Sigue has an international dimension and strives to comply with the practices of financial institutions regarding corporate governance in all of the countries in which it operates.
The essential principle of Sigue's governance structure is a strong Board of Directors (“Board”) charged with providing guidance and oversight to the Company’s management in conducting the business affairs of the Company.
To facilitate its role and ensure it meets its objectives, the Board has established four committees.
These are the Audit and Finance Committee, the Technology Steering Committee, the Compensation & Succession Committee, and the Governance & Nominating Committee. These Committees assist the Board with its periodic review of the institution's strategies and policies related to risk among others.
The ultimate goal of the governance structure is to ensure the effective and appropriate management of the Company.
These strong ethical principles govern the conflicts that might arise between the interests of employees and those of Sigue and its stakeholders. Additionally, these principles cover the questions or circumstances that create conflicts of interests.
Therefore, employees must notify the Company of any direct or indirect conflict that might exist with the Company's interests. This applies to any interest the employee may have in a company whose activities are the same, similar or complementary with those of Sigue.
Additionally, these principles apply to the same, similar or complementary activities as those of the Company when performed on their own behalf or on behalf of a third party. Following are the key provisions of Sigue’s Code of Conduct and Ethics:
It is the policy of the Company to maintain the highest standards of professional and ethical conduct. Customer, agent, community, shareholder and employee confidence is the foundation of Sigue Corporation’s continued growth and success. This confidence is based on trust, a trust that we must continue to earn each day.
We are committed to acting honestly in carrying out our professional responsibilities. It is not enough merely to do what is legal; we must do what is right. At times, the proper course of action may be unclear.
Employees are encouraged to discuss such issues with their immediate supervisor, the Company’s internal legal counsel, or a member of the Human Resources Department, knowing that management will assure a safe environment for any employee who seeks guidance in make the right ethical judgment.
The Company’s Code of Conduct provides a standard by which we can measure our personal and professional conduct. It has been designed to help all employees deal with the complex situations that may be encountered.
Since it is impossible to anticipate all of the many circumstances that may be covered by such a code, employees should be continually sensitive to the fact that actions, as viewed by disinterested observers, are subject to close security and critical interpretation.
Even the appearance of a conflict of interest may be damaging to the employee and to the organization. Violation of this Code of Conduct will be considered a serious matter and may be considered grounds for termination of employment.
During the course of their work, employees may become aware of confidential information about the Company, customers, employees, agents, and vendors. Such information is privileged and must be held in the strictest of confidence.
It is to be used solely for corporate purposes and never for personal gain by the employee. Under no circumstances should such information be transmitted to persons outside the corporation, including family or other employees of the Company unless they need to know in order to discharge their responsibilities.
Employees must promptly notify their immediate supervisor of any employee suspected of committing a dishonest or fraudulent act. The Human Resources Department must also be notified of evidence discovered which suggests that a crime has been committed.
The Company is required by law to report violations of criminal laws to state and/or federal law enforcement agencies. Dishonest and fraudulent acts of employees are crimes under federal and state law and may be punishable by fines and/or imprisonment. Examples of activities prohibited by law include:
Concealing, stealing, embezzling or misapplying corporate funds or assets.
Using threats, physical force or other unauthorized means to collect money.
Using a computer to gain unauthorized access to the records of an employee, visitor, customer, agent or vendor.
Falsification, unauthorized modification, destruction, theft or removal (without authorization) of Company documents.
Theft, destruction, or unauthorized modification or removal of any Company property or property belonging to another employee, a customer, agent or vendor.
Aiding others in dishonest or inappropriate conduct either before or after the fact.
Directors or Officers in Outside Companies
No employee of the Company is allowed to serve as an officer or director of an outside business organization, except in exceptional circumstances and then only upon prior written approval of the President of Sigue Corporation agents.
Employees are trained in anti-money laundering and anti-terrorist financing upon employment by the Company and on an annual basis thereafter. Further, those employees with direct agent contact, in addition to those employees working in the operational and internal control areas of the institution, receive enhanced anti-money laundering and anti-terrorist financing training on a periodic basis.
Similarly, those employees working as agent relationship managers, compliance agent trainers and internal reviewers, receive additional, specialized, anti-money laundering and anti-terrorist financing training.
SIGUE ’s compliance function includes a group of employees dedicated to training and reviewing agent compliance programs.
