ME Elecmetal’s elements for the prevention of crimes related to Law 20.393

Comply with regulations and ensure ethical conduct in accordance with international standards.


To this end, and following the enactment in 2009 of the criminal liability law for legal persons in Chile (Law 20.393), ME Elecmetal decided to implement a Crime Prevention Model to comply with the law and ensure that its operations were framed within ethical standards related to the crimes indicated in the law. The law originally established three offenses, which have been gradually increased. These offenses are related to money laundering, financing of terrorism, receiving, bribery and incompatible negotiation, among others.

The designed and developed crime prevention model takes into account various activities and governance or support areas.

There are four areas to monitor and manage the various activities developed:

  1. Audit Committee: composed of three ME Elecemetal Directors, plus two members of management (General Manager and Corporate Finance Manager) and the Internal Audit Manager, who meet on a quarterly basis.
  2. Ethics Committee: composed of two members of the ME Elecmetal management team, specifically the General Manager of South America and the Personnel Manager, plus the Internal Audit Manager. Meetings are held quarterly.
  3. General Administration
  4. Support Administration

Activities managed and monitored in the Model are related to prevention, detection, response and monitoring/updating in relation to workers, customers and suppliers.

In terms of prevention, one of the most relevant activities is the employee training — a mandatory activity that is carried out each year online. Operations and administrative staff participate, with a special focus on supervisory and administrative positions — the latter being those who have the most risks exposure related to the crimes defined in the Law, due to their job responsibilities.

In addition, ME Elecmetal applies a due diligence process with new clients to ensure the nature of their ownership as well as their financial solvency.

Having a robust model to comprehensively address the risks related to the offenses indicated in the law. In addition, this allows ME Elecmetal to work with confidence in case any risk of non-compliance materializes.


Specifically, the ME Elecmetal Model covers: instruments, risk matrix and controls, whistleblower channel, training and governance for its management and monitoring.

Prevention Model

“At ME Elecmetal, business must be conducted within a framework of ethical responsibility, ensuring unrestricted compliance with local laws and regulations and the expectations of our stakeholders,” explains Rodrigo Carreño, Internal Audit Manager for ME Elecmetal.

In October 2022, the certification of the Crime Prevention Model was renewed for two more years.

Work is currently underway for the next certification process.

With respect to the training carried out in 2022, the number of employees trained increased by 7% compared to 2021.

In 2022, we also implemented the electronic form for declaring conflicts of interest through a platform with an external provider, which improves the quantity and quality of information related to conflicts and potential conflicts of interest that ME Elecmetal employees may have.





BH Compliance, follows up on the risk matrices and the controls applied for their mitigation and grants the Crime Prevention Model certification.


B-GRC technically administers the conflict of interest form.


Fundación Generación Empresarial technically manages ME Elecmetal’s Whistleblower Channel.






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