1. Compliance and Transparent Practices Survey in 300 largest companies in Argentina Center for Governance and Transparency Hotel Emperador 4.15.2010 Buenos Aires, Argentina Copyright © 2010 IAE Business School. All rights reserved.

3. Transparent practices in leading companies in Argentina – Quantitative study Online, phone interviews Method 104 cases Sample 300 largest companies by revenue in Argentina . Universe November 23, 2009 – February 12, 2010 Date IPSOS - Mora y Araujo Survey conducted by

4. Sample structure (I) Number of companies by business sectors Ownership Base: 104 cases. Source: Survey “Transparent Practices in Argentina” - Ipsos Mora y Araujo

5. Sample structure (II) Type of company Base: 104 cases. Source: Survey “Transparent Practices in Argentina” - Ipsos Mora y Araujo

6. Opinion on Compliance and Transparency

7. Importance of Compliance In your opinion, how important is the issue of compliance for competing in Argentina? In the industry In the company 81% 19% 73% 27% Base: 104 cases. Source: Survey “Transparent Practices in Argentina” – Ipsos Mora y Araujo Very Important Important Barely important Not important

8. Indicators

9. Elements of Compliance Existence of a formalized code of conduct Training Specific audits Existence of hotlines for whistleblowers Existence of help hotlines Existence of a formalized, comprehensive compliance program Existence of role of Compliance Officer 74% 65% 61% 56% 49% 48% 38% Source: Survey “Transparent Practices in Argentina” - Ipsos Mora y Araujo 98% 68% 94% 70% 82% 84%

10. Source: Survey “Transparent Practices in Argentina” - Ipsos Mora y Araujo 0 to 2 elements 3 to 4 elements 5 to 7 elements 34% 17% 49% ¿Which elements are in place? Formalized code of conduct Yes (83%) Formalized compliance program Yes (3%) Yes (22%) Yes (88%) Compliance Officer Yes (0%) Yes (11%) Yes (73%) Training Yes (17%) Yes (72%) Help hotlines Yes (6%) Yes (44%) Yes (80%) Hotlines for whistleblowers Yes (6%) Yes (50%) Yes (92%) Specific Audits Yes (14%) Yes(72%) Distribution of Compliance elements amongst companies Yes (88%) Yes (100%) Yes (96%) Yes (31%)

11. Aspects of Compliance Programs Identify the main aspects included in your company’s program Base: Business firms with a formalized program (50 cases) – Source: Survey “Transparent practices in Argentina” – Ipsos Mora y Araujo Compliance programs by year of introduction Aspects Business Ethics/Codes of Conduct/Transparent Practices Finance/Accounting transparency 24% 18% Health-, security-, and environment-related policies 16% Third party relationships 16% Compliance with internal and external norms 12% Conflicts of interests 18% Fraud policy/Illegal payments 10% Information confidentiality and privacy 10% Internal control/Personal conduct/Protection of company assets 14% Business risk 8% Good business practices 8%

12. Role of Compliance Officer Base: 104 cases - Source : Survey “Transparent practices in Argentina” – Ipsos Mora y Araujo ) No 60% Don’t Know Existence of Compliance Officer Yes 38% 2% Full-time/Part-time Compliance Officer Base: Business firms with a Compliance Officer (39 cases) Part-time Full-time 38% 62%

13. Responsibilities of a Compliance Officer Responsibilities To whom reports the Compliance Officer Which are the three main activities the Compliance Officer is responsible for in your company? Base: Companies with a Compliance Officer (39 cases) Source: Survey “Transparent practices in Argentina” - Ipsos Mora y Araujo Compliance with internal and external norms Audits / internal control 24% 22% Code of conduct compliance 21% Offer practical information and training on code of conduct. 21% Disseminate the compliance program’s goals 18% Report on unethical behavior 13% Identify operational risks 11% Lead all compliance-related initiatives 9% Review of norms and guidelines 8% Compliance program execution 10%

14. Impact of the Compliance Officer How much impact would you say the Compliance/Ethics Officer has in your organization? Base: Companies with a Compliance Officer (39 cases) Source: Survey “Transparent practices in Argentina” – Ipsos Mora y Araujo 90% 10%

15. Cooperation amongst Compliance Officers To what extent is the cooperation amongst Compliance Officers from different companies relevant? It is… Base: Companies with a Compliance Officer (39 cases) Source: Survey “Transparent practices in Argentina” – Ipsos Mora y Araujo 80% 20%

16. Training in codes of conduct and transparent business policies

17. Training in Business Ethics Do you develop or have developed training for employees concerning your company’s business ethics and transparency policies? Base: (104 cases) – Source: Survey “Transparent practices in Argentina” – Ipsos Mora y Araujo Base: Companies that have in place training programs (68 cases) Training development Have the trainings been performed face-to-face or online? Types of Training Yes No 65% 34% Don’t know 1% Face-to-face Internet Both 29% 22% 49%

18. Unethical behavior and risk assessments To what extent would you say that unethical behaviors fall within the scope of your company’s risk assessment processes? Base: 104 cases. Source: Survey “Transparent practices in Argentina” – Ipsos Mora y Araujo 76% 24% 40% 17% 16% Number of elements 5 to 7 3 to 4 0 to 2

19. Integrity Pacts Do you know or are you aware of the existence and implementation of integrity pacts? Base: 104 cases. Source: Survey “Transparent practices in Argentina” – Ipsos Mora y Araujo Knowledge of the Instrument Yes No 18% 79% Don’t Know 3%

20. How to improve Compliance Programs Which of the following are for you the three most important issues to improve the development of compliance practices in Argentina? Base: 104 cases. Source: Survey “Transparent practices in Argentina” – Ipsos Mora y Araujo 67 5 to 7 elements 45 5 to 7 elements

21. Analysis and conclusions

25. Center for Governance and Transparency Professors: Matthias Kleinhempel Lorenzo Preve Fernando Zerboni Coordinator: Gabriel Cecchini IAE Business School – Austral University Campus Pilar - Buenos Aires - Argentina Contact: [email_address] / www.iae.edu.ar/transparencia