Agents are trained in anti-money laundering and anti-terrorist financing upon being activated as an agent. Agents also receive periodic enhanced training for the purpose of ensuring their awareness of current issues in the anti-money laundering and anti-terrorist financing environment, as well as to reinforce their knowledge concerning SIGUE’s policies and procedures.
Additionally, agent compliance programs are periodically reviewed and tested using a risk-based selection to assure compliance with SIGUE’s anti-money laundering and anti-terrorist financing policies, as well as applicable laws, rules and regulations.
SIGUE approaches monitoring from a risk-based perspective and develops control s to detect and prevent money laundering activity. SIGUE program consists of layers of controls which include front-end and back-end monitoring designed to interdict transactions that, based on internally and externally developed criteria
Additionally, SIGUE conducts extensive “backend monitoring” of transactions that facilitates timely and accurate filing of suspicious transaction reports, large cash transaction reports, and terrorist property reports as required by applicable laws, rules, and regulations. All reports filed, along with supporting documentation, are maintained for at least five years.
Generally, the monitoring of consumer transaction activity is based on the identification of suspect activity, such as high numbers or amounts of transactions, structuring of transactions, concentration and disbursement of transactions and fund flows to/from high-risk countries.
Agent monitoring addresses activity that presents a likelihood of collusion among agents and/or agents and consumers.
Following identification of unusual activity SIGUE endeavors to:
Conduct investigations pursuant to established procedures to evaluate the entirety of the consumer’s activity and the potential for agent complicity, in addition to formally document the matter.
File appropriate regulatory reports.
Make and implement decisions to maintain or terminate the financial relationship in accord with internal policy or applicable law.
Subsequent to the events of September 11, 2001, denying financial system access to the criminal and terrorist elements in our society has become an even greater concern and importance.
SIGUE recognizes its duty and responsibility as an active participant of the global cooperative against terrorism and criminal financing, and filters millions of transactions each year against relevant sanctions lists in its commitment to meet this obligation.
Internal Audit is responsible for independently reviewing and verifying the compliance of SIGUE’s business units with the business-wide anti-money laundering and anti-terrorist financing policies and underlying procedures.
The AML-ATF Program has been defined as a high priority by Sigue and is, therefore, subject to annual audits. Sigue also contracts with an independent outside firm to conduct reviews of its AML and Compliance function on an annual basis.
Commitment to Privacy
Sigue Corporation and its domestic and international subsidiaries and affiliate companies (Collectively “Sigue”) understand the importance of protecting your privacy.
Sigue values your trust and is committed to protecting and safeguarding “confidential non-public” information (“NPI”), in accordance to the industry’s best practices and applicable state, federal and international laws. Below is a description of the types of information obtained, how it is used, and how it is protected.
Collection and Use of Information
Sigue collects NPI in order to conduct business for which non-public information is otherwise necessary to execute, administer or enforce transactions.
Additionally, such information assists Sigue in providing you with a higher quality of products and services and a prompt response to your financial services’ needs and inquiries. Sigue collects non-public personal information from a variety of sources, which may include:
Transaction applications, questionnaires and other forms;
Prospective Agent Applications and other forms;
Transactions with Sigue Corporation & Related Companies; and
Consumer and Information reporting agencies, as appropriate.
Sharing Information with Third Parties
Sigue only discloses non-public personal information to related companies and non-affiliated third parties when the same is necessary to execute, administer or enforce transactions in connection with the operating and processing of a financial product or service authorized or requested by you.
Sigue does not disclose information about you or your transaction history, nor about former consumers or former agents to non-affiliated third parties for their independent use unless:
The consumer or agent has authorized disclosure;
The information is provided as part of a transaction initiated by consumer or agent;
The disclosure otherwise is lawfully permitted or required.
Right to Financial Privacy Act
The Right to Financial Privacy Act (RFPA) imposes limitations on the authority of government agencies to acquire records of individual’s financial transactions. No government authority may obtain copies of or have information containing the financial records of any customer from a financial institution unless provided for under the exceptions of rule RFPA, 1978, 12 USC § 3410 et seq.
Security of Information
The security of your non-public information is a top priority for Sigue. NPI is protected by maintaining physical, electronic and procedural safeguards that meet or exceed the requirements of applicable law. NPI is restricted to those employees who need to have access to the information in order to provide you with products or services or when required to respond to a legal request.
