Separation of duties
Each subsidiary runs its own P&L. Shared-services decisions are made at the holding level, with a documented authorization matrix.
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Governance
Governance at the holding level exists to keep each subsidiary honest: to its operators, its counterparties, its regulators, and its investors.
Principles
Each subsidiary runs its own P&L. Shared-services decisions are made at the holding level, with a documented authorization matrix.
Every regulatory obligation we take on is tracked in the Cantarell Systems compliance engine. What we file is what we measured.
We operate in jurisdictions where soft expectations exist. We do not. Our anti-corruption standard is bright-line and applies equally to every employee and counterparty.
We collect operational data because we need it to run the business. We do not monetize it, sell it, or share it outside the purposes disclosed to the counterparty that generated it.
Observable compliance
Our Systems subsidiary makes every regulatory obligation trackable and auditable across the group. CRE, SAT, ASEA, EPA, FMCSA, PHMSA: measured, filed, observable.
CRE
MX
SAT
MX
ASEA
MX
EPA
US
FMCSA
US
PHMSA
US
Policies
01
Our code of conduct is the operating baseline for every employee, contractor, and counterparty. It is enforced by the board and reviewed annually.
02
Zero tolerance for bribes, facilitation payments, or inducements. Violations are terminable and reportable.
03
A confidential channel exists for reporting violations. Retaliation against a good-faith reporter is itself a terminable offense.
04
We follow GDPR-equivalent standards for personal data across all jurisdictions, even where the local standard is lower.
Confidential channel
Ethics, compliance, or safety violations: confidential channel with zero tolerance for retaliation.