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Anticorruption Plan

Medellin Metro System, as a state entity, complies with the National Government's anti-corruption guidelines, in compliance with the provisions of Decree 2641 of 2012, which regulates Articles 73 and 76 of Law 1474 of 2011, "through which rules are issued to strengthen the mechanisms for the prevention, investigation and punishment of acts of corruption and the effectiveness of public management control".

Based on the methodology "Strategies for the Construction of the Anti-Corruption and Citizen Service Plan" designed by the Transparency Secretariat of the Presidency of the Republic, which must be implemented by all national, departmental and municipal entities, METRO created its Anti-Corruption Plan.

Resolution 8050 of 2015 adopts the Anti-Fraud and Anti-Corruption Policy of Metro de Medellín and additionally modifies Resolution 5266 of 2009 by which the public policy of administrative transparency and probity was adopted in accordance with Municipal Agreement No. 65 of 2008.


Get to know our Fraud Risk Matrix

The Company permanently manages its risks, with the purpose of defining the necessary measures that seek to minimize them, thus seeking the Company's permanence in the market, the continuity of the operation, the maintenance of its good image and good relations with its stakeholders, avoiding damage to the environment, protecting the life and integrity of its employees and users, ensuring that its actions are carried out within the legal regulations and adopting risk management policies that help to comply with the Mega and the Company's objectives.

Particularly with regard to corruption risks, the Company, in a preventive manner, and being aware that any activity performed by human beings is exposed to risks of various kinds, evaluates which potential risk events may occur in terms of corruption, identifying the following:



Risk Name Risk Description Processes most exposed to risk



Improper conclusion of contracts

  • Possibility of violation of the legal or constitutional regime of disqualifications and incompatibilities by employees involved in the processing, approval or execution of a contract.
  • Possibility of processing, entering into or settling contracts without the legal requirements or directing contracting in favor of a third party. All of the above in order to obtain an illicit benefit for the employee, contractor or third party.
  • Management of the supply of goods and services.
  • I+D+i Management
  • Project management




Bribery *


  • Possibility that an employee or contractor acting on behalf of the company requests or receives gifts in order to carry out activities, delay or illegitimately omit an act proper to their position, and offer a gift for the performance, delay or omission of the activities of other national and international public employees, authorities or individuals.
  • Management of the supply of goods and services.
  • I+D+i Manegement
  • Project management
  • Business structuring and management






  • Possibility of unlawful appropriation or improper use by employees of assets whose administration or custody has been entrusted to them by virtue of their position in order to obtain a benefit for themselves or for a third party.
  • Management of the supply of goods and services.
  • Financial and accounting management
  • Maintenance management
  • Project management
  • Customer service management
Misuse of information
  • Possibility of disclosing inside information to third parties in order to obtain an illicit benefit for oneself or for a third party.
  • Business planning


Influence peddling

  • Possibility that an employee or public servant makes improper use of the influence derived from his position or connections with persons with influence, in order to obtain from another public servant any type of benefit for himself or for a third party Management supply of goods and services.
  • I+D+i Management
  • Project management
  • Human Talent Management

Undue pressures
  • Possibility of using mechanisms such as force or coercion on one or more employees or servants to act in an unlawful or unfair manner.
  • Todos los procesos