Employees are trained in the proper handling of NPI and must adhere to Sigue privacy policies. Employees who violate these policies are subject to disciplinary action, up to and including termination. Third Party Vendors or contractors that are engaged in order to effect transactions are subject to contractual requirements to ensure that sensitive personal NPI is safeguarded.
Sigue reserves the right to modify this Policy at any time. If you have any questions regarding this Policy, please contact Sigue Corporation at 1-800-385-3316 or via mail at 13291 Ralston Avenue Sylmar, CA 91342
Servicios Financieros Latinoamericanos, S. A. de C.V., con domicilio en Av. Presidente Masaryk No. 111, 1º piso, México, D.F., en concordancia con el Consentimiento otorgado para el tratamiento de sus Datos Personales, aun los Sensibles, patrimoniales y/o financieros, le comunicamos que los mismos serán tratados bajo métodos y procedimientos de seguridad y privacidad a fin de poder formalizar y desarrollar cabalmente la relación jurídica que tenemos celebrada o por celebrar, pero sin que se vea afectada la seguridad de sus Datos Personales, relación que puede ser de carácter laboral, comercial, de servicios, de representación, de colaboración. Esta empresa solamente podrá transferir sus Datos Personales a sus encargados, terceros, incluyendo empresas filiales y/o toda persona física o moral, nacional o extranjera vinculados con esta empresa, para cumplir con los fines acordados en la relación antes mencionada. Las personas que reciban y manejen sus Datos Personales, de igual forma estarán obligadas en los mismos términos del presente aviso.
La Responsable tiene establecida una Solicitud y una guía para el titular a través de la página www.sigue.com , para facilitar al Titular el ejercicio de los derechos de acceso, rectificación, cancelación, oposición o revocación del consentimiento para el tratamiento de sus Datos Personales.
El ejercicio de los derechos de acceso, rectificación, cancelación, oposición, o revocación del consentimiento para el tratamiento de sus datos podrá efectuarse por escrito en el domicilio de esta empresa o a través del correo electrónico protecciondatos@sigue.com, a partir del 6 de enero de 2012, observándose las formalidades establecidas en la Ley Federal de Protección de Datos Personales en Posesión de los Particulares y su Reglamento.
El presente aviso podrá sufrir modificaciones en cualquier tiempo y será dado a conocer a través de la página www.sigue.com y/o por el presente medio, el cual además sirve como medida compensatoria en los términos de la Ley y Reglamento antes referidos.
Passwords
All access to any of the systems under Sigue’s information network is controlled by passwords. These passwords are
required to be changed by the user periodically. Only a systems administrator has the ability to add users to the information
network. This person ensures only authorized users are given access to the network. Certain key application systems
require a further level of password authorization.
Government Requests for Data
Sigue supports the efforts of government to prevent illegal activities. Sigue provides consumer information as requested by
government representatives only upon presentation of proper government requests as outlined by the law.
Physical Security of Data
Sigue maintains its data on servers. Currently, these servers are located in the Company’s data centers. The servers are
located in a secured facility that can only be accessed by authorized personnel. When data files are stored off-site, Sigue
verifies that the off-site vendor maintains security over the data.
Agent Files
Sigue maintains files of its agents which can only be accessed by authorized personnel.
Employee Training
A key component of information security is employee training. Our operator training emphasizes that consumer data
is confidential. Our Compliance training for all employees emphasizes that Suspicious Activity Report (“SAR”) data is
confidential.
Document Shredding
Sigue utilizes a shredding service for the safe destruction of sensitive documents, including those with consumer data.
ALASKA
Notice to our Alaska Remitters
Consumer Notice: If you have complaints with respect to any of the money transmission activities conducted at any Alaska Sigue agent location, you
may contact the State of Alaska, Division of Banking & Securities, 550 W. 7th Avenue, Suite 1850 Anchorage, Alaska 99501, (907) 269-4584.
ARKANSAS
Notice to our Arkansas Remitters
Consumer Notice: If you have complaints with respect to any of the money transmission activities conducted at any Arkansas Sigue agent location,
you may contact the Arkansas Securities Department, Heritage West Building, Suite 300 201 East Markham Street Little Rock, Arkansas 72201-1692,
Telephone: (501) 324-9260.
CALIFORNIA
Notice to our California Remitters
Consumer Notice: If you have complaints with respect to any aspect of the money transmission activities conducted at any California Sigue agent
location, you may contact the California Department of Financial Institutions at its toll-free telephone number, 1-800-622-0620, by e-mail at
consumer.complaint@dfi.ca.gov, or by mail at Department of Financial Institutions, Consumer Services, 1810 13th Street, Sacramento, CA 95811.
