Program of Integrity and Ethics in Business
ECORODOVIAS INFRAESTRUTURA E LOGÍSTICA: CODE OF CONDUCT (2021-2023)
Program of Integrity and Ethics in Business
The EcoRodovias Group has put in place an Integrity Program that aims to curb, detect and remedy fraudulent actions and misconducts in the course of its business by focusing on such matters as the Brazilian anticorruption legislation, internal controls, and business management tools in an effort to mitigate the Company’s exposure to corruption risks.
Since 2015, our integrity program has stepped up its practices and standards by customizing work plans for distinct companies and teams so as to address anticorruption risk assessments at business unit level. Other rules were issued in addition to the Code of Conduct, such as the Anticorruption Guide; the Anticorruption Policy; the Normative Ruling on Disciplinary Measures; the Profile Report; and the Internal Rules of the Ethics Committee.
In 2018, the EcoRodovias Group revamped its Integrity Program and hired dedicated professionals knowledgeable in compliance matters; since then, the Group has taken several actions aimed at improving its governance framework as well as its Ethics and Integrity Program, to wit:
- Reviewing the code of conduct (2018-2020);
- Hiring intelligence systems to monitor and assess the compliance status;
- Developing new e-training and live training programs on compliance matters, targeted at colleagues and third contractors;
- Keeping a 24×7 anonymous reporting channel run by an independent company;
- Adopting a Policy on Interactions with Government Officials, along with implementing prevention controls and transparency practices for such interactions;
- Implementing a Policy on Control of Vendors, as well as a program for assessing and reassessing the reputation of business partners/vendors and their abidance by compliance standards;
- Implementing Policies on Gifts, Contributions and Entertainment, which set the guidelines for offering and receiving gifts, gratuities and entertainment, or sponsored travel and training;
- Implementing a Policy on Conflict of Interests, by which our colleagues are required to advise Compliance of any situation that may impair objective decision-making or else the Group’s independence in the course of its business;
- Implementing a Policy on Contributions and Sponsorships, which sets the guidelines for contributions and sponsorships of any kind;
- Implementing a Policy on Competition and Participation in Public Procurement, with clear guidance and rules on how to avoid anticompetitive practices;
- Reviewing the Policies on Supplies and Document Retention;
- Implementing an Ethics and Compliance Portal to monitor and coordinate all compliance-related initiatives and information;
- Opening a channel by which our colleagues and third contractors may interact with Compliance to clarify their doubts on compliance matters;
- Making periodical disclosure of our initiatives, controls, policies and procedures to all colleagues and third contractors.
Code of Conduct (2021-2023)
The Code of Conduct, to which the senior management of the EcoRodovias Group is highly committed, is updated every two years and is binding on all directors, officers, committee members, employees, third contractors, vendors, service providers, intermediaries and associate agents.
A breach of this code of conduct leads to the opening of a confidential probe into the purported misconduct, and may subject the offenders to such disciplinary measures as retraining; oral admonishment; written admonishment; suspension; dismissed without cause; and dismissal with cause, as provided in the Company’s internal normative ruling. A breach of this code of conduct by third persons may subject them to the penalties set out in the corresponding contracts, including termination of conduct and the end of business relations with the EcoRodovias Group.
Click here to access the Code of Conduct.
The EcoRodovias Group’s Code of Conduct is open to the public at the following website address:
Normative Ruling on Anti-Corruption and Anti-Bribery
The Normative Ruling on Anti-Corruption and Anti-Bribery was implemented to consolidate the EcoRodovias Group’s commitment to promote the fight against corruption and bribery in all its operations, based on clear and objective guidelines on the prohibited and expected conducts of the EcoRodovias Group’s employees and third parties, mainly with regards to the contact with Public Officers.
The EcoRodovias Group does not admit any form of corruption or bribery in its business and, therefore, prohibits the payment, promise or offering of improper advantage, directly or indirectly (through third parties), to public or private officers, customer representatives or third parties, or third parties related to them, with a view to obtaining improper benefits or business guarantees for the person or for the EcoRodovias Group.
Click here to access the Normative Ruling on Anti-Corruption and Anti-Bribery*.
The Ethics Channel
The EcoRodovias Group has an independent and confidential ethics channel by which our colleagues and third parties may report an actual or potential breach of the Code of Conduct. Anonymous reporting is possible, and no retaliation or punishment is permissible to those reporting in good faith and responsibly, as per item 9 of the Code of Conduct.
The Ethics Committee is tasked with receiving the reports on an actual or suspected violation of the Code of Conduct, conducting investigations and adjudicating on them, all of which in strict confidentiality.
It is incumbent on the Ethics Committee; (i) assessing whether the Code of Conduct is up-to-date and adequate, making the necessary adaptations when necessary; (ii) guiding and following up on the actions necessary for disclosure and dissemination of the Code; (iii) adjudicating on any breach of the Code of Conduct, with periodical reporting to the Board of Directors in this regard; and (iv) clarifying any doubts on correct interpretation of the Code of Conduct.