Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Therefore, effective control over financial reporting cannot, and does not, provide absolute assurance of achieving our control objectives. Also, projections of, and any evaluation of effectiveness of the internal controls in future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.
Under the supervision and with the participation of our management, including our Chief Executive Officer, our Chief Financial Officer, and our Director of Legal and Governance, we conducted an evaluation of the effectiveness of our internal control over financial reporting as of December 31, 2021, based on the criteria established in Internal Control - Integrated Framework of the Committee of Sponsoring Organizations of the Treadway Commission (2013).
Based on this assessment, management believes that, as of December 31, 2021, its internal control over financial reporting was effective based on those criteria.
C. Attestation Report of the Registered Public Accounting Firm
The effectiveness of the Company’s internal control over financial reporting as of December 31, 2021, has been audited by Pistrelli, Henry Martin y Asociados S.R.L., an independent registered public accounting firm, as stated in their report which is included on page F-4 to F-5 of this annual report.
D. Changes in Internal Control over Financial Reporting
There have been no changes in the Company’s internal control over financial reporting that occurred during the year ended December 31, 2021, that have materially affected, or are reasonably likely to materially affect, our internal controls over financial reporting.
ITEM 16. RESERVED
ITEM 16A. Audit committee financial expert
We have determined that Mr. Constantin Papadimitriou and Mr. Robert Bedingfield are independent, as such term is defined under SEC rules applicable to foreign private issuers. In addition, Mr. Robert Bedingfield is regarded as audit committee financial expert.
ITEM 16B. Code of Conduct
We have adopted a code of conduct applicable to the board of directors and all employees. Since its effective date on September 24, 2012, we have not waived compliance with or amended the code of conduct.
ITEM 16C. Principal Accountant Fees and Services
The independent registered public accounting firm for the fiscal year ended December 31, 2021, and December 31, 2020, was Pistrelli, Henry Martin y Asociados S.R.L. (member of Ernst & Young Global).
The following table provides detail in respect of audit, audit related, tax and other fees billed by the independent registered public accounting firm for professional services:
| | | | |
| | 2021 | | 2020 |
|
| | (in millions of US$) |
Audit fees | | 1.02 | | 0.93 |
Audit related fees | | 0.07 | | — |
Tax services fees | | 0.05 | | 0.04 |
Total | | 1.14 | | 0.97 |