COLORADO
Notice to our Colorado Remitters
Consumer Notice: Entities other than FDIC-insured financial institutions that conduct money transmission activities in Colorado, including the sale
of money orders, transfer of funds, and other instruments for the payment of money or credit are required to be licensed by the Colorado Division
of Banking pursuant to the Money Transmitters Act, Title 12, Article 52, Colorado Revised Statutes. If there are questions or concerns regarding a
transaction with Sigue, please contact the Colorado Division of Banking at 303-894-7575 or by mail at: Colorado Division of Banking, 1560 Broadway,
Suite 975, Denver, Colorado 80202
Consumer complaints should be in writing, providing as much detail as possible. Please include the following information:
• The name of the institution and the name of any person(s) at the institution with whom the complainant has had contact. Include telephone
number(s) and addresses.
• A complete description of the complaint and any efforts that have been made to resolve the complaint directly with the institution.
• Copies of any available documentation supporting the complaint and efforts toward resolution.
• Any suggestions regarding a preferred resolution of the complaint.
FLORIDA
Notice to our Florida Remitters
Consumer Notice: If you have complaints with respect to any aspect of the money transmission activities conducted at any Florida Sigue agent location, you
may contact the division of consumer services of the Florida Department of Financial Services at 200 East Gaines Street, Tallahassee FL 32399, telephone: 1-
877-693-5236.
GEORGIA
Notice to our Georgia Remitters
Sigue Corporation is licensed by the Georgia Department of Banking & Finance. Money transmission activity is licensed under the Georgia Sale of Checks Act
ILLINOIS
Notice to our Florida Remitters
Consumer Notice: Sigue Corporation holds License #80, authorized under the Illinois Money Transmitter Act, 205 ILCS 657. For customer support regarding
suspected violations of this act please contact the Illinois Department of Financial Institutions, Consumer Credit Division - toll free (888) 298-8089.
MARYLAND
Notice to our Maryland Remitters
Consumer Notice: The Commissioner Of Financial Regulation For The State Of Maryland will accept all questions or complaints regarding Sigue Corporation
License # 9069, NMLS #915912 (or agents in Illinois offering service on behalf of Sigue) at 500 North Calvert Street, Room 402, Baltimore, Maryland 21202,
Phone Number 888-784-0136.
NEW YORK
Notice to our New York Remitters
Consumer Notice: Sigue Corporation, located at 13291 Ralston Ave., Sylmar, CA91342, is licensed as a Money Transmitter by the Banking Department
of the State of New York. For questions and/or to register complaints, contact Sigue at (800) 385-3316. Mail any unresolved complaints to: Consumer
Services Division of the New York State Department of Financial Services, One State Street, New York, NY 10004-1511
NORTH CAROLINA
Notice to our North Carolina Remitters
Consumer Notice: Money transmission on behalf of Sigue Corporation is conducted pursuant to the Money Transmitter’s Act.
OKLAHOMA
Notice to our Oklahoma Remitters
Consumer Notice: Upon filing an individual income tax return with either a valid social security number or a valid taxpayer identification number, you are
entitled to an income tax credit equal to the amount of the fee paid for your wire transaction.
PENNSYLVANIA
Notice to our Pennsylvania Remitters
Consumer Notice: Sigue Corporation is licensed to Transmit Money by the Department of Banking, Commonwealth of Pennsylvania.
RHODE ISLAND
Notice to our Rhode Island Remitters
Consumer Notice: Sigue Corporation is authorized do to business in Rhode Island as a Licensed Money Transfer company.
TEXAS
Notice to our Texas Remitters
Consumer Notice: Sigue Corporation is licensed under the laws of the State of Texas and by state law is subject to regulatory oversight by the Texas
Department of Banking. Any customer wishing to file a complaint against Sigue Corporation should contact Sigue Corporation directly at (877) 624-1487.
After first contacting Sigue, if you still have an unresolved complaint regarding the company’s money transmission activity, please direct your complaint to
the Texas Department of Banking, 2601 North Lamar Blvd., Austin, TX 78705, Telephone: 1(877) 276-5554
Fax: 512-475-1313, E-mail: consumer.complaints@dob.texas.gov, Website: www.dob.texas.gov.
Sigue Corporation, All rights reserved
Language