From policy to practice: Embedding compliance, ethics and anti-corruption at scale
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1. Company at a Glance
Cementos Progreso’s compliance journey is grounded in the belief that ethical conduct, transparency and accountability are essential to long-term business resilience—particularly in environments where corruption risks are high. Over the past decade, the company has transformed compliance from a fragmented control function into a strategic pillar embedded across governance, operations and growth decisions.
What began as a response to internal and external risk evolved into a robust, certified compliance system aligned with international standards. Today, compliance supports business continuity, investor confidence and a strong speak-up culture across multiple geographies.
Construction, concrete, construction materials and aggregates
Industry
1899
Founded
Guatemala
Headquarters
4000+
Number of Employees
Guatemala, Belize, El Salvador, Honduras, Costa Rica, Panamá, Colombia and Dominican Republic
Global Presence
2. The Challenge
Building trust and resilience in a high-corruption context
Operating primarily in Guatemala and expanding across Latin America, Cementos Progreso faces heightened exposure to corruption, bribery and ethical misconduct. As a family-owned company of more than 125 yeas of existence, with rotating board membership and growing regional complexity, early compliance efforts were met with skepticism and cultural resistance.
Compliance was initially perceived as a “check-the-box” requirement rather than a value-adding function. Limited awareness, inconsistent risk management practices and decentralized operations made it difficult to implement uniform standards across business units and regions.
At the same time, acquisitions and growth ambitions increased the need for stronger governance, transparency and risk mitigation. Cementos Progreso recognized that sustainable growth would require embedding compliance deeply into the company’s culture, systems and decision-making processes.
3. The Action
From basic controls to a robust compliance system
SECURING BOARD AND EXECUTIVE-LEVEL COMMITMENT
One of the most critical turning points was strong and sustained support from the Board of Directors and senior leadership. A change in CEO enabled the compliance function to gain visibility, authority and strategic relevance. Board endorsement helped reposition compliance as a mechanism to protect and strengthen the company rather than constrain it.
ESTABLISHING STRUCTURE, DATA AND BENCHMARKING
Cementos Progreso focused on building a structured compliance framework supported by data collection and benchmarking. The compliance team began systematically tracking incidents, concerns and risk indicators, allowing the company to compare progress over time and across areas. This data-driven approach enabled continuous improvement and alignment with international best practices.
STRENGTHENING ETHICS, TRAINING AND AWARENESS
Communication and training became central to building a culture of integrity. The company introduced ongoing ethics and compliance training, operational-level engagement, creative awareness activities and a dedicated compliance month. As awareness increased, so did employee willingness to speak up— signaling growing trust in the system.
IMPLEMENTING ENTERPRISE RISK MANAGEMENT (ERM)
Cementos Progreso introduced risk matrices across all business areas to identify inherent risks, define controls and assign ownership. While early resistance was common, accountability gradually became embedded. Internal audits assess the effectiveness of controls and identify gaps, ensuring that risk management is actively used rather than treated as a formality.
INSTITUTIONALIZING WHISTLEBLOWING AND INVESTIGATIONS
A robust speak-up system was implemented, supported by strict confidentiality and zero-tolerance non-retaliation policies. Complaints are managed through a centralized investigation team and reviewed by regional and corporate compliance committees. Cases are classified by risk level, escalated when necessary and closed with defined consequences and corrective actions.
STRENGTHENING ANTI-BRIBERY SYSTEMS THROUGH ISO 37001
To further reinforce credibility and rigor, Cementos Progreso pursued ISO 37001 certification for its Anti- Bribery Management System. Internal audits, cross-functional auditors and external certification audits— including board and C-suite interviews—helped strengthen internal discipline, improve preparedness and build investor and stakeholder trust.
4. Overcoming Barriers
Cultural Resistance
Early efforts faced resistance from leadership and employees who viewed compliance as disruptive. This was addressed by reframing compliance as a tool to protect the company, strengthen culture and support long-term value creation.
Operational Complexity Across Regions
Managing compliance across multiple countries and business lines introduced coordination challenges. Cementos Progreso established regional compliance committees aligned with a centralized corporate structure to ensure consistency and local relevance.
Building Trust in Speak-Up Mechanisms
Encouraging employees to report concerns required time and credibility. Strict enforcement of confidentiality and non-retaliation policies gradually increased reporting and trust.
5. Impacts & Results
7,845 hours of ethics and anti-corruption training delivered in 2024 (+23.4% vs 2023).
US$54,860 invested in ethics and anti-corruption training in 2024.
Women represented 21% of people trained in 2024 (while representing 18% of the workforce), indicating broader participation across the organization.
In 2025, 124 reports were accepted for investigation work in all the operations within all the regions; in 31 of those cases (40%) with employee involvement.
Where wrongdoing was confirmed, the company applied sanctions: 58% of cases resulted in termination and 42% in formal warnings recorded in the employee file.
6 reports related to corruption, fraud and bribery were received in 2024, down from 9 in 2023 (a 33% reduction).
67% of these reports were anonymous in 2024 (notably higher than prior years).
The average time to resolve corruption, fraud and bribery reports decreased from 32 days in 2023 to 3 days in 2024.
6. Key Lessons Learned
Leadership commitment is non-negotiable
Compliance only scales when the Board and CEO visibly support it.
Compliance must enable business, not restrict it
Positioning compliance as a growth enabler increases adoption and cultural alignment.
Speak-up cultures require trust and zero retaliation
Confidentiality and consistent enforcement are essential to credibility.
Data and audits drive continuous improvement
Measurement, benchmarking and certification strengthen discipline and transparency.
Embedding compliance takes time
Cultural change requires persistence, structure and long-term commitment.
"At the beginning, people were fighting process. You have to start by having your matrix and analyzing your risks and understanding what inherent risk means.”
Christie Ippisch, Compliance Officer
7. Company Commitment
Cementos Progreso is a committed participant of the UN Global Compact since 2011 and an active member of the UN Global Compact Think Lab, on Business Integrity and the UN Global Compact & UNODC COSP Private Sector Platform.
8. Recommended Resources
Recommended UN Global Compact Resources
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Disclaimer: This case example is intended strictly for learning purposes and does not constitute an endorsement of the individual companies by the UN Global Compact.