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Code of ethics

1. Scope

The main purpose of this ethics code is to promote and advocate a series of corporate values and principles that promote the development of healthy and sustainable relationships of trust between all employees, senior management, suppliers, shareholders, customers, and in general with all those who we have a relationship with.

This code must cover all employees, senior management, and suppliers, regardless of their position or geographical location, and must be understood and applied to promote exemplary conduct and behaviors within the company.

2. Ceiba Fundamentals

At Ceiba, we generate ideas and solutions to improve our client’s business. Relationships between employees, management, suppliers, shareholders, clients, and other stakeholders are guided by the values of human dignity and mutual respect. We act in accordance with the law and with absolute transparency when it comes to our work and our relationship with clients. We work as a team with our clients to provide them with a solution that meets their needs. Furthermore, we expect all our employees, regardless of their position, to act consistent with our company principles and values, contributing to our mission and objectives.  


At Ceiba, we work with passion to transform our client’s businesses, helping them become more successful through the use of technology and innovation.


We aim to be the company that clients and best talents want to work with.


  • We generate ideas and solutions.
  • We value our employees and their families. 
  • We value continuous learning.
  • We work as a team with our clients transparently.
  • Our priority is to improve our client’s business.



We act in accordance with how we think and feel, adequately expressing any disagreement or discrepancy and always respecting the recipient of the message.


No one should be discriminated based on their gender, race, national or family origin, language, religion, political or philosophical opinion.

In relations between employees, members of senior management, suppliers, and shareholders, a cordial treatment will prevail, regardless of their relationship with the company.


All actions taken by Ceiba will be carried out lawfully. Likewise, we seek to motivate everyone who has a relationship with Ceiba, to ensure that their actions correspond to the current legal framework.


We make conscious decisions and assume responsibility for those decisions while responding to inquiries at all times. Additionally, it is our priority to fully comply with those commitments already assumed by Ceiba, always seeking customer satisfaction.


 Treating everyone with respect and appreciation. 


At Ceiba, we mobilize towards the same objective, taking advantage of individual capacities, understanding and accepting different personalities and characters. We strive to foster an environment of collaboration among all actors.

3. General rules of conduct

Proper use of information:

All company employees must handle the information they have access to, with care and a sensible conduct, guaranteeing confidentiality following company policies and employment contracts.

Presents, benefits, and invitations:

To prevent corruption, bribery, and conflict of interest, employees cannot use their power to obtain benefits for themselves, their families, friends or third parties. This implies that presents or benefits received or offered must be authorized by their manager. In no case that amount can exceed $200,000 COP ($50 USD) or its equivalent, and it cannot be ostentatious items.

If any doubts about the nature of a gift or service, employees can consult  the Ethics Committee staff.

Conflicts of interest:

All employees must be loyal to third parties, treat them fairly, and on equal terms. 

The following situations will be subject to review to determine if there is a conflict of interest:

  • Carry out commercial negotiations with a delegated client or prospect where there is a consanguinity or sentimental link that may interfere in decisions.
  • Choice of suppliers or contractors in which there is a consanguinity or sentimental link that may interfere in decisions.
  • Participation in a productive project in which there is a consanguinity or sentimental link with the assigned person in charge by the client that may interfere in decisions or actions undertaken.

Free competition:

 Ceiba is committed to generating value propositions to clients within the company’s operational capabilities. It does not participate in activities seen as unfair competition, nor participate in monopolies and restrictive trade practices that would affect the dynamics of the sector.

In general, within the principles of economic competition, it is prohibited to:

  • Using discounts, profit margins, cost, or any other mechanism to set prices for products and services.
  • Agreements to limit the production of any good or service.
  • Collective boycotts, such as deciding jointly with a competitor whether to negotiate with any other company.
  • Exchange of commercial information that is not public, or sharing commercially sensitive company secrets and information with the competition. 
  • Promote or execute agreements and acts contrary to free competition.
  • Making agreements for the setting of prices, conditions of sales or commercialization.

Financial information management:

Ceiba is committed to offering real and transparent information about its operations to its shareholders and the market in general. That is why all employees must contribute so that the financial statements, tax returns, and the likes, reflect the real economic facts. This could be done through either reporting of information or the application of controls at the corresponding levels. Similarly, we comply with national laws concerning financial and tax reports to the corresponding entities. We comply with the registration, conservation, and preparation of financial reports under the relevant guidelines.

Asset protection:

All the assets, services, and resources of the company can only be used for commercial activities and should not be used inappropriately or in a way that could affect the company or third parties.

Relationship with customers:

Ceiba is committed to delivering the highest quality service with professionalism and respect. 

Complaints and claims of the clients will be attended according to the means provided by the organization adequately, seeking the satisfaction of client needs fairly.

Fair working conditions:

Ceiba guarantees an equity environment and a fair remuneration. Ceiba ensures the health, safety, dignity, reputation, and integrity of all its employees. Discrimination is not tolerated and diversity, exchange of views, and ideas are encouraged respectfully and constructively.

Occupational safety and health:

Ceiba’s objective is to preserve the life, health, and well-being of employees and third parties.

Money laundering:

 In order to protect Ceiba’s name, commercial relationships that facilitate money laundering, financing of terrorism or other crimes will be avoided. Additionally, no labor or commercial relationship will be initiated with natural or legal persons that are linked to any of the activities listed above. 

Objective internal audit:

Ceiba’s internal auditors must sign a declaration of confidentiality and objectivity that contains good practices and the qualities required for their role. 

The company will ensure that the person(s) is selected according to the profile and appropriate skills to perform the role.

Copyright and intellectual property:

Copyright and intellectual property and that of third parties must be respected and protected. 

Additionally, all the patrimonial rights that fall on the software or on any other copyright enshrined in the Law, developed by the employee, individually, collectively or in collaboration, will be owned by Ceiba and are considered property of this, therefore, neither during the term of the employment contract, nor after its termination, the information related to the software or the software itself, may be used and / or removed from the Ceiba facilities by the employee for their own benefit or that of third parties, without the respective written authorization of the Legal representative of Ceiba.

Selection and hiring:

Ceiba’s hiring process is based on the capacity, experience, and knowledge of the candidates, as well as how they identify with our company values and principles. 

The selection and hiring process is carried out with respect and equality, without creating false expectations for the candidates and complying with the relevant rules and regulations.

IV. Sanctions

Failure to adhere to Ceiba’s ethics code by any of its recipients may result in internal, administrative, or legal sanctions. Employees who do not comply with the code of ethics will face disciplinary action as defined in the employment contract. 

V. Ethics committee

The objective of the ethics committee is to promote ethical management and ensure compliance with the code of ethics within Ceiba. 

The Committee must establish strategies for the dissemination, implementation, and strengthening of the code of ethics as well as evaluating exceptions and cases that may arise.

Who can join the ethics committee?

Should be persons of integrity with a long history in the company. From a functional point of view, different areas should be represented on the committee, and ideally, the number of members should be odd. Additionally, the members should have the training to handle cases from an ethical point of view.

VI. Glossary


Any benefit (financial or not) granted to an employee by a third party or vice versa. This also includes the provision of services or goods at prices below market prices.


It implies benefits such as invitations to consume food, tickets for events, transportation, and lodging.

Conflict of interest:

A conflict of interest is considered any situation in which a person confronts their personal interests with those of society, in personal activities or when dealing with third parties, be they suppliers, contractors, clients or others; in such a way that freedom and independence of decision are affected, due to differences in the motives of those who intervene in the relationship.