PET for making clothing. This clothing can be purchased by Crowdters by exchanging rewards points earned for project execution, contributing to environmental sustainability in daily life. The company also shares tips through its platforms to raise awareness about responsible consumption and proper waste management within the community.
Questions and Non-Compliance

It’s crucial for PARUMA S.A.S. that employees with questions about the application of this Code communicate them to the responsible department. This way, guidance can be provided, and corrections can be made if necessary. The primary recommendation is for employees to address their questions and concerns internally, either with their immediate supervisor or the human resources department.


The provisions contained in this code are mandatory. Non-compliance can result in disciplinary proceedings and, consequently, the application of disciplinary measures outlined in the Internal Work Regulations, without prejudice to any legal responsibilities that may apply.


Employees should note that this code does not cover all possible questionable work-related behaviors. Therefore, any other behavior by an employee that may be questionable under the terms of this code or the Internal Work Regulations may lead to the application of disciplinary measures, always guided by common sense and applicable legislation regulating the matter.

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