Corporate governance
Ethics and Integrity
In our operations, we value business ethics and integrity and work in compliance with Brazilian legislation and the market in which we operate. We have a Code of Conduct, which guides the positioning of all our employees (permanent and outsourced) so that they work in a transparent, ethical, fair and equal manner. All internal regulations, policies published for shareholders (including compliance), statutes and codes are 100% approved by the members of the governance bodies.
Regularly, all employees undergo training on the Code through the compliance tool and in 2022, we carried out reviews and updates to our policies to ensure alignment with best practices. In the year, we also carried out several internal actions to disseminate and consolidate our Compliance Program. New employees are registered in a compliance training tool and have seven days to take the courses. All new employees must complete training on the Code of Conduct.
In 2022 edition, we implemented the Supplier Code of Conduct, available on the supplier portal for all suppliers who undergo compliance assessment. At the time of approval or reassessment on the supplier portal, all partners receive a copy of the document. For suppliers classified as risk 1, it is mandatory to sign the acknowledgment term.
Ethics and Sustainability Week
The ESG agenda gained space among the topics addressed at the Ethics and Sustainability Week, abesides compliance and risk management issues. Held in November, the event is essential to disseminate our organizational culture.fundamental para a disseminação de nossa cultura organizacional.
In this edition, Ethics Week received external speakers who addressed topics such as 'ESG applied to a business', 'The importance of ethics in corporations', 'Environmental Sustainability in focus', 'How to deal with harassment in the workplace' and 'Conflict of Interests' and featured awards and many activities. The event had over 70 simultaneous accesses in the lives and over 100 employees of the offices in the decompression area.
Ethics Channel
An exclusive service to report any practice thar may represent a violation of the Code of Conduct, in particular, fraud, corruption, moral harassment, discrimination, sexual harassment, or even acts that do not comply with current legislation.
Go to https://even.becompliance.com/canal-etica/canal-denuncias
It is up to the outsourced company to analyze each report received fairly and impartially. If confirmed, the complaint is informed to Even to adopt the necessary measures. All records receive a response, which can be found on the Channel itself, through the protocol informed at the time of the report.
Cases of misconduct requiring investigation and applying any disciplinary measures are dealt with by the Risk Management and Compliance area and discussed in the Audit Committees. Cases involving fraud, in turn, are reported and monitored directly by the Audit Committee, which may even rely on the collaboration of a specialized consultancy.
Risks and Compliance
The Risks and Compliance area evaluates compliance risks and specific risks related to Unethical Conduct, Corruption and Fraud. Its mission is to identify controls that can be improved and implement action plans to mitigate relevant risks.
In its work, the area is supported by the Compliance Program, a tool aimed at a system for mapping and mitigating ethics and integrity risks, with controls for preventing conflicts of interest and fighting corruption and money laundering. The program streamlines training and development actions for a culture of integrity in the Company and monitors policies and standards in line with the best market practices.
In 2022, we implemented the Compliance Risk Assessment (“CRA”) system, which makes it possible to diagnose and measure the classification of risks related to compliance, improving our internal controls.
The technological tool BeCompliance also went into operation this year and started to control the reporting of gifts, conflicts of interest, and records of interaction with public authorities, besides providing support for training on different compliance topics.compliance.
On another front, we maintain the Money Laundering Prevention Program. The tool allows us to identify possible operations that intend to use our products to hide the money of illicit origin.
The Company also has several policies related to the area, including:
Conflicts of Interest
We have a Conflict of Interest portal to identify situations of conflict of interest and report to the Compliance team to adopt mitigation measures. The portal has a conflict of interest registration system, via a form, filled out by employees before joining the Company – and renewed annually – and by suppliers in the due diligence process, which aims to identify, prevent and mitigate possible conflicts that may impact the Company.
All information collected is analyzed by the Compliance team and compiled in a database, which makes it possible to control and predict future conflicts of